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EPA-450/2-90-014
Interim Summary Report of the State and
Promoted Initiative Program
FINAL REPORT
Prepared by:
C-E Environmental, Inc.
6320 Quadrangle Drive; Suite 100
Chapel Hill, N.C. 27514
Edited by:
David Painter
Noncriteria Pollutant Program Branch
Air Quality Management Division
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
February 1990
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This report has been reviewed by the Office of Air Quality Planning
and Standards, U. S. Environmental Protection Agency, and has been
approved for publication. Mention of trade names or commercial
products does not constitute endorsement or recommendation for use.
EPA 450/2-90-014
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TABLE OF CONTENTS
Executive Summary.
Appendix A - Summaries of Each High Risk Point Source Evaluation
Amalgamated Sugar - Idaho
American Chrome and Chemical - Texas
ASARCO - Colorado
ASARCO - Montana
Brookhurst Subdivision - Wyoming
Burroughs Helcome - North Carolina
Dow Chemical - California
Dow Chemical - Louisiana
First Chemical Corporation - Mississippi
Hoechst Celanese - Rhode Island
Hospital Haste Incinerators - New York
MacAlloy Corporation - South Carolina
Occidental Chemical Corporation - North Carolina
OMC Spruce Pine - North Carolina
Owens-Illinois - Ohio
PPG - West Virginia
Standard Chlorine - Delaware
Velsicol Chemical Corporation - Tennessee
Vista Chemical Corporation - Maryland
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Executive Summary
Background
In 1985, EPA issued an Air Toxics Strategy that, among other things, called
for the initiation of programs designed to assist State and local (S/L) air
pollution control agencies in their efforts, to regulate localized air toxics
concerns. One of the programs established as a direct result of the
implementation of the strategy is the high risk point source (HRPS) initiative
program. This program is funded by a portion of the grant funds that EPA
provides to S/L air pollution control agencies (i.e. section 105 grants).
Candidate sources to be investigated under the program are identified by either
EPA (referred to as a promoted initiative) or a S/L agency (referred to as a
state initiative). This document has been prepared to summarize the results of
some of the initially completed HRPS initiatives in order that the findings of
those studies may be shared with other air pollution control agencies which may
be interested in similar sources.
Discussion
The purpose of the HRPS initiative program is to provide opportunities to
S/L air pollution control agencies to conduct air toxics evaluations and use
the results of those analyses to make regulatory decisions regarding the need
to control facilities emitting air toxics. In this manner, S/L's developing air
toxics programs would understand the issues involved with such analyses.
Likewise, agencies with already-established programs would be better able to
address some of the issues that presented themselves during the course of their
HRPS evaluations.
In order for an individual project to be funded under the HRPS program,
a number of criteria had to be met. These include, but are not limited to, such
factors as the willingness of the S/L agency to conduct and document the
evaluation, the likelihood of EPA developing national emission standards
affecting the potential high risk source, the developmental status of the S/L
air toxic program, and, the likelihood that the source's emissions pose a high
risk to the surrounding populations.
Funding for each of the projects summarized herein ranged from $ 10,000
to $ 25,000. If similar projects were proposed by two or more S/L agencies, both
were generally not funded. It was assumed that the results of the selected
project would be shared with other S/L agencies. Selection of individual
projects was coordinated with the State and Territorial Air Pollution Program
Administrators and Association of Local Air Pollution Control Officials
(STAPPA/ALAPCO). Since a primary goal was to develop S/L air toxics programs,
agencies applying for funds were encouraged to perform the studies with in-
house personnel. However, at the request of some S/L agencies, some studies were
performed by contractors managed by EPA Regional Office personnel working closely
with the requesting S/L agency, which had the responsibility of making a
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regulatory decision.
During the 1986 through 1989 time period, sixty-six separate projects were
funded as part of the initiative program. These projects involved 37 different
States (including 4 local agencies) located in all of the ten EPA Regional
Offices and have involved the evaluation of at least 15 different types of source
categories.
Table 1 briefly summarizes each of the 19 projects that were initially
completed under the HRPS initiative program. For each project, there is a
listing of the source evaluated, the pollutants covered, whether or not emission
reductions were achieved, and whether or not health impacts have been quantified.
More complete discussions of each of these 19 projects are presented as an
appendix to this report.
The initial results from this program are encouraging, based on the
summaries of the HRPS projects that are included as part of this report.
Specifically, seven of these 19 projects have lead to emission reductions of
toxic air pollutants while other studies have had less tangible, but,
nevertheless, positive results. For example, fourteen of these projects have
resulted in the quantification of public health impacts associated with air toxic
emissions from the facility. In some States, conducting the HRPS evaluation
project represents a key milestone in the development and implementation of an
air toxics program. In other cases, the initiative projects resulted in the
implementation of pollution prevention programs as well as serving to enhance
and improve the coordination between EPA headquarters and Regional Offices.
While this report is intended to briefly summarize completed projects, it is
recommended that the reader contact the participating agency for further
information on any particular project of interest. The participating agency is
identified on each of the summary sheets.
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DISTRIBUTION OF INITIATIVES PROJECTS
by REGION
RMAPO2
Projects Funded as of Fall 1989
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Table 1
SUMMARY OF PROMOTED/STATE INITIATIVE STUDIES
SOURCE/STATE
POLLUTANT
HEALTH
EMISSION IMPACTS
REDUCTION QUANTIFIED
COMMENTS
AMALGAMATED SUGAR/ID
AMERICAN CHROME
& CHEM./TX
ASARCO - Globe/CO
ASARCO/MT
Cadmium
BROOKHURST SUBDIV.,
CASPER,WY
BURROUGHS WELLCOME/NC
Formaldehyde N
Other Aldehydes
Total Chromium Y
Hexavalent Chromium
Cadmium and cadmium
compounds
Arsenic N
Compounds.listed in N
Sara Title III
Methylene Chloride N
Y
Y
N
N
State plans follow-up study.
Additional controls installed
by the company were considered
acceptable.
Additional control device
added. Future additional
control devices to be
installed through CERCLA.
Implementation of the lead
SIP should reduce emissions
from the facility by 20-50%.
State issued notice
of violation to one of the
facilities. State will also
conduct ambient air monitoring
to detect toxic VOCs.
The risk level for the plant
emissions is considered
acceptable under the State's
guidelines.
Page 1 of 5
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Table 1 (Continued)
SUMMARY OF PROMOTED/STATE INITIATIVE STUDIES
SOURCE/STATE
DOW CHEMICAL/CA
POLLUTANT
HEALTH
EMISSION IMPACTS
REDUCTION QUANTIFIED
DOW CHEMICAL/LA
FIRST CHEMICAL CORP./MS
1,3-Butadiene,
Propylene Oxide,
Xylene,
Carbon tetrachloride
Perchloroethylene
Hexachlorobenzene
Chloroform
Methylene Chloride
Perchloroethylene
Carbon tetrachloride
Benzene
H
N
COMMENTS
Additional control
actions initiated, but
not aa a direct result of
this study. Recommendations
made for further emissions
reductions.
The actual throughput at
the plant is below the State
cutoff for requiring controls.
Additional controls (BACT) to
be installed on the production
facility. State is
negotiating with facility for
additional controls on the
storage tanks.
Page 2 of 5
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Table 1 (Continued)
SUMMARY OF PROMOTED/STATE INITIATIVE STUDIES
SOURCE/STATE
POLLUTANT
EMISSION
REDUCTION
HEALTH
IMPACTS
QUANTIFIED
COMMENTS
HOBCHST CELANESE/RI
HOSPITAL WASTE
INCINERATORS/NY
HACALLOY CORP./SC
Aniline N
Anieidine
3-3'Dichlorobenzidine
Nitro-o-aniaidine
Toluene
Ethylene dichloride
Ethylene oxide
Methylene chloride
o-Toluidine
Dioxins, Furans N
Arsenic
Cadmium
Chromium
Iron
Manganese
Nickel
Lead
Pathogens
Hexavalent Chromium Y
Risk estimate for acute
hazardous effect acceptable
to State. Evaluation of
current air toxics permit
to address further emission
reductions.
Study involved documenting
the process and analyses used
for developing State
regulations for hospital
incinerators.
Facility required to install
controls and ensure regulatory
compliance by Oct. 1, 1988.
Page 3 of 5
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Table 1 (Continued)
SUMMARY OF PROMOTED/STATE INITIATIVE STUDIES
SOURCE/STATE
POLLUTANT
HEALTH
EMISSION IMPACTS
REDUCTION QUANTIFIED
COMMENTS
OCCIDENTAL CHEM.
CORP./NC
OMC SPRUCE PINB/NC
OWENS-ILLINOIS/OH
PPG/WV
Hexavalent Chromium Y
Styrene
Styrene Oxide
Arsenic
Benzene
N
N
N
N
STANDARD CHLORINE/DE
Monochlorobenzene
Dichlorobenzene
Trichlorobenezene
N
Some controls initiated as a
result of study. Additional
controls currently under
evaluation.
Stack height increased and
fugitives routed to stack.
Facility is in compliance with
NC regulations.
Facility discontinued use of
arsenic as a result of the
study.
Current controls represent
BACT. Further emissions
reductions currently under
review. Storage tanks to be
included in future air toxic
regulations.
Study concluded no additional
controls required.
Page 4 of 5
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Table 1 (Continued)
SUMMARY OF PROMOTED/STATE INITIATIVE STUDIES
SOURCE/STATE
POLLUTANT
EMISSION
REDUCTION
HEALTH
IMPACTS
QUANTIFIED
COMMENTS
VELSICOL CHEMICAL CORP./TN
VISTA CHEMICAL CORP./MD
Hexachlorocy-
clopentadiene
Benzene, Chloride,
Toluene, Xylene,
Carbon tetrachloride
Chlorine
Chloroform
Ethylene dichloride
Hydrogen chloride
Methylene chloride
N
The etudy recommends per-
forming ambient monitoring and
obtaining an accurate
equipment count.
Benzene emissions
to be reduced over
the next five years,
including a 97% reduction
in benezene emissions
from the wastewater treatment
system.
Page 5 of 5
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APPENDIX A
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PROJECT SUMMARY SHEET
TYPE OF PROJECT: State Initiative FUNDING YEAR: FY 1987
PARTICIPATING AGENCY: Idaho Department of Health and Welfare
Telephone (208) 334-5898
SOURCE:. Amalgamated Sugar
LOCATION: Nampa, Idaho
POLLUTANTS: Formaldehyde
Other Aldehydes
EPA REGION: Region X
CONTRACTOR: PEI ASSOCIATES
APPROACH: Literature search, site visits, and engineering analysis to estimate
potential emissions and make recommendations for additional control.
Risk analyses were done for formaldehyde and acetaldehyde based on
monitoring data available to the State from the Integrated Air Cancer
Project.
PUBLIC INVOLVEMENT: No
RESULTS: Alternative controls were suggested for VOC sources within the
sugar beet processing operation. The State is planning to perform
stack sampling at the facility to quantify emmisions of other
aldehydes.
EMISSION REDUCTION: None yet.
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STATE INITIATIVE STUDY
STATE OF IDAHO
Background
During an emission inventory conducted in 1985, sugar beet processing
facilities were identified as potentially significant sources of formaldehyde
in Idaho. However, a recent inspection of one of these facilities suggests that
formaldehyde emissions may be lower than originally estimated. This State
initiative was undertaken to determine the validity of the original emissions
estimates.
Source
The Amalgamated Sugar processing plant in Nampa, Idaho was examined in this
initiative. (Amalgamated also operates two other sugar beet processing
facilities in the State.) Amalgamated Sugar's Nampa plant is the largest beet
sugar manufacturing plant in North America, processing about 1.4 million tons
of beets annually. In Idaho, sugar beet processing takes place from November
through February, and does not operate during the other months.
Chemicals Studied
The primary concern at the outset of this project was formaldehyde emissions.
In addition to studying formaldehyde emissions, it was determined that there were
numerous vents that emitted significant amounts of VOC, specifically aldehydes.
Study Approach
This study consisted of an analysis of Amalgamated's sugar manufacturing
process to determine the validity of emission estimates made in the 1985 emission
inventory and to determine the overall composition of these estimates. The
results of the analysis were also intended to help determine the need for and
methods to be used in quantifying organic emissions.
Sugar beet processing steps studied in this initiative are: beet receiving and
transfer; sugar extraction (diffusion); juice purification; juice S02 treatment;
juice evaporation; juice storage; sugar separation, drying and storage; and pulp
drying. Other emission sources are lime kilns (for conversion of limestone to
calcium oxide and C02) and coal storage. In addition to the process information,
the State was able to draw on ambient monitoring data for aldehydes (specifically
acetone, acrolein, formaldehyde, and acetaldehyde) collected in a four-day period
near the Nampa plant. This monitoring work was done as part of the Boise
Integrated Air Cancer Project. The monitoring data allowed the State to do risk
analyses for formaldehyde and acetaldehyde, two human carcinogens.
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Results
The sugar manufacturing process and types of emissions associated with each
step are documented in the contractor's report. That report noted that emission
estimates of VOC from many of the vents cannot be calculated because of lack of
test data. The total VOC emissions from the dryers can be calculated from the
back half of the particulate matter tests. These emissions are considered
condensable VOC compounds, which form visible plumes and impact the ambient total
suspended particulate matter levels at ambient temperatures. Formaldehyde
emissions from pulp drying are estimated to be 0.7 tons/yr and the total
condensable organics are estimated to be 12.47 tons/yr.
Risk analyses of the formaldehyde and acetaldehyde monitoring data performed
by the State indicated that human cancer risk near the Nampa facility may be
approximately 1 x 10"5.
Conclusions
The analysis led to several specific conclusions, principally noting further
work to be done or control devices to be added: (1) stack tests should be
conducted for VOC and condensable organics from the juice purification process,
evaporators, the pan boiler and vents for noncondensable gases; (2) species
composition should be determined for VOC and condensable organics emitted from
juice purification, evaporators, pan boiling, and pulp dryers; (3) ammonia mass
emission rates from evaporators and pan boiling vents should be determined; (4)
packed-bed scrubbers should be installed on evaporators and on the juice
precipitation process; (5) a presaturator should be installed on pulp dryer
scrubbers; (6) a fabric filter should be installed on the lime kiln auxiliary
fan; and (7) dust suppressants should be used on coal piles.
The IAQB has decided that the next step is to conduct source sampling at
Amalgamated Sugar for the purpose of developing additional source specific
information to develop permit restrictions, if necessary. The State has
concluded that source testing followed by modeling will give the best data in
an expedient time frame at the lowest cost.
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PROJECT SUMMARY SHEET
TYPE OF PROJECT: Promoted Initiative FUNDING YEAR: FY 1986
PARTICIPATING AGENCY: Texas Air Control Board (TACB)
Telephone (512) 451-5711
SOURCE: American Chrome and Chemicals, Inc. (AC&C)
LOCATION: Corpus Christi, Texas
POLLUTANTS: Total Chromium
Hexavalent Chromium
EPA REGION: Region VI
APPROACH: Comparison of monitored and modelled levels to the health effects
screening levels established by the TACB.
OTHER OBSERVATIONS: Because the modeled exceedances of the health effect levels
were in unpopulated areas and were predicted to occur
infrequently, the TACB determined that there is no reason
to implement controls over what the facility has already
committed to install.
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AMERICAN CHROME AND CHEMICALS
PROMOTED INITIATIVE STUDY
STATE OF TEXAS
Background
In 1987 the State of Texas was funded $15,000 to analyze total and hexavalent
chromium emissions from an American Chrome and Chemicals facility. This project
was initiated as the result of EPA's analysis of this facility which indicated
that, although public health risks associated with total and hexavalent chromium
emissions from this facility did not warrant the development of national federal
regulations, the risks were of a localized nature that may require regulatory
action at the state level.
Source
The facility is located in Corpus Christi, Texas and produces sodium
chromate, sodium bichromate, chromic acid and high-purity chromic oxide.
Chemicals Studied
Both total chromium and hexavalent chromium air emissions from the facility
were assessed in this study.
Study Approach
The TACB evaluated ambient air quality monitoring data for both total and
hexavalent chromium and performed dispersion modeling to estimate ambient levels
of hexavalent chromium. The TACB then compared the monitored and modelled data
to the health effects screening levels (HESL) established by the TACB for
airborne chromium (both total and hexavalent).
Results
The results of the state's analysis of the AC&C facility are contained in a
written report submitted to the Region VI EPA office dated April 13, 1987. The
major results of this study are contained in the following paragraphs.
The comparison of the ambient monitoring data for hexavalent chromium with
the HESL for hexavalent chromium revealed that no levels above either the short-
term or long-term health effects screening levels were measured. There was,
however, one site which measured an exceedance of the HESL for total chromium.
Based on this, the TACB performed an assessment of the actual population
exposures to chromium in the vicinity of the facility. In addition, the basis
for the HESL was also further examined.
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The results of this further analysis resulted in a revision of the HESL for
chromium in valence states other than +6. The revision was based on the fact
that, in this situation, the amount of hexavalent chromium in the air is known
whereas the original HESL was set to cover those situations in which the amount
of hexavalent chromium present is unknown. None of the measured levels of total
chromium exceed either the revised 30-minute or annual HESL.
The results of the dispersion modeling performed by the TACB for this
facility showed exceedances of both the short-term and annual HESL for hexavalent
chromium. However, both of these exceedances are limited to unpopulated areas
and the short term exceedance is expected to occur infrequently.
Conclusions
Since neither the hexavalent chromium nor total chromium HESL are exceeded
(based on the monitoring data) and because the TACB feels it is unlikely that
chromium levels significantly higher than those measured exist in the vicinity
of the facility, the TACB concluded, based on the monitored data, that
detrimental effects from exposure to measured levels of hexavalent and total
chromium in the vicinity of the AC&C facility are not expected.
Based on the initial results of dispersion modeling, the company committed
to install additional controls. The TACB concluded that the modeled
concentrations after installation of the additional controls are acceptable
principally because the exceedances occur in unpopulated areas. Furthermore,
the exceedance of the short-term HESL is predicted to occur infrequently.
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PROJECT SUMMARY SHEET
TYPE OF PROJECT: Promoted Initiative FUNDING YEAR: FY 1987
PARTICIPATING AGENCY: State of Colorado Department of Health
Telephone (805) 654-2806
SOURCE: ASARCO-Globe, Inc.
LOCATION: Denver, Colorado
POLLUTANTS: Cadmium and cadmium compounds.
EPA REGION: Region VIII
CONTRACTOR: Midwest Research Institute
APPROACH: Emissions estimates for cadmium and compounds were calculated by
using previous stack test data, engineering test data and
production data. These data were used in an ISCST dispersion
model to predict ambient concentrations using four different plant
scenarios involving current operation and maximum operation with
current controls and with additional controls. The output was
then used in an EPA Human Exposure Model (HEM) to predict the
associated health risk to the local community.
PUBLIC INVOLVEMENT: None
RESULTS: The results of the ISCST and HEM modeling showed that at the current
production rate, a 40% reduction (over current levels) in maximum
individual risk (MIR) would occur by adding additional emission
controls. Likewise, the predicted risks at the maximum production rate
showed that a 56% reduction in MIR would occur by adding additional
controls.
EMISSION REDUCTION: The facility has added an additional control device as a
result of this study.
OTHER OBSERVATIONS: The plant plans to install additional control devices in
the future through current CERCLA regulations and the State
will incorporate a cadmium standard in air toxic
regulations which are currently being developed.
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8
ASARCO-GLOBE
PROMOTED INITIATIVE STUDY
STATE OF COLORADO
Background
In 1987, the State of Colorado performed an analysis of cadmium and cadmium
compound emissions from an ASARCO-Globe, Inc. facility. This project was
initiated as the result of EPA's analysis of this facility in 1986 which
indicated that, although public health risks associated with emissions from this
facility did not warrant the development of national federal regulations, the
risks were of a localized nature that may require regulatory action at the state
level.
Source
The ASARCO-Globe facility is a primary cadmium refining facility located in
an industrial area on the northside of the city of Denver, Colorado. This
facility currently manufactures cadmium oxide powder and cadmium metal powder.
The plant also produces cadmium metal sticks by special order and cadmium sulfide
on an intermittent schedule.
Chemical Studied
The facility was analyzed for emissions of cadmium and cadmium compounds.
Study Approach
Cadmium and cadmium compound emissions were calculated for a number of sources
by the use of previous stack test data, engineering test data and production
data. The emission estimates reflect current operations and controls. The study
also evaluated the potential for emission reductions at each emission source. "
The emission estimates were used by the State in the Industrial Source Complex
Short Term (ISCST) dispersion model to predict the ambient concentrations at 162
receptor locations in the vicinity of the facility. Modeling was performed for
four different plant scenarios. These were: 1) current operation with existing
controls, 2) current operation with improved controls, 3) maximum operation with
existing controls, and 4) maximum operation with improved controls. The modeling
results were then used by the EPA in the Human Exposure Model (HEM) in order to
predict the associated health risk to the local community. The two measures
of risk which are calculated by the HEM model are the Maximum Individual Risk
(MIR) which is the risk of contracting cancer associated with an individuals
lifetime exposure to the highest predicted annual average ambient concentration,
and the Aggregated Risk (AR) which is an estimate of the increase in cancer cases
per year for the entire population within the study area based on a 70 year
continuous exposure.
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Results
The report submitted to the EPA Region VIII Office in September, 1987 details
the methodologies and results of the analysis. A summary of these results
follows.
The results of the HEM reflecting the current production rate with the
existing controls showed a MIR value of 5.4 x 10"4. A MIR value of 3.1 x 10"'
was predicted by modelling the facility at the current production rate with
improved controls. These results show that with the plant operating at the
current production rate with additional emission controls, a 42% reduction in
the current MIR from cadmium and cadmium compound emissions at this facility
would result.
The results of modelling plant emissions under maximum operation conditions
with existing controls and with additional controls showed a MIR value of 1.6
x 10~3 and 6.9 x 10~4, respectively. These results translate to a 56% reduction
in MIR through the implementation of improved reduction controls.
Conclusions
As a result of this study, the facility has added an additional control
device. In the future, the facility plans to install additional control devices
under the current CERCLA regulations. The State of Colorado is currently in the
process of developing air toxic regulations with plans to include an acceptable
standard for cadmium.
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PROJECT SUMMARY SHEET
TYPE OF PROJECT: Promoted Initiative FUNDING YEAR: FY 1987
PARTICIPATING AGENCY: Montana Department of Health and Environmental Services
Telephone (314) 854-6921
SOURCE: ASARCO Primary Lead Smelter
LOCATION: East Helena, Montana
POLLUTANTS: Arsenic and cadmium
! EPA REGION: Region VIII
CONTRACTOR: PEI Associates
APPROACH: The approach used involved the review and summarization of readily
available reports and data summaries on previous risk assessments
and ambient air quality data. A listing of available options for
reducing emissions from the facility was to be developed. The
evaluation was to be used by the State to evaluate the feasibility
of reducing cancer risks in the East Helena area.
PUBLIC INVOLVEMENT: No
RESULTS: The results are limited to identifying various considerations that
could be used to update the previous risk assessment and identifying
various recommendations for better assessment of air quality trends in
the Helena area.
EMISSION REDUCTION: Implementation of the lead SIP should result in a 20-50
percent emission reduction.
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11
ASARCO LEAD SMELTER
PROMOTED INITIATIVE STUDY
STATE OF MONTANA
Background
In 1987 the project was funded to analyze arsenic and cadmium emissions from
an ASARCO facility. This program was initiated as the result of EPA's analysis
of this facility which indicated that, although public health risks associated
with arsenic and cadmium emissions from this facility did not warrant the
development of national federal regulations, the risks were of a localized nature
that may require regulatory action at the state level.
Source
The facility is a lead smelter and is located in East Helena, Montana.
Chemicals Studied
Arsenic and cadmium emissions from the facility were examined in this study.
Study Approach
The approach used in this evaluation was to review available risk assessment
data and to provide an assessment of risk analyses which have been completed to
date. In addition, although not part of the original scope, a review of
available ambient monitoring data was performed to identify source contributions
and to examine the impact implementation of the lead SIP will have on ambient
concentrations and, ultimately, cancer risk. A list of technically and
economically feasible options for reducing cancer"risks in the East Helena area
was to be developed. This analysis is designed to be used by the State for
decisions on the feasibility of implementing strategies to reduce the cancer risk
from smelter emissions to the general population in the East Helena area.
Results
The results of the State's analysis of the ASARCO facility are contained in
a written report submitted to the Montana Operations Office of the EPA Region
VIII office dated September 30, 1987. The major results of this study are
contained in the following paragraphs.
The report prepared by a contractor recommends that the risk assessment
conducted by EPA be updated for three reasons:
l)the application of dispersion modeling in the Helena Valley has been
questioned,
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12
2) conditions at the ASARCO smelter have changed significantly since the
implementation of the lead SIP, and
3) chemical mass balance results show that fugitive emissions other than those
from the smelter contribute significantly to the total suspended particulate
levels in the East Helena area.
The report also recommends considering the procedures used to evaluate risks at
Superfund sites for determining what risk levels might be considered acceptable.
Regarding the analysis of ambient air quality data the report concluded that
assessment of the actual and potential improvement in the air quality in the East
Helena area resulting from the implementation of the lead SIP will require
additional data.
Conclusions
This study indicates that implementation of the lead SIP should result in a
20-50 percent reduction of lead emmisions from the facility.
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13
PROJECT SUMMARY SHEET
TYPE OF PROJECT: State Initiative
FUNDING YEAR: FY 1987
PARTICIPATING AGENCY:
Wyoming Department of Environmental Quality (DEQ)
Telephone (307) 777-7391
SOURCES: Nalco Chemical
Chemical Marketing Services
Little America Refinery Company (LARCO)
Dowel 1 Schlumberger
Kansas Nebraska Energy
Casper Sewage Treatment Plant
LOCATION: Brookhurst Subdivision of Casper, Wyoming
POLLUTANTS: Although hydrogen sulfide, mercaptan and benzene are the principal
pollutants of concern, the study addressed all compounds listed in
SARA Title III that are emitted from the six facilities that were
examined.
EPA REGION: Region VIII
CONTRACTOR: E.H. Pechan & Associates
APPROACH: The study involved conducting site inspections to allow the estimation
of emissions that are associated with the six facilities. Emissions
were estimated on the basis of actual source emission measurements,
if available, or using emission factors and source operating
parameters. Existing emission controls were also examined.
PUBLIC INVOLVEMENT: Yes
RESULTS: Emissions of total VOC and toxic air pollutants for each facility were
estimated.
EMISSION REDUCTION: None beyond that which is currently installed.
OTHER OBSERVATIONS: The source which caused the public complaints that led to
this study is now shut down and would be required to obtain
a new permit before resuming operation. The information
generated in this study could be used in atmospheric
dispersion modeling and in health risk assessment studies
in order to further evaluate potential public health impacts
associated with toxic air pollutants from the six facilities
included in the State initiative study. The evaluation did
result in the issuance of a notice of violation to LARCO.
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14
The State will follow-up the initiative with ambient
monitoring to detect toxic VOCs.
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15
BROOKHURST SUBDIVISION
STATE INITIATIVE STUDY
STATE OF WYOMING
Background
In 1987 the State of Wyoming proposed a study to evaluate air emissions of
toxic organic chemicals from several facilities in the Brookhurst area of Casper,
Wyoming. The project was nominated as a result of several citizen complaints of
odor and reported illness. Because the project was nominated by the State,
demonstrated progress by the State in developing and implementing an air toxic
program, and met the other criteria of the State initiative program, it was
funded by EPA as part of the State initiative program.
Source
Six industrial and municipal plants were included in this analysis. They
include:
* Little America Refinery Company - a 24,500 barrel per day crude oil
refinery;
* Nalco Chemical company - a specialty chemical mixing, handling, and storage
facility;
* Kansas Nebraska Energy - a natural gas processing facility;
* Dowell Schlumberger - an oil field servicing company;
* Casper Wastewater Treatment Plant - a 6 million gallon per day wastewater
treatment facility; and
* Chemical Marketing Services - a sulfuric acid storage and transfer facility.
All of these facilities are located near the Brookhurst subdivision and
emissions from these plants can be transported across the subdivision.
Chemicals Studied
Although three pollutants (hydrogen sulfide, mercaptan and benzene) were
identified by the DEQ as being of primary concern, the study analyzed total
volatile organic compounds (VOC) and individual air toxic compounds, including
those identified in the Toxic Release Inventory under Section 313 of the
Superfund Amendments and Reauthorization Act.
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Study Approach
On-site inspections were conducted in order to evaluate potential emission
sources, existing emission controls, and operating practices. This information
was supplemented with information from the plant operators in order to allow for
the estimation of emissions and to objectively evaluate the existing emission
controls. This study did not include conducting any ambient impact analysis or
health impact analysis to nearby human populations.
Results
The results of the State's analysis of the six facility are contained in a
written report submitted to the EPA Region VIII office dated January 1989. The
major results of this study are contained in the following paragraphs and are
presented on a facility by facility basis.
Little America Refining Co. - Both total VOC and individual toxic compound
emissions were estimated for this facility. Toxic air pollutant emissions were
estimated from both the SARA 313 data and from the application of available
emission factors. Individual chemicals that were included in the inventory
include: propylene, aluminum oxide, sodium hydroxide, chlorine, methanolamine,
ethylene, cyclohexane, benzene, toluene, ethyl benzene, xylene, 1,2,4,
trimethylbenzene, napthalene, ammonia, benzo-a-pyrene, and biphenyl. Although
data were identified that showed measurable concentrations of hydrogen sulfide
in various gas streams in the refinery, sufficient data were not available to
allow for estimation of hydrogen sulfide emission rates to the air.
Nalco Chemical - The report contains emission estimates for total VOC and
individual toxic compounds including toluene, xylene, methanol, isopropanol,
isobutanol and heavy aromatic compounds.
Kansas Nebraska Energy - Emissions estimates of ethane, propane, butane,
mercaptan and hydrogen sulfide are included in the report.
Powell Schlumberger - Hydrogen chloride emissions from the storage tank and
truck loading operations are presented. No discussion of control technology or
control costs for this facility are presented in the report.
Casper Wastewater Treatment Plant - The report contains an estimate of
hydrogen sulfide emissions from the flare.
Chemical Marketing Services - Because the vapor pressure of HC1 is negligible,
the report assumes that HC1 emissions from this facility are negligible.
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Conclusions
The report concludes that, according to the findings of the on-site surveys
and the estimated emissions of toxic air pollutants, there do not seem to be any
unusual or exceptional emissions during normal plant operations. However, it
is recognized that there may be periodic odor problems associated with certain
normal plant operations. Specifically, mercaptan was detected at the Kansas
Nebraska Energy facility and hydrogen sulfide may be emitted from this facility
and the refinery. Likewise, the report also notes that there exists the
possibility for puff or short-term releases of VOCs. The report also recognizes
the need for additional information on hydrogen sulfide and VOC in order to
estimate emissions associated with short-term upsets.
An enforcement action resulted as the result of the evaluation of the Little
America Refinery Company.
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PROJECT SUMMARY SHEET
TYPE OF PROJECT: Promoted Initiative FUNDING YEAR: FY 1987
PARTICIPATING AGENCY: North Carolina Division of Environmental Management
Telephone (919) 727-8060
SOURCE: Burroughs Wellcome
LOCATION: Greenville, North Carolina
POLLUTANTS: Methylene Chloride
EPA REGION: Region IV
APPROACH: Methylene Chloride emissions were estimated using mass balance
calculations. This data was then used in the EPA Human Exposure Model
(HEM) to estimate the human exposure and individual risk between 200
meters and 50 kilometers from the facility.
PUBLIC INVOLVEMENT: None.
RESULTS: The results of the HEM modeling showed that the maximum individual risk
of 8.3 x 10"6 for a 70 year lifetime exposure was better than the
acceptable risk value for methylene chloride (1 x 10~5).
EMISSION REDUCTION: None were required.
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BURROUGHS WELLCOME
PROMOTED INITIATIVE STUDY
STATE OF NORTH CAROLINA
Background
j In 1987, an analysis of methylene chloride emissions was performed at a
Burroughs Wellcome facility under the EPA Promoted Initiative study program.
This study was initiated as the result of EPA's analysis of this facility which
j indicated that, although public health risks associated with methylene chloride
: emissions from this facility did not warrant the development of national federal
regulations, the risks were of a localized nature that may require regulatory
i action at the state level.
Source
The Burroughs Wellcome facility is located in Greenville, North Carolina and
is involved in the manufacturing of pharmaceutical products.
Chemical Studied
t
Methylene chloride was the only chemical whose emissions were studied.
Study Approach
The facility was visited by representatives from the State in September 1987.
Based upon this visit and discussions with plant personnel, it was decided to
use mass balance calculations to estimate the methylene chloride emissions from
the facility (e.g. losses from both vents and fugitive emissions).
Engineering parameters of emission points were supplied by the facility and
both the calculated emissions rates and the parameters were used by the EPA as
input to the Human Exposure Model (HEM) to estimate the exposure and individual
risk to the general population between 200 meters and 50 kilometers from the
facility.
Results
The results of the evaluation are contained in a report submitted by the State
to the EPA Region IV office dated January 4, 1988. The results of the analysis
as documented in the report are provided in the following summary.
The mass balance calculations showed a 30.4% reduction in the 1984 emission
estimates originally used by the EPA in its analysis of the facility.
The HEM modeling predicted a maximum individual risk value of 8.3 x 10'6 for
a 70 year lifetime exposure to the estimated methylene chloride emissions from
this facility. Under North Carolina's guidelines, an individual risk of 1.0 x
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10"5 is acceptable for a Group B carcinogen. Since methylene chloride is a Group
B carcinogen, the predicted risk levels associated with methylene chloride
emissions from this facility were deemed acceptable.
The estimated population exposed was 288,000.
Conclusion
Based on the predicted maximum individual risk associated with methylene
chloride emissions from the facility in this study, no additional emissions
reduction from this facility was required by the State.
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PROJECT SUMMARY SHEET
TYPE OF PROJECT: Promoted Initiative
FUNDING YEAR: FY 1987
PARTICIPATING AGENCY: Bay Area Air Pollution Control District (BAAPCD)
Telephone (415) 771-6000
SOURCE: Dow Chemical Company
LOCATION: Pittsburg, California
POLLUTANTS: Carbon Tetrachloride
Perchloroethylene
1,3-Butadiene
Hexachlorobenzene
Methylene Chloride
Propylene Oxide
1,1,1-Trichloroethane
Trichloroethylene
Xylene
EPA REGION: Region IX
APPROACH: The study approach involved compiling an emissions inventory and
modeling these emissions in order to estimate public health cancer
risks.
PUBLIC INVOLVEMENT: No
RESULTS: In general, the cancer risk estimates generated in this study are lower
than previous estimates with the maximum individual risk estimated to
be in the 10'5 range.
Although this study alone did not directly result in the
installation of additional controls, the facility has
recently implemented a number of additional control actions.
EMISSION REDUCTION:
OTHER OBSERVATIONS: Recommendations for further study were made that included
reducing the uncertainty in the emissions inventory,
evaluating mitigation measures, conducting further ambient
monitoring, and developing emission estimates for additional
pollutants.
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DOW CHEMICAL COMPANY
PROMOTED INITIATIVE STUDY
STATE OF CALIFORNIA
Background
In 1987 the Bay Area Air Pollution Control District (BAAPCD) was funded to
analyze carbon tetrachloride (CT) and perchloroethylene (PCE) emissions from a
Dow Chemical Company facility. This project was initiated as the result of EPA's
analysis of this facility which indicated that, although public health risks
associated with CT and PCE emissions from this facility did not warrant the
development of national federal regulations, the risks were of a localized nature
that may require regulatory action at the state level.
Source
The facility is a synthetic organic production plant located in an
unincorporated area of Contra Costa County between the Cities of Pittsburg and
Antioch in the State of California. It consists of a number of different
operations producing a variety of products as listed below:
- The chlorine or chloralkali plant produces chlorine and caustic from brine;
- The pertet plant produces PCE and CT by the hydrocarbon chlorinolysis
process;
- The latex plant uses 1,3-butadiene in the production of latex;
- The symtet plant produces chlorinated pyrridines which are intermediate
products used in the production of pesticides; and
- The specialty chemicals plant which uses large amounts of methylene chloride
in the manufacture of specialty chemicals.
Chemicals Studied
Air emissions of carbon tetrachloride, perchloroethylene, 1,3-butadiene,
hexachlorobenzene, methylene chloride, propylene oxide, 1,1,1-trichloroethane,
trichloroethylene, and xylene from storage tanks, loading and handling
operations, process vents, equipment leaks, equipment openings, and wastewater
treatment were assessed in this study. Although CT and PCE were the chemicals
initially targeted for analysis, the BAAPCD expanded the evaluation to address
other chemicals emitted from the Dow facility.
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Study Approach
An emissions inventory for both point and area sources was developed through
the use of a variety of data sources including: various conversations with Dow
plant personnel, standard emission estimation techniques, the BAAPCD's existing
emissions inventory, and SARA Title III data. Two emission scenarios were used
in this study. The only difference between the two is the basis for the
estimation of fugitive emissions from equipment leaks. The first scenario uses
the values reported by Dow under SARA Title III while the second uses District
calculations based on the protocol recommended by EPA.
The Industrial Source Complex Long-Term (ISCLT) model was used to translate
the emission estimates into ambient pollutant impacts. The results of the
modeling were used to establish the spatial pattern of long-term average ambient
concentrations in the Pittsburg/Antioch area, to identify the maximum off-
property ambient pollutant concentrations and to identify the maximum ambient
concentration for locations where long-term human exposure would be expected to
occur, including surrounding occupational and residential areas.
Based on the estimated ambient impact analysis, two estimates of cancer risk
(inhalation pathway only) for both residential and occupational areas surrounding
the facility were calculated. These are the individual cancer risk (i.e., the
risk of an individual contracting cancer from continuous exposure for a lifetime
to the maximum predicted ambient concentration) and the excess cancer burden
(i.e., the increase in cancer cases in a population resulting from exposure to
one or more carcinogens).
Results
The results of the district's analysis of the Dow facility are documented in
a report dated July 1989. The major results of this study are contained in the
following paragraphs.
Spatial patterns of ambient concentrations were determined for those chemicals
with a maximum off-property impact greater than 0.5 ug/m3. Chemicals with off-
property impacts of less than 0.5 ug/m3 included 1,3 butadiene,
hexachlorobenzene, propylene oxide and xylene.
The maximum predicted residential cancer risk was 2.8 X 10'5 for emissions
scenario 1 and 7.8 X 10"s for emissions scenario 2. The maximum predicted
occupational cancer risk was 1.5 X 10'5 for emissions scenario 1 and 3.6 X 10"5
for emissions scenario 2.
The estimated residential excess cancer burden was 0.7 cases/lifetime for
emissions scenario 1 and 1.92 cases/lifetime for emissions scenario 2. The
estimated occupational excess cancer burden was 0.034 cases/lifetime for
emissions scenario 1 and 0.092 cases/lifetime for emissions scenario 2.
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Conclusions
The results of this evaluation were compared to EPA's previous analysis of
this facility, to a subregional dispersion modeling study (Contra Costa County
Air Toxics Exposure Study), and to previously gathered ambient air quality
monitoring data. The comparison to the previous EPA study reveals that the
estimated public health risks associated with emissions from the facility are
substantially less than previously estimated. The comparison to the subregional
study reveals that the emission estimates from this study were either within the
range of previous estimates or were substantially less than previous estimates
depending on the chemical examined. Ambient concentrations from the current
study compared reasonably well with impacts predicted in the subregional study;
however, the predicted impacts in areas where people can be exposed are
substantially lower in this study than in the subregional study. Finally, the
comparison to measured ambient data shows that the predicted levels fall within
the range of measured levels with the exception of PCE and MC which had
substantially lower levels predicted than measured.
The study resulted in a number of recommendations for further analyses. These
include reducing the emission inventory uncertainties, particularly with regards
to emissions from equipment leaks, evaluating mitigation measures beyond those
that have recently been implemented, conducting further ambient monitoring, and
developing emission estimates for several pollutants that were not included in
this study but which were included in Dow's SARA Section 313 report to the EPA.
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PROJECT SUMMARY SHEET
TYPE OF PROJECT: Promoted Initiative FUNDING YEAR: FY 1987
PARTICIPATING AGENCY: Louisiana Department of Environmental Quality (DEQ)
Telephone (504) 342-1201
SOURCE: Dow Chemical Corporation
LOCATION: Plaquemine, Louisiana
POLLUTANTS: Chloroform
Methylene chloride
Perchloroethylene
Carbon tetrachloride
EPA REGION: Region VI
APPROACH: The evaluation consisted of performing an inspection of the
handling, loading and storage operations of the facility.
PUBLIC INVOLVEMENT: No
RESULTS: Both continuous and episodic emissions from equipment leaks, storage
tanks, process vents, and loading operations were quantified.
EMISSION REDUCTION: None beyond that which is currently installed.
OTHER OBSERVATIONS: The loading facility is uncontrolled because the actual
loading rate (26,000 gpd) is below the State cutoff
(40,000 gpd) for requiring VOC controls.
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DOW CHEMICAL COMPANY
PROMOTED INITIATIVE STUDY
STATE OF LOUISIANA
Background
In 1987 the State of Louisiana analyzed emissions from a Dow Chemical Company
facility. This project was initiated as the result of EPA's analysis of this
facility which indicated that, although public health risks associated with the
emissions of four organic compounds from the handling, loading and storage
operations of this facility did not warrant the development of national federal
regulations, the risks were of a localized nature that may require regulatory
action at the state level.
Source
The facility is located in Plaquemine, Louisiana and produces a variety of
chlorinated hydrocarbons.
Chemicals Studied
Air emissions of chloroform, methylene chloride, perchloroethylene and carbon
tetrachloride from equipment leaks, storage tanks, process vents, loading
operations, equipment openings, handling operations and pressure relief
discharges were examined in this study.
t
i Study Approach
I An inspection of the facility was conducted to obtain information on
j estimates of emissions of the four compounds from the handling, loading and
' storage areas of the facility. Members of the Dow environmental group assisted
j in the collection of data and documents during the inspection. This study did
j not include conducting any ambient impact analysis or health impact analysis to
: nearby human populations.
Results
The results of the state's analysis of the Dow facility are contained in a
written report submitted to the EPA Region VI office dated December 2, 1987.
The major results of this study are contained in the following paragraphs.
Both routine and episodic emissions were quantified from equipment leaks,
process vents, storage tanks and loading operations. Of these sources, the
loading operations are responsible for approximately 50 percent of the emissions
of the four compounds examined. On an individual chemical basis, equipment leaks
are the largest source of perchloroethylene and carbon tetrachloride emitting
53 and 33 percent of the total emissions of these compounds, respectively.
Likewise, loading operations are the largest source of methylene chloride and
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chloroform emitting 55 and 58 percent of the total emissions of these compounds,
respectively. No differentiation between routine releases and episodic releases
was made.
The analysis also revealed that only 0.08 percent of the equipment has leaks.
Also identified was the fact that the loading facilities do not have a vapor
recovery system installed. This is attributable to the fact that the throughput
of the operation is below the 40,000 gallon per day exemption level specified
in Louisiana's regulation.
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PROJECT SUMMARY SHEET
TYPE OF PROJECT: Promoted Initiative FUNDING YEAR: FY 1986
PARTICIPATING AGENCY: Mississippi Department of Natural Resources, Bureau of
Pollution Control-- Telephone (601) 961-5171
SOURCE: First Chemical Corporation
LOCATION: Pascagoula, Mississippi
POLLUTANTS: Benzene
EPA REGION: Region IV
APPROACH: The State used updated emissions data reflecting current controls and
additional controls on two storage tanks provided by the facility as
input into a modified CRSTER model for determining the predicted annual
ambient concentrations between 1-10 kilometers from the plant. These
results were then used to predict the cancer risk to an individual by
using the unit risk value for benzene.
PUBLIC INVOLVEMENT: No
RESULTS: Initial modeling of ambient concentrations and subsequent risk analysis
showed the maximum individual risk to be 7.45 x 10"5 which was
considered by the State to be an acceptable level. The results of
modeling with additional controls showed an approximate one-third
reduction in the maximum individual risk level (e.g. 2.6 x 105).
EMISSION REDUCTION: The State is currently negotiating with the facility for
additional controls to be employed on the two fixed storage
tanks.
OBSERVATIONS: The State is requiring the facility to install Best
Available Control Technology (BACT) equipment on part of
the production facility which was destroyed by a fire.
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FIRST CHEMICAL CORPORATION
PROMOTED INITIATIVE
STATE OF MISSISSIPPI
Background
In 1986, the State of Mississippi was provided funding by the EPA in order
to study benzene emissions from a First Chemical Corporation facility. This
study was initiated as a result of an EPA analysis of the facility which
indicated that the health risks associated with emissions from the facility did
not warrant the development of national federal regulations. Instead, the risks
were of a localized nature that may require regulatory action at the State level.
The First Chemical Corporation facility is located in Pascagoula, Mississippi
and is involved in the production of organic chemicals.
Chemical Studied
Benzene is the only chemical whose air emissions were analyzed.
Study Approach
The State compiled an initial emissions inventory of the facility and
requested the facility to supplement and update the inventory. This updated
inventory was then used by the State in a modified CRSTER model for determining
the annual ambient concentrations at receptor locations between 1-10 kilometers
(at one kilometer distances) from the center of the facility. The predicted
concentrations were then used to estimate the cancer risk to an individual by
multiplying the unit risk value for benzene by the estimated ambient
concentrations.
A second emissions modeling and risk analysis was conducted to reflect
additional controls (representing a 90% recovery) on two large fixed benzene
storage tanks.
Results
The results of the evaluation are contained in a report submitted by the
State to the EPA Region IV office dated September 30, 1986. A brief summary of
the report follows.
The maximum individual risk calculated from the first model run (e.g. without
additional controls on the storage tanks) was 7.45 x 10"5. This risk value was
determined by the State to be an acceptable level but since the majority of
benzene emissions originated from the two fixed storage tanks, the State modeled
the facility by incorporating additional controls on the two storage tanks (e.g.
a vapor recovery system or conversion to an internal floating roof). The results
of this second model run showed that the maximum individual risk level dropped
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30
to a value of 2.6 x 10"5 (an approximate one third decrease from the first
model ing results).
Conclusions
j When this report was prepared, the State was negotiating with the First
Chemical Corporation for additional controls on the two benzene storage tanks.
The State will also require the facility to install Best Available Control
Technology (BACT) on the part of the production facility that was destroyed by
a fire.
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PROJECT SUMMARY SHEET
TYPE OF PROJECT: State Initiative
FUNDING YEAR: FY 1987
PARTICIPATING AGENCY: Rhode Island Department of Environmental Management (DEM)
Telephone (401) 277-2808
SOURCE: Hoechst Celanese
LOCATION: Coventry, Rhode Island
POLLUTANTS:
Aniline
o-Anisidine
3-3'-Dichlorobenzidine
5-Nitro-o-anisidine
Toluene
Ethylene dichloride
Ethylene oxide
Methylene chloride
o-Toluidine
EPA REGION: Region I
APPROACH: Comparison of modeled ambient concentrations with acceptable
ambient levels (AAL) contained in Regulation 22.
PUBLIC INVOLVEMENT: Yes
RESULTS: Initial modeling showed ambient concentrations for four of the
compounds to below the AALs. More refined modeling showed one
additional compound to have predicted ambient levels below the AAL,
while the remaining four compounds had predicted ambient
concentrations greater than the AAL but below the AAL for sources
with the lowest achievable emission rate (LAER).
EMISSION REDUCTION: Pending. More analysis will be conducted as the current
operating permit is further evaluated for compliance with
the new toxics regulation.
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HOECHST CELANESE
STATE INITIATIVE STUDY
STATE OF RHODE ISLAND
Background
In 1987 the State of Rhode Island proposed a study of air emissions and
resulting impacts from a chemical manufacturing facility owned and operated by
the Hoechst Celanese Corporation. The project was nominated because of the large
number of toxic substances used at the facility and because of the proximity of
the facility to residential areas. Because the project was nominated by the
State, involved the implementation of Rhode Island's air toxic regulation, and
met the other criteria of the State initiative program, it was funded by EPA as
part of the State initiative program.
Source
This facility is located in Coventry, Rhode Island and is involved in the
manufacturing of dyes, pigments and Pharmaceuticals. The facility consists of
eight production buildings, a wastewater treatment plant and some ancillary
buildings. The facility is bordered by residential neighborhoods and the
Pawtuxet River.
Chemicals Studied
Through inventory records and ambient monitoring data, the Department of
Environmental Management (DEM) determined that 11 out of 40 toxic substances
which are regulated under Rhode Island's Air Toxic Regulation 22 are used or
emitted at the Hoechst Celanese facility. Of these 11 toxic substances
identified, an impact analysis was performed on 9 of these substances. The 9
chemicals studied were aniline, o-anisidine, 3-3'-dichlorobenzidine, 5-nitro-
o-anisidine, toluene, ethylene dichloride, ethylene oxide, methylene chloride
and o-toluidine. The other two identified chemicals, chloroform and hydrogen
chloride, were dropped from consideration because the process emitting the
chloroform was discontinued and because it was considered unlikely that the
quantities of hydrogen chloride used at the facility would result in an
exceedance of the corresponding acceptable ambient level (AAL).
Study Approach
The company was requested by the State to identify all emission points and to
provide the emission rates and stack parameters at each of these points. Hoechst
Celanese calculated the emission rates by using at least two methodologies (e.g.
materials balance, emission factors, engineering calculations). The selection
of a specific method depended upon the type of emission point evaluated. Hoechst
Celanese also provided the DEM with other information such as building dimensions
for the purposes of air quality modeling.
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Air emissions modeling was then performed by DEM in order to determine the
impacts at and beyond the site boundary. Once the predicted impacts were
determined for each of the 9 chemicals studied, they were then compared to the
corresponding AAL specified in Regulation 22. It should be noted, that for some
chemicals, Regulation 22 contains an additional AAL to be applied to those
facilities which have been determined to have installed LAER. Where the ambient
concentration for a particular chemical was predicted to be hi.gher than the AAL,
a more refined modeling approach was used.
Public involvement in this study consisted of a group representing State
government, the community and industry agreeing to review the study throughout
its progression. This group meets on a monthly basis and reviews and comments
on issues related to health impacts from the Hoechst Celanese plant.
Results of the Impact Analysis
The results of the analysis of the Hoechst Celanese facility were documented
in a report submitted to the Region I EPA office on April 5, 1989. The major
conclusions of that report are summarized in the following paragraphs.
The predicted ambient concentration for aniline, o-anisidine, 3,3'-
dichlorobenzidine, 5-nitro-o-anisidine and toluene were found to be substantially
below the AAL's as referenced in Regulation 22.
Because the initial predicted ambient concentrations for ethylene dichloride,
ethylene oxide, methylene chloride and o-toluidine were above the corresponding
AAL, these chemicals were evaluated using the refined model. With the exception
of o-toluidine, which was an order of magnitude lower than the AAL, the predicted
concentrations for these chemicals, based on the refined modelling, were still
greater than the AAL but were lower than or approximately equal to the AAL for
sources with LAER.
Conclusions
Overall, it was determined that the emissions of chemicals which were studied
would not pose any acute hazardous situation to neighboring residents. In
addition, the report concluded that the final determination for emissions
reductions at this facility"will be dependent on the resolution of various
issues, such as the verification of the emissions data and the examination of
additional emission points. The final outcome will be reflected in a revised
operating permit for the faciltily.
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PROJECT SUMMARY SHEET
TYPE OF PROJECT: State Initiative FUNDING YEAR: FY 1987
PARTICIPATING AGENCY: New York State Department of Environmental Conservation
Telephone (518) 457-7230
SOURCE: Hospital waste incinerators
LOCATION: Not applicable
POLLUTANTS:Polychlorinated dioxins
Furans
Arsenic
Cadmium
Chromium
Iron
Manganese
Nickel
Lead
Pathogens
EPA REGION: Region II
APPROACH: The purpose of this study was to document the development of
regulations controlling hospital waste incinerators. As such, the
approach used was to compile materials documenting the process that
New York followed in developing the. regulations as well as
presenting the approach "at two EPA-sponsored workshops on hospital
waste incinerators.
PUBLIC INVOLVEMENT: There was public involvement in the development of the
regulations, but not as part of the initiative.
RESULTS: The State Initiative study resulted in the documentation of the
process and the analyses that were part of the development of
proposed State regulations for new and existing hospital waste
incinerators. These materials included the Environmental Impact
Statement for the proposed regulations, a draft report on New York's
infectious waste plan, a risk analysis of emissions from a
hypothetical waste incinerator, and a copy of New York's Air Guide-
1. These materials were also presented at two EPA-sponsored hospital
waste incinerator workshops for state and local air pollution control
agencies.
EMISSION REDUCTION: Control will result once the regulations are implemented.
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STATE INITIATIVE STUDY
DEVELOPMENT OF INCINERATOR REGULATIONS
STATE OF NEW YORK
Background
In 1987, the State of New York received EPA grant money in order to document
the process of developing regulations for hospital waste incinerators (HWI).
The grant conditions required that two specific areas (i.e., source
characterization and source control) be included in the documentation. Source
characterization includes identifying sources of information needed to determine
what toxic and pathogenic substances may be emitted in hospital incineration and
identifying what public health risks may be associated with toxics and pathogens
that can be released from hospital waste incinerators. Source control includes
listing possible control options for hospital waste incinerators and listing the
steps that New York followed in selecting a means of controlling hospital waste
incinerator emissions. The initiative also required the State to present their
experience at two EPA-sponsored workshops on hospital waste incineration.
Source
No one specific source was the subject of this initiative, however, emissions
data and engineering parameters from an incinerator at Cedar Sinai Medical Center
located in Los Angeles, California was used as the basis for estimating the
health risks associated with hospital waste incinerators.
Chemical Studied
The emissions of polychlorinated dioxins and furans, and metals of arsenic,
cadmium, chromium, iron, manganese, nickel and lead were included in the risk
assessment.
Study Approach
The approach consisted of compiling a variety of documents that address the
characterization of hospital waste incinerators and the public health risks
associated with HWI emissions. Documents describing the process that New York
followed in developing regulations for hospital waste incinerators were also
compiled. The State presented the results of its investigation of hospital waste
incinerators at two EPA-sponsored workshops on HWIs.
Results
The results of the initiative are documented in a letter dated September 20,
1988 and submitted to the EPA Region II Office. Included in this documentation
are copies of the final environmental impact statement for the proposed
regulations on incinerators, dated August 1988; a preliminary draft of the State
of New York's infectious waste plan; a report entitled "Air Quality Impacts from
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a Hospital Incinerator", which presents public health risks that can be
associated with hospital waste incinerator emissions; and a copy of New York's
Air Guide-1.
The health impact analysis showed that dioxin compounds could pose a
significant carcinogenic risk with or without controls and arsenic and cadmium
emissions present a significant risk in the absence of particulate controls.
Lead emissions were found to have a significant noncarcinogenic impact especially
without the use of controls.
Conclusion
The proposed regulations establish limits for new and existing municipal and
private solid waste incinerators as well as for all infectious waste
incinerators. Limits for particulates, hydrogen chloride, dioxin, and visible
emissions are included. Minimum operating temperatures were included in the
proposed regulations to improve combustion. Monitoring, stack testing,
reporting, and operator training programs are also included.
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PROJECT SUMMARY SHEET
TYPE OF PROJECT: Promoted Initiative FUNDING YEAR: FY 1987
PARTICIPATING AGENCY: South Carolina Department of Health and Environmental
Control (DHEC)
Telephone (803) 734-4750
SOURCE: MacAlloy Corporation
LOCATION: Charleston, South Carolina
POLLUTANTS: Hexavalent Chromium
EPA REGION: Region IV
APPROACH: The study approach involved the use of a more refined dispersion
model to estimate public health risks and the formation of a task
force to review and evaluate the results of a series of source
inspections.
PUBLIC INVOLVEMENT: No
RESULTS: The detailed dispersion modeling indicates that maximum individual
risk is estimated to be 1.3 x 10'% roughly an order of magnitude
increase over the previous estimate. The source inspections
revealed a series of poor control practices including some
violations of South Carolina's air quality control regulations.
EMISSION REDUCTION: As a result of a consent order, MacAlloy was required to
install a variety of controls and achieve compliance with
all applicable regulations and permit requirements by
October 1, 1988.
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MACALLOY CORPORATION
PROMOTED INITIATIVE STUDY
STATE OF SOUTH CAROLINA
Background
In 1987 the State of South Carolina analyzed hexavalent chromium emissions
from the Macalloy Corporation facility. This study was initiated as the result
of EPA's analysis of this facility which indicated that, although public health
risks associated with hexavalent chromium emissions from this facility did not
warrant the development of national federal regulations, the risks were of a
localized nature that may require regulatory action at the state level. In
addition, Macalloy has received several citations for excess emissions.
Source
The facility is located in Charleston, South Carolina and is involved in the
manufacture of ferroalloys.
Chemicals Studied
Hexavalent chromium air emissions from all emission sources within the
facility was the only chemical assessed in this study.
Study Approach
The approach to the evaluation of the Macalloy facility involved conducting
an exposure and risk assessment and conducting a number of site inspections.
The risk assessment was performed by EPA using the Industrial Source Complex -
Long Term (ISCLT) dispersion model coupled with the Human Exposure Model (HEM).
The emissions data used for the risk assessment was the same as that used by EPA
in their analysis of the facility. However, the meteorological station used was
different.
In addition to conducting a more refined risk assessment, the South Carolina
DHEC convened a task force to conduct site investigations, to evaluate specific
problems and to identify potential corrective actions.
Results
The results of the State's analysis of the Macalloy facility are contained in
a written report submitted to the EPA Region IV office dated April 20, 1989.
The major results of this study are contained in the following paragraphs.
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The more detailed risk assessment using a more refined dispersion model and
more representative meteorological data results in an increase in the maximum
individual risk from 1.7 x 10'3 to 1.3 X 10'2.
The site inspections found that the major source of emissions from the
facility is the furnace building. A number of violations of applicable
regulations were observed and several malfunctions and operational problems with
the control equipment and control practices at the facility were noted. As a
result of the evaluation Macalloy was notified by DHEC that it did not intend
to renew its operating permit.
In response to the notification of the DEHC's intent not to renew the
operating permit of the facility, Macalloy prepared and submitted a formal plan
for assuring compliance with applicable regulations. This plan was incorporated
into a consent decree and required Macalloy to install additional control
equipment and to modify certain operations at the facility to reduce plant
emissions.
Specifically, the Macalloy Corpaoration has agreed to:
1) install hood extensions on electric furnaces #14 and #15,
2) the addition of a third baghouse,
3) modify dust handling to incorporate slurrying,
4) the addition of water sprays to minimze fugitive dust,
5) construct a windscreen to minimize fugitive dust and enhance the efficiency
of the hoods, and
6) operate a truck to spray roadways.
Conclusions
A quantitative estimate of emission reduction resulting from these additional
controls was not calculated. All regulations and permit requirements were to
be complied with by October 1, 1988.
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PROJECT SUMMARY SHEET
TYPE OF PROJECT: Promoted Initiative FUNDING YEAR: FY 1987
PARTICIPATING AGENCY: North Carolina Division of Environmental Management
Telephone (919) 733-3340
SOURCE: Occidental Chemical Corporation
LOCATION: Castle Hayne, North Carolina
POLLUTANTS: Hexavalent Chromium
EPA REGION: Region IV
APPROACH: The study involved a number of different methods for analyzing the
public health impacts of the facility. In addition to updating
emission estimates, performing dispersion modeling and estimating
public health risks through EPA's Human Exposure Model (HEM), these
methods included assessing chromium exposures to plant tissue in
areas surrounding the facility and examining data on respiratory
tract cancer mortality in the state.
PUBLIC INVOLVEMENT: No
RESULTS: Based on the results of the various analytical methods used to assess
the public health impact of the facility, the state has made six
specific recommendations for improved control of hexavalent chromium
emissions at the facility.
EMISSION REDUCTION: The facility has implemented some changes (e.g.,
decreasing the chrome concentration in the recirculating
water) in response to the recommendations contained in
the report and is evaluating other changes, including
the installation of additional control equipment.
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OCCIDENTAL CHEMICAL CORP.
PROMOTED INITIATIVE STUDY
STATE OF NORTH CAROLINA
Background
In 1986 the State of North Carolina analyzed hexavalent chromium emissions
from an Occidental Chemical Corporation facility. At the time of the study, the
facility was owned by the Diamond Shamrock Chemical Corporation. This study
was initiated as the result of EPA's analysis of this facility which indicated
that, although public health risks associated with hexavalent chromium emissions
from this facility did not warrant the development of national federal
regulations, the risks were of a localized nature that may require regulatory
action at the state level.
Source
The chemical plant is located in Castle Hayne, North Carolina and is involved
in the production of chromium chemical compounds. Emissions from the following
operations in the facility were evaluated as part of this study: chromate ore
drying, residue drying, chromate roasting, chromate quenching, chromate ore
grinding, sodium sulfate drying, bichromate crystallizing, chromic acid
production, chromic acid filtration and chromic acid packaging.
Chemicals Studied
Air emissions of hexavalent chromium (Cr**) were analyzed in this study.
Study Approach
The State used a variety of methods in assessing hexavalent chromium
emissions from the facility. Specifically, these included conducting plant
inspections and updating current emissions data to reflect actual production
rates. These revised emission estimates were used as input for the ISCLT
dispersion model, with the output of the dispersion model being used by EPA in
the Human Exposure Model (HEM) in order to estimate exposures and cancer risks
to the population living within 50 kilometers of the facility.
In addition to the above-mentioned methods, the state also took samples from
pine trees at various distances from the facility and analyzed these samples for
chromium content. The state also examined data from the North Carolina Division
of Health Services on respiratory tract cancer mortality rates in the State.
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Results
The results of the State's analysis are documented in a report dated
September 16, 1986. The report, which was submitted to the EPA Region IV office,
contains the state's recommendations for controlling chromium emissions from the
facility. A summary of the results and the State's recommendations are contained
in the following paragraphs.
The results of the HEM indicated that, based on the revised emission
estimates, the maximum individual lifetime cancer risk increased over the
previous estimate from 1.8 x 10_3 to 8.7 x 10.3 and the annual incidence has
increased from 0.07 to 0.14. The analysis of hexavalent chromium in the plant
tissues revealed detectable levels of chromium in pine trees in the vicinity of
the facility.
Based on the results of the analysis, the state made a number of
recommendations for reducing hexavalent chromium emissions from the plant.
Specifically, these included the following:
1. Using clean water in the scrubbers instead of recycled process liquors,
2. Installing improved mist eliminators on the scrubbers,
3. Performing improved, regular maintenance on the electrostatic
precipitators,
4. Controlling chromic acid emissions,
5. Implementing improved operator training and operation techniques to
prevent spills and overflows, and
6. Implementing a regular maintenance schedule to help prevent leaks and/or
eruptions.
Conclusions
Although measures have been taken to reduce the emissions of hexavalent
chromium from the Castle Hayne, North Carolina facility, the reductions could
not be quantified. The facility has, however, committed to implement additional
improvements in equipment and procedures to further reduce hexavalent chromium
emissions.
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PROJECT SUMMARY SHEET
TYPE OF PROJECT: State Initiative FUNDING YEAR: FY1988
PARTICIPATING AGENCY: North Carolina Division of Environmental Management (DEM)
Telephone (919) 733-3340
SOURCE: OMC Spruce Pine, Inc.
LOCATION: Spruce Pine, North Carolina
POLLUTANTS: Styrene
Styrene oxide
EPA REGION: Region IV
APPROACH: The study involved performing a stack test of the facility as well
as performing dispersion modeling of the stack test results.
Monitoring of the ambient air in the vicinity of the facility was
also performed.
PUBLIC INVOLVEMENT: No
RESULTS: The stack testing results showed detectable levels of styrene but no
detectable levels of styrene oxide. The dispersion modeling predicted
ambient levels above the threshold odor limit. The monitoring results
showed measurable concentrations of both styrene and styrene oxide in
the ambient air in the vicinity of the facility.
EMISSION REDUCTION: The main stack at OMC was raised and some of the
fugitive emission sources were routed to the main stack
as a result of this investigation.
OTHER OBSERVATIONS: The facility was determined to be in compliance with
applicable air quality regulations of the State of North
Carolina.
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OMC SPRUCE PINE, INC.
STATE INITIATIVE STUDY
STATE OF NORTH CAROLINA
Background
The State of North Carolina Division of Environmental Management (DEM)
conducted a study of the OMC Spruce Pine facility. The study was initiated as
the result of numerous complaints concerning fumes and odors from nearby
residents. The study was funded by EPA through a grant under EPA's state
initiative program.
Source
The facility is a manufacturing plant located in Spruce Pine, North Carolina.
The plant is near a residential area and an elementary school. The Asheville
Regional Office of DEM has received numerous complaints from nearby residents.
Chemicals Studied
Styrene and styrene oxide air emissions from the facility were the only two
chemicals assessed in this study.
Study Approach
The study consisted of performing stack sampling and ambient monitoring to
determine if measurable amounts of styrene and/or styrene oxide exist in the
stack emissions and ambient air. The study also involved performing dispersion
modeling of stack emissions based on the results of the stack sampling.
The study is intended to be a follow-up to an investigation conducted in May
1987 which discovered measurable amounts of styrene and styrene oxide in the
ambient air outside the OMC property boundaries. Since the previous
investigation the facility has raised its stack an additional 86 feet and has
routed some fugitive emission sources to the stack.
Results
The results of the State's analysis of the OMC facility are contained in a
written report submitted to the EPA Region IV office, dated December 3, 1987.
The major results of this study are contained in the following paragraphs.
The stack testing results showed detectable levels of styrene but no
detectable levels of styrene oxide. The dispersion modeling predicted ambient
levels of styrene above the threshold odor limit at locations outside OMC
property boundaries. Finally, the ambient monitoring results show a presence
of both styrene and styrene oxide in the ambient air in the vicinity of the
facility.
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Conclusions
The study has resulted in two conclusions. First, the facility was not in
violation of any applicable air quality regulations. Second, the measured
ambient concentrations of styrene oxide were possibly due to atmospheric
reactions since the stack testing results did not indicate the presence of
styrene oxide.
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PROJECT SUMMARY SHEET
TYPE OF PROJECT: Promoted Initiative FUNDING YEAR: FY 1987
PARTICIPATING AGENCY: Ohio Environmental Protection Agency
Telephone (614) 644-2270
SOURCE: Owens-Illinois, Libby Glass Division
LOCATION: Toledo, Ohio
POLLUTANTS: Arsenic
EPA REGION: Region V
Contractor: PEI ASSOCIATES
APPROACH: The study involved estimating arsenic emissions from the facil ity;
predicting, through dispersion modeling, ambient arsenic
concentrations based on the emission estimates; and estimating
public health risks associated with arsenic emissions from the
facility.
PUBLIC INVOLVEMENT: No
RESULTS: The evaluation showed that the major source of arsenic emissions at
the facility is the seven glass melting furnaces that are currently
in operation. Modeling of these furnace emissions results in maximum
individual cancer risks of 2.3 X 10~4 and 4 X 10"5 for the uncontrolled
and controlled scenarios, respectively. Annual incidence was 0.017
and 0.0026 cancer cases for the uncontrolled and controlled
scenarios, respectively. 'v
EMISSION REDUCTION: As a result of the evaluation, the facil ity discontinued the
use of arsenic. Also, two additional glass plants in Ohio
discontinued usage of arsenic in their production processes.
OTHER OBSERVATIONS: Because of the initiative study, the Ohio EPA began
. development of state regulations for arsenic emissions
from glass manufacturing. That effort was dropped when
the three potentially affected facilies discontinued
usage of arsenic.
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OWENS-ILLINOIS
PROMOTED INITIATIVE STUDY
STATE OF OHIO
Background
In 1987 the State of Ohio agreed to analyze arsenic emission from an Owens-
Illinois facility. This project was initiated as the result of EPA's analysis
of glass manufacturing facilities which led to the promulgation of Federal limits
on emissions of arsenic from glass manufacturing plants. Although arsenic
emissions from the Owens-Ill inois facil ity are below the Federal regulatory 1 imit
on uncontrolled arsenic emissions from glass melting furnaces, the public health
risks associated with the Owens-Ill inois facil ity were of a local ized nature that
may require regulatory action at the state level.
Source
The facility is located in Toledo, Ohio and is classified as a pressed and
blown glassware industry. It manufactures soda-lime glass and produces tableware
as an end product.
Chemicals Studied
Arsenic air emissions from the arsenic unloading station, the batch department
operations and the glass melting furnaces was the only contaminant assessed in
this study.
Study Approach
Observations obtained during a plant tour and data and information provided
by the facility and by Ohio EPA were used to update and/or verify emissions
information contained in EPA's background information document on glass
manufacturing plants. This information was used to identify and define sources
of potential arsenic emissions. The ISCLT dispersion model was used to estimate
ambient concentrations of arsenic associated with the updated emission estimates.
Both uncontrolled and controlled scenarios were modeled. The modeled ambient
concentrations were then used in the Human Exposure Model (HEM) to estimate the
cancer risk of the general population residing in the vicinity of the facility
as a result of exposure to ambient levels of arsenic associated with plant
emissions of arsenic.
Results
The results of the State's analysis of the Owens-Illinois facility are
contained in a written report submitted to the EPA Region V office dated April
1987. The major results of this study are contained in the following paragraphs.
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The evaluation of plant emissions showed that the major source of arsenic
emissions at the facility is the glass melting furnaces. Arsenic emissions from
the arsenic unloading operation are considered to be negligible and arsenic
emissions from the batch department operations are a small fraction (i.e., 1
percent) of the total plant wide emissions. The plant inspections also revealed
that two of the seven furnaces at the facility are no longer in operation.
Only emissions from the glass melting furnaces were modeled with the ISCLT
dispersion model. The results showed that the maximum ambient concentration for
all furnaces (no emissions control) was 0.0532 ug/m3. This concentration was
predicted to occur at a point 200 meters east-northeast from the facility.
Emissions from the facility assuming a eighty-five percent control were also
modeled. The maximum modeled concentration associated with controlled emissions
was 0.008 ug/m3.
The HEM was used to estimate both maximum individual cancer risks and annual
cancer incidence within 50 km of the facility. The maximum individual cancer
risk was estimated at 2.3 X 10"4 and 4 X 10"5 for the uncontrolled and controlled
scenarios, respectively. Annual incidence was 0.017 and 0.0026 cancer cases for
the uncontrolled and controlled scenarios, respectively.
Conclusions
The notable outcome of this studing is that the facility was successful in
completely eliminating arsenic emissions through process modifications. In
addition two other glass manufacturers in Ohio also discontinued arsenic usage.
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PROJECT SUMMARY SHEET
TYPE OF PROJECT: Promoted Initiative FUNDING YEAR: FY 1987
PARTICIPATING AGENCY: West Virginia Air Pollution Control Commission (WVAPCC)
Telephone (304) 348-4022
SOURCE: PPG
LOCATION: Moundsville, West Virginia
POLLUTANTS: Benzene
EPA REGION: Region III
APPROACH: Comparison of revised emission levels with EPA original estimates.
No ambient impact analysis was performed.
PUBLIC INVOLVEMENT: No
RESULTS: The WVAPCC's estimate of emissions from the process units represents
roughly a 97% reduction from EPA's estimates. WVAPCC indicates that
the current level of control on these units represents best available
control technology (BACT). The analysis also identified the storage
tanks as the largest source of benzene emissions at the facility.
These tanks were not included in EPA's emission estimate.
EMISSION REDUCTION: None beyond that which is currently installed.
OTHER OBSERVATIONS: The WVAPCC will explore means to reduce the blowdown kettle
emissions associated with the vacuum pump system downtime.
They also plan to address the storage tank emissions in any
air toxics regulations that the Commission may adopt.
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PPG
STATE INITIATIVE STUDY
STATE OF WEST VIRGINIA
Background
In 1987 the State of West Virginia was funded to analyze benzene emission
from a PPG facility. This project was initiated as the result of EPA's analysis
of this facility which indicated that, although public health risks associated
with benzene emissions from this facility did not warrant the development of
national federal regulations, the risks were of a localized nature that may
require regulatory action at the state level.
Source
The facility is located near Moundsville, West Virginia and produces
chlorobenzene.
Chemicals Studied
Benzene air emissions from the chlorobenzene unit and storage tanks was the
only chemical assessed in this study.
Study Approach
Engineering design calculations were used to estimate the benzene emission
rate (Ib./yr.) from the facility. These emission estimates were calculated by
the facility, reviewed by the state and compared to the initial emissions data
used by the EPA in their analysis of the facility. This study did not include
conducting any ambient impact analysis or health impact analysis to nearby human
populations.
Results
The results of the state's analysis of the PPG facility are contained in a
written report submitted to the EPA, Air Toxics Program Section, dated November
17, 1987. The major results of this study are contained in the following
paragraphs.
The revised emission estimates for the process units are approximately 97%
lower than the estimates used by EPA in their analysis of the facility. This
reduction is attributable to the installation of a condenser followed by a
refrigerated packed-bed counter-current scrubber, as well as the replacement of
the steam injectors with a vacuum pump. Over 99% of the current emissions are
due to the vacuum pump system downtime. With the vacuum pump system operating,
annual emissions of benzene from the process units would be less than 2 pounds
per year as compared to the emission estimate of over 95,000 pounds per year used
by EPA.
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In addition to identifying the emission reduction from the process units
listed above, the state also inventoried benzene emissions from storage tanks.
The emission estimates for the storage tanks indicates that they are the largest
source of benzene emissions from the PPG facility, emitting roughly 70,000 pounds
per year of benzene. EPA had not included storage tank emissions in their
original analysis.
Conclusions
The state plans to examine methods to reduce the vacuum pump downtime and to
consider the incorporation of storage tanks as sources of benzene emissions in
promulgating any future air toxic regulations.
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PROJECT SUMMARY SHEET
TYPE OF PROJECT: State Initiative FUNDING YEAR: FY 1987
PARTICIPATING AGENCY: Delaware Division of Environmental Control
Telephone (302) 736-4791
SOURCE: Standard Chlorine of Delaware, Inc.
LOCATION: Delaware City, Delaware
POLLUTANTS: Monochlorobenzene
Dichlorobenzene
Trichlorobenzene
EPA REGION: Region III
APPROACH: Ambient sampling data and a review of plant processes and
emissions estimates were used to determine if ambient
concentrations around the plant are acceptable.
PUBLIC INVOLVEMENT: No
RESULTS: Emissions and ambient concentrations of chlorobenzenes associated with
this plant are acceptable, but fenceline concentrations should
continue to be studied.
EMISSION DEDUCTION: No emission reduction of chlorobenzenes was
recommended.
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STANDARD CHLORINE
STATE INITIATIVE STUDY
STATE OF DELAWARE
Background
The State of Delaware conducted a study of emissions and ambient
concentrations of chlorobenzene at the Standard Chlorine of Delaware plant to
assist in the determination of whether chlorobenzene emission reductions were
needed at Standard Chlorine.
Source
The Standard Chlorine facility studied is located 2.8 miles north of Delaware
City, Delaware. It produces monochlorobenzene, ortho-dichlorobenzene, para-
dichlorobenzene, trichlorobenzene, and tetrachlorobenzene. At the time of this
study, the plant had temporarily discontinued production of meta-dichlorobenzene.
The facility is located in the vicinity of at least 10 other chemical plants,
but only one of these plants is a major handler of benzene. Three schools and
a subdivision are within 5.5 miles of the plant.
Chemicals Studied
This study focused on chlorobenzene emissions, specifically
monochlorobenzene, dichlorobenzene, and trichlorobenzene.
Study Approach
This study examined the following types of data: (1) plant, processes
including emission sources and rates, (2) fenceline monitoring data at Standard
Chlorine, (3) ambient monitoring data from a State air toxics survey, (4) ambient
monitoring data from a State sampling site 3.2 miles from the Standard Chlorine
plant, and (5) toxicological information. Each of these information sources is
described below.
1. Meetings were held between the State and Standard Chlorine personnel in
order to document process descriptions and emission estimates. Descriptions and
emission estimates were developed for the benzene chlorination process, the
monochlorobenzene process, the dichlorobenzene process, the trichlorobenzene
process, and the tetrachlorobenzene process. Emission estimates were based on
both stack testing (monochlorobenzene and dichlorobenzene emissions from the
benzene chlorination process) and engineering calculations.
2. Fencel ine concentrations of the three chlorobenzenes studied were sampled
and analyzed on seven days; three days during the annual plant shutdown, and four
days after the plant had started up again. Two samples were taken each day
during the same time interval each at approximately 125 feet from each other.
Sampling was performed according to NIOSH Method 1003.
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3. Additional data were obtained from an air toxics survey done for the
State by a consultant. Samples in this study reflected emissions of air toxics
by industrial sites and not data on the composite ambient air concentrations.
Samples were taken at Standard Chlorine and in Delaware City on four days.
4. Data from a State air toxics monitoring site 3.2 miles from the Standard
Chlorine plant were also reviewed. Again sampling was done according to the
NIOSH Method 1003.
5. Toxicological information was reviewed in order to evaluate whether
ambient concentrations in the vicinity of the facility were acceptable. This
information included NIOSH Permissible Exposure Limits (PELs) and Immediately
Dangerous to Life or Health Levels (IDLH); ACGIH threshold limit values (TLVs),
short term exposure levels (STELs), and ceiling exposure levels; and LCLO and
LC50 values.
. Results of the Impact Analysis
The fenceline monitoring data showed a range in concentration of all three
pollutants. No trichlorobenzenes were detected in the air toxics survey
monitoring or the State sampling site monitoring. Data from all three sampling
efforts showed ambient concentrations of monochlorobenzene and dichlorobenzene
below the workplace standards by more than a factor of 1/100. Trichlorobenzene
concentrations monitored at the Standard Chlorine fenceline were also below this
level.
Conclusions
the State concluded that, although Standard Chlorine contributes measurable
amounts of chlorobenzenes to the atmosphere, the emissions.are at an acceptable
level and do not warrant additional control technology even though such
technology is available. The State suggested that fenceline concentrations
continue to be monitored. The State would like to be able to distinguish between
"permitted" and fugitive emissions. In addition, the State suggested that the
study be expanded to'consider the following: (1) emissions from the new scrubber
to be installed at the hydrogen chloride absorber, (2) testing of storage vents
to compare actual emissions to calculations, and (3) emissions from air stripping
of wastewater effluent.
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PROJECT SUMMARY SHEET
TYPE OF PROJECT: Promoted Initiative FUNDING YEAR: FY 1986
PARTICIPATING AGENCY: Tennessee Division of Air Pollution Contro
Telephone (615) 741-3931
SOURCE: Velsicol Chemical Corporation
LOCATION: Memphis, Tennessee
POLLUTANTS: Hexachlorocyclopentadiene (HEX)
EPA REGION: Region IV
CONTRACTOR: Alliance Technologies Corporation
APPROACH: HEX emissions were calculated from three emission points within
the facility. These data were used in an ISCST model to predict
the average ambient concentrations at plant boundaries and in
local areas surrounding the facility. The modeling was performed
with and without proposed emission control strategies. The eight
hour average ambient concentrations were compared to threshold
level values (TLV) established by the American Council for
Government Industrial Hygienists (ACGIH). The predicted 24-hour
average ambient concentration values and the average annual
concentrations were compared to the 24-hour and annual average
Acceptable Daily Intake (ADI) values as calculated by EPA,
respectively.
PUBLIC INVOLVEMENT: None
RESULTS: Modeling performed without emission controls showed that only one
location at the plant boundary exceeded the acceptable TLV. Outside
the plant boundary the maximum eight hour ambient concentration was
shown to be only 21% of the acceptable TLV. The 24-hour ADI values
were exceeded in areas around the plant boundary and annual ADI's were
exceeded in areas at and around the plant boundary. Modeling
performed with proposed emission controls showed that there would not
be any areas at or outside the plant boundaries which would exceed the
TLV. The annual ADI value was exceeded at only one area at the plant
boundary.
EMISSION REDUCTION: None.
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VELSICOL CHEMICAL CORPORATION
PROMOTED INITIATIVE STUDY
STATE OF TENNESSEE
Background
In 1986, the project was funded to analyze hexachlorocyclopentadiene (HEX)
emissions at a Velsicol Chemical Corporation facility. This project was
initiated as a result of an EPA analysis of the facility which indicated that,
although the health risks associated with emissions from the facility did not
warrant the development of national federal regulations, the risks were of a
localized nature that could warrant action at the State level.
Source
The Velsicol facility is located in Memphis, Tennessee and is one of only two
facilities in the country which manufactures HEX. This compound is an
intermediate used in the production of chlorendic anhydride, a flame retardant,
and chlorinated pesticides (which includes heptachlor and chlordane). Both
chlorendic anhydride and heptachlor are produced at the Memphis facility.
Chemical Studied
This study analyzed HEX emissions from production units, storage and handling
operations and secondary sources (i.e. wastewater treatment).
Study Approach
Estimates of emissions from each of the sources mentioned above were
calculated by using mass balance calculations. These data were then used in the
Industrial Source Complex Short Term (ISCST) model to predict the average ambient
8-hour, 24-hour and annual concentrations of HEX at 80 receptor locations
between .2 - 1.5 kilometers from the facility and at 14 additional locations at
the plant boundaries (5 locations) and around homes, schools and churches in
local areas surrounding the plant (9 locations). A total of 94 receptor
locations were modeled. These areas were modeled for ambient concentrations
before and after the incorporation of proposed emission reduction control
strategies.
The predicted 8-hour average ambient concentrations were then compared to the
recommended Threshold Level Value of .001 ppm as established by the American
Council for Governmental Industrial Hygienists (ACGIH). Additionally, the
predicted 24-hour and annual average ambient concentrations were compared to the
24-hour and annual Acceptable Daily Intake (ADI) values of 19.5 ug/m3 and .231
ug/m3 respectively, as calculated by the EPA's Office of Health and Environmental
Assessment.
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Results
A detailed analysis of the predicted ambient average concentrations modeled
before and after the implementation of control strategies, and the associated
TLV and ADI results are contained in a report, dated August 1987 and submitted
to the EPA Region IV office. A summary of the results follows.
Based on the emissions calculations, the secondary sources were found to emit
the highest levels of HEX (77.7% of the total plant emissions). Production unit
equipment leaks accounted for 20.7% of the total emissions and storage and
handling operations were shown to be responsible for only 1.6% of the total plant
emissions.
The results of the modeling (before controls) showed that the average eight
hour concentration predicted at only one of the fenceline receptors (.0302 ppm)
would exceed the accepted Threshold Limit Value (TLV) of 0.01 ppm. This
predicted concentration was shown to be three times the value as recommended by
the American Council for Governmental Industrial Hygienists. At the non-
fenceline receptors (e.g. local areas surrounding the facility), the highest
predicted average eight hour concentration was .0021 ppm or only 21% of the
acceptable TLV. Additionally, it was shown that the 24-hour Acceptable Daily
Intake was exceeded at three of the five fenceline receptors while annual the
ADI was shown to be exceeded at all five fenceline receptors and four of the
nine non-fenceline receptors.
The contractor who performed the study proposed several methods for reducing
the emissions of HEX from the facility. These were:
1. the installation of a cover/decanter system to control HEX emissions from
the wastewater treatment plant (estimated to reduce emissions by 98%),
2. the institution of a monthly leak detection and repair (LDAR) program to
reduce emissions from valves, pumps and open-ended lines (estimated to reduce
emissions by 60% for the HEX production unit, 63% for the heptachlor unit and
66% for the chlorendic anhydride unit), and
3. modifying the method used to load HEX into 55 gallon drums (e.g. a
submerged fill versus a splash fill method would reduce emissions by 65%).
The ambient modeled HEX concentrations reflecting the implementation of these
recommended controls showed that none of the average eight hour ambient
concentrations would exceed the TLV's at all the fenceline or non-fenceline
receptors. It was also shown that the predicted ambient concentration at only
one fenceline receptor would exceed the acceptable annual ADI value while none
of the fenceline and non-fenceline receptors exceeded the 24-hour ADI value.
The contractor's report recommended that the plant monitor both the influent
and effluent concentrations and flow from the wastewater treatment plant and
obtain an accurate count of components that contribute to equipment leaks in
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order that a more accurate estimate of HEX emissions from this facility can be
determined.
Conclusions
The State has taken no action to require additional emission controls as
a result of this study.
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PROJECT SUMMARY SHEET
TYPE OF PROJECT: State Initiative
FUNDING YEAR: FY 1987
PARTICIPATING AGENCY: Maryland Department of the Environment, Air Management
Administration. Telephone (301) 631-3225
SOURCE: Vista Chemical Company
LOCATION: Baltimore, Maryland
POLLUTANTS: Benzene
Carbon tetrachloride
Chlorine
Chloroform
Ethylene dichloride
Hydrogen chloride
Methylene chloride
Toluene
Xylene
EPA REGION: Region III
APPROACH: Comparison of modeled maximum off-site concentrations with the
ambient screening levels from Maryland's air toxics regulations
(COMAR 26.11.15)
PUBLIC INVOLVEMENT: No
RESULTS: All emissions with the exception of benzene result in ambient
concentrations less than the screening levels. Benzene concentrations
were slightly higher that the screening levels which indicated that,
under the Maryland regulations, there is a need for a more detailed
evaluation for benzene emissions.
EMISSION REDUCTION:
OTHER CONSIDERATIONS:
Better fugitive emissions estimates may show that benzene
concentrations are less than the screening level. This
study will achieve a 97% overall reduction in benzene
emissions from the wastewater treatment system. Vista must
be in compliance for benzene emissions by July 1990.
Because Vista is planning to reduce benzene emissions
significantly over the next five years, this study
considered both current and projected emisssions. Review
of the Vista facility has had a major impact on setting
the review process used for other facil ities in Maryland.
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61
VISTA CHEMICAL COMPANY
STATE INITIATIVE STUDY
STATE OF MARYLAND
Background
In FY 1987, the State of Maryland undertook a review of air emissions from a
chemical manufacturing company. The review followed the approach outlined in
Maryland's air toxics regulations. The State of Maryland Air Management
Administration (AMA) received a grant from EPA under the State initiative program
to evaluate this source which had the potential to create high risks from
emissions of toxic air pollutants.
Source
The Vista Chemical Company's Baltimore plant is located in southeastern
Baltimore on the Patapsco River. Vista Chemical Company is a major publicly-
owned manufacturer and marketer of commodity petrochemical products derived from
oil and natural gas. Two primary products are produced at the Baltimore plant.
The first is a soft detergent intermediate, a linear alkyl benzene (LAB), which,
after further processing by the customer, is the active ingredient in many
biodegradable detergents and industrial cleaners. The second is sodium toluene
xylene sulfonate (STXS), used by household and industrial detergent manufacturers
to increase viscosity and solubility in aqueous solutions. Emissions from the
Baltimore plant are released from a variety of elevated stacks and fugitive
emissions sources.
Chemicals Studied
Emissions of nine toxic air pollutants listed in the Maryland regulations
were considered in this review: benzene, carbon tetrachloride, chlorine,
chloroform, ethylene dichloride, hydrogen chloride, methylene chloride, toluene,
and xylene.
Vista is in the process of modifying their waste water treatment operations.
These changes will treat the waste water in a closed system and virtually remove
all benzene before it contacts the atmosphere. For this reason, current and
projected benzene emissions were considered in the study.
Study Approach
Detailed emission estimates of all nine toxic pollutants were provided by
Vista. These estimates were reviewed and verified by the Engineering Division
of AMA. The sources of emissions are the LAB unit, the STXS unit, the waste
water unit and fugitive sources including equipment leaks such as those from
valves, pumps, compressors, pressure relief devices, and connectors. Estimates
of fugitive emissions were based on EPA's guidance for estimating emissions from
equipment leaks. Other emission estimates were based on actual testing or
estimates made using the maximum rated operating capacity.
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62
•
Air quality modeling was performed by the AMA in accordance with EPA
Guidelines on Air Quality Models, using two levels of air quality modeling.
First, the AMA conducted screening modeling to determine which pollutants with
simple emission characteristics required refined modeling. This effort was
restricted to pollutants with a single emission point. The following pollutants
were screened in this manner: chlorine, methylene chloride, chloroform, carbon
tetrachloride, and ethylene dichloride. Of these, methylene chloride and
chlorine were required to undergo modeling using a slightly more sophisticated
screening model (PTPLU).
The AMA used more refined dispersion modeling for the remaining four
pollutants because of the complexity of the emission sources. Ground level
concentrations were calculated using EPA's Industrial Source Complex Short-Term
(ISC-ST) and Industrial Source Complex Long-Term (ISC-LT) models.
Results of the more refined modeling were compared with the ambient screening
levels contained in the Maryland regulations.
Results of the Impact Analysis
The results of the State's analysis of the Vista Chemical Company facility are
contained in a written report submitted to EPA Region III Office dated April 3,
1989. The major results of this study are summarized in the following
paragraphs.
All emissions with the exception of benzene were shown to result in
concentrations below the ambient screening levels. Consequently, benzene
emissions, according to Maryland's air toxics regulations, must undergo a more
detailed review and compliance must be achieved by July 1, 1990.
The maximum concentrations of benzene occur adjacent to the waste water
treatment system which consists of API separators, pH adjustment sumps, and an
air flotation tank. Vista is in the process of redesigning their waste water
treatment system, and will eliminate all air emissions in the new design.
Projected emissions, based on the new design, would result in concentrations
below or equal to screening levels in residential areas but slightly above
screening levels for neighboring industrial property. (Maryland regulations
allow higher concentrations for off-site property zoned and used for industrial
purposes.)
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63
Conclusions
Emissions of the eight substances except benzene would be allowable under
Maryland's air toxics regulations. No further study of these emisisons is
required.
Based on the results of this study and the compliance dates in the
regulations, Vista has initiated two projects to reduce and reassess benzene
emissions. The first is to redesign of the waste water treatment system which
will reduced emissions by more than 97 percent, and the second is to conduct
tests to refine the benzene emissions estimates.
As a result of this study, Maryland instituted a multimedia source review
program.
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TECHNICAL REPORT DATA
{Please read Instructions on the reverse before completing}
1. REPORT NO.
EPA-450/ 2-90-014
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Interim Summary Report of the State and
Promoted Initiative Program
5. REPORT DATE
February 1990
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO
R. Schell, R. Bushow, and A. Pelland
9. PERFORMING ORGANIZATION NAME AND ADDRESS
ABB Environmental Services
6320 Quadrangle Drive, Suite 100
Chapel Hill, NC 27514
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68^02-4400^^.14
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency
OAR, OAQPS, AQMD, NPPB, ATPS (MD-15)
Research Triangle Park, NC 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
IS. SUPPLEMENTARY NOTES
EPA Project Officer:
David F. Painter
16. ABSTRACT
In 1985 the EPA established the high risk point source (HRPS)
initiative program. This program was funded by a portion of the
grant funds that EPA provides to S/L air . pollution control
agencies (i.e. Section 105 grants). Candidate sources to be
investigated under the program were identified by either EPA
(referred to as a promoted initiative) or a S/L agency (referred
to as a state initiative). This document was been prepared to
summarize the results of some of the initially completed HRPS
initiatives. This report summarizes each of the 19- projects that
were initially completed under the HRPS initiative program. For
each project, there is a listing of the source evaluated, the
pollutants covered, whether or not emission reductions were
achieved, and whether or not health impacts have been quantified.
More complete discussions of each of these 19 projects are
presented as an appendix to this report.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Air Toxics
High Risk Point Sources
Source Evaluation
State Initiatives
Promoted Initiatives
IS. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
20. SECURITY CLASS (This page)
22. PRICE
EPA Farm 2220-1 (R«». 4-77) PREVIOUS EDITION is OBSOLETE
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