AIR TOXICS INFORMATION
CLEARINGHOUSE
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
State and Territorial Air Pollution Program Administrators
Association of Local Air Pollution Control Officials
Rationale for Air Toxics
Control in Seven State and
Local Agencies
August 1985
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DCN No. 85-203-024-34-05
AIR TOXICS INFORMATION CLEARINGHOUSE:
RATIONALE FOR AIR TOXICS CONTROL IN
SEVEN STATE AND LOCAL AGENCIES
FINAL REPORT
Prepared for:
John Vandenberg
Project Officer
Pollutant Assessment Branch
Strategies and Air Standards Division
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Prepared by:
Alice S. Pelland and Patricia A. Cruse
Radian Corporation
3200 East Chapel Hill Road/Progress Center
Post Office Box 13000
Research Triangle Park, North Carolina 27709
August 16, 1985
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DISCLAIMER
This report has been reviewed by the Office of Mr Quality Planning and
Standards, U.S. Environmental Protection Agency, and approved for
publication as received from Radian Corporation. Approval does not signify
that the contents necessarily reflect the views and policies of the U.S.
Environmental Protection Agency, nor does mention of trade names or
commercial products constitute endorsement or recommendation for use.
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PREFACE
EPA, in the past, has focused most of its efforts in the control of air
toxics on the Clean Air Act §112 programs (National Emission Standards for
Hazardous Air Pollutants). The amount of time involved for § 112 listing
and eventual emission control is extensive. The public is concerned over
continuing exposure to potentially toxic air pollutants. The resultant
public pressure has had an impact such that many State and local agencies
have developed or are now actively developing air toxics regulatory programs
apart from Federal activities.
In response to State and local agency requests for assistance in
information exchange, EPA has formed an information dissemination center,
known as the Air Toxics Information Clearinghouse. It is being implemented
in close coordination with the State and Territorial Air Pollution Program
Administrators (STAPPA) and the Association of Local Air Pollution Control
Officials (ALAPCO).
The purpose of this report, published by the Air Toxics Information
Clearinghouse, is to provide State and local agencies with descriptive
information on the approaches used by some of these agencies for determining
acceptable ambient concentrations and emissions limits for toxic air
pollutants. The report includes a chapter on each of four State and three
local agencies, as well as an Executive Summary which contrasts the various
programs and presents a summary table of various guidelines for ambient
concentrations used by the agencies. These seven agencies were chosen
because they represent several different approaches to air toxics control
and different levels of program development. Information presented here was
compiled in June 1985.
This report is one of several publications prepared by the Air Toxics
Information Clearinghouse. Clearinghouse and other related EPA publications
include:
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- Study of Selected State and Local Air Toxics Control Strategies -
EPA 450/5-82-006, October 1982.
- Air Toxics Information Clearinghouse: Selected Bibliography of
Health Effects and Risk Assessment Information - July 1984.
Air Toxics Information Clearinghouse: Interim Report of Selected
Information on State and Local Agency Air Toxics Activities -
September 1984.
- Air Toxics Information Clearinghouse: Bibliography of Selected
EPA Reports and Federal Register Notices - January 1985.
- Air Toxics Information Clearinghouse: Second Interim Report of
Selected Information on State and Local Agency Air Toxics
Activities - March 1985.
- Air Toxics Information Clearinghouse: Ongoing Research and
Regulatory Development Projects - March 1985.
- Air Toxics Information Clearinghouse Newsletter, Vol. 1, No. 1-5,
Vol. 2, No. 1-3 - December 1983, February 1984, April 1984,
July 1984, September 1984, December 1984, February 1985, and
May 1985.
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ABSTRACT
An Air Toxics Information Clearinghouse has been established by EPA’s
Office of Air Quality Planning and Standards for the purpose of facilitating
information transfer among State, local, and Federal air quality management
agencies. This document has been published as part of that effort.
This report describes the approach used by four State and three local
agencies for determining acceptable ambient concentrations and, if
applicable, emission limits for noncriteria air pollutants. The agencies
included are located in: Chattanooga/Hamilton County (Tennessee),
Connecticut, Maine, Mississippi, Nevada, Philadelphia (Pennsylvania), and
Sacramento County (California).
This report was submitted in partial fulfillment of Contract
Number 68-02-3889, Work Assignment Number 34, by Radian Corporation under
the sponsorship of the U.S. Environmental Protection Agency. Information
was collected in June 1985, and the report was completed in July 1985.
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TABLE OF CONTENTS
Page
Preface . V
Abstract V i i
Tables X I
List of Abbreviations XR1
Part I - Executive Summary 1
Introduction 1
Summary 5
Part II - Descriptions of Selected Program Rationale 17
Sacramento County, California 19
Philadelphia, Pennsylvania 27
Chattanooga/Hamilton County, Tennessee 39
Maine 45
Mississippi 61
Nevada 65
Connecticut 71
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LIST OF TABLES
Table Page
1 Comparison of Seven Air Toxics Programs: General
Program Aspects 6
2 Comparison of Seven Air Toxics Programs: Bases for
Acceptable Ambient Concentrations 8
3a Comparison of Acceptable Ambient Concentrations of
Organic Compounds 9
3b Comparison of Acceptable Ambient Concentrations of
Inorganic Compounds 11
4 Comparison of Acceptable Asbestos Concentrations 13
5 Pollutants Having Some Evidence of Carcinogenicity:
Sacramento County 22
6 Toxic Air Contaminants and Ambient Air Quality
Guidelines Listed by Air Management Services, City
of Philadelphia 28
7 Philadelphia Air Management Services Ambient Air
Guideline - Setting Methodology for Toxic Air
Contaminants 33
8 List of 99 Pollutants Developed by Chattanooga-Hamilton
County Air Pollution Control Bureau 41
9 Priority Ranking for Maine’s Hazardous Air Pollutants 56
10 Summary of Classification Schemes for Known and Suspect
Carcinogens Used by Connecticut Department of
Environmental Protection 73
11 Maximum Allowable Ambient Concentrations Proposed by
Connecticut Department of Environmental Protection 77
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LIST OF ABBREVIATIONS
1. ACGIH - American Conference of Governmental Industrial Hygienists
2. AOl - acceptable daily intake
3. ALAPCO - Association of Local Air Pollution Officials
4. BACT - Best Available Control Technology
5. C - ceiling (TLV-C)
6. CAG - Carcinogen Assessment Group (EPA)
7. DNA - deoxyribonucleic acid
8. EPA - Environmental Protection Agency
9. IARC - International Agency for Research on Cancer
10. ISC - Industrial Source Complex Model
11. LOEL - lowest observed effects level
12. NAAQS - National Ambient Air Quality Standards
13. NAS - National Academy of Sciences
14. NCI - National Cancer Institute
15. NESHAP - National Emission Standard for Hazardous Air Pollutants
16. NIOSH - National Institute of Occupational Safety and Health
17. NLM - National Library of Medicine
18. NOEL - no observed effects level
19. NTP - National Toxicology Program
20. OSHA - Occupational Safety and Health Administration
21. PEL - permissible exposure level (OSHA)
22. RTECS - Registry of Toxic Effects of Chemical Substances
23. STAPPA - State and Territorial Air Pollution Program Administrators
24. STEL - short-term exposure level (TLV-STEL)
25. TLV - threshold limit value (ACGIH)
26. TWA - time weighted average (TLV-TWA)
27. WHO - World Health Organization
28. UNAMAP - User’s Network for Applied Modeling of Air Pollution
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PART I - EXECUTIVE SUMMARY
INTRODUCTION
PURPOSE
The Air Toxics Information Clearinghouse has been established by EPA’s
Office of Air Quality Planning and Standards for the purpose of facilitating
information transfer among State, local, and Federal air quality management
agencies. This document has been published as part of that effort.
This report is the result of a study of the rational used by State and
local agencies in selecting acceptable ambient concentrations and, if
applicable, emission limits for toxic air pollutants. The study was
undertaken by the EPA’s Office of Air Quality Planning and Standards as part
of the Air Toxics Information Clearinghouse. For various reasons, several
State and local agencies have established their own programs to control
emissions of toxic air pollutants. Furthermore, other agencies are in the
process of developing such programs and have requested guidance from EPA.
This report is designed, in part, to serve as a resource for agencies that
wish to develop their own approach to air toxics controls.
METHODOLOGY
Information on all seven agencies was collected in telephone
conversations with one or more agency staff members. In some cases, printed
material describing a particular facet of an agency’s program was reviewed.
The chapters summarizing rationale for the various approaches were reviewed
by the respective agencies and revised according to their comments.
Agencies selected for this report have been active in the Air Toxics
Information Clearinghouse by submitting information in several air toxics
program areas. An effort was made to present approaches used by both State
and local agencies, to present some varied methods for selecting acceptable
ambient levels for air toxics and to cover agencies at different program
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development stages. The methods used for selecting acceptable ambient
levels include application of safety factors to occupational levels, risk
assessment, and requirements for best available control technology. States
covered extensively in earlier EPA air toxics reports were not included
since this report is intendes to supplement previous publications.
Specifically, in October 1982, EPA published “Study of Selected State and
Local Air Toxics Control Strategies” (EPA 450/5-82-006), which describes air
toxics programs for seven State and one local air agencies.
ORGANIZATION
This report is divided into two parts. Part 1, the Executive Summary,
compares and contrasts the programs and includes a table comparing the
acceptable ambient levels of the agencies for 49 toxic air pollutants.
Part 2 consists of a description of the rationale for acceptable ambient
levels for each agency studied.
Each of the descriptions addresses the same general topics: general
program aspects, basis for acceptable ambient limits and emission limits.
risk assessment and risk management, and air toxics program application and
enforcement. The sections on general program aspects give a brief overview
of the agencies’ approach to selecting acceptable limits and notes whether
the requirements apply to only new sources or new and existing sources. The
sections on basis for acceptable ambient limits and emission limits cover
the health effects addressed, how acceptable ambient limits are determined,
the averaging period, the relationship between ambient limits and emission
limits, dispersion models used, and public participation in the development
of air toxics requirements. The sections on risk assessment and risk
management address how the agencies use these techniques, the steps each
agency follows in risk assessment, exposure estimates, and the use of
computer modeling. The sections on application and enforcement discuss how
ambient limits/emission limits are applied, any regulatory distinctions
between new and existing sources, whether sources are allowed to develop
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alternatives to the agencies’ limits, requirements for monitoring and stack
testing, uses of emission inventories, review and appeal procedures and
noncompliance penal ties.
The level of detail available concerning each of the programs was not
consistent among the seven agencies. There are two major reasons for this.
First, three of the programs discussed are in the planning stage and these
agencies have not been confronted with several issues pertaining to
implementation. Second, agencies in less industrialized areas have not been
faced with several of the issues associated with large numbers of sources.
Some of the areas represented are more heavily industrialized than others
and agencies in these areas have handled more source permit applications.
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SUMMARY
This section summarizes the seven State and local agency air toxics
programs included in this report, comparing and contrasting the agencies
contacted. The summary is organized to address the same four general topics
included in the discussion for each agency: general program aspects, basis
for acceptable ambient limits and emission limits, risk assessment and risk
management, and application and enforcement of the air toxics policies.
General Program Aspects
Table 1 compares the seven programs in terms of the status, the scope,
and the general approach.
Basis for Acceptable Ambient Guidelines/Emission Limits
All seven agencies use or are considering using some type of acceptable
ambient concentration. Table 2 summarizes the basis for establishing
acceptable ambient concentrations and the safety factors applied, and the
averaging times. Tables 3A and 3B summarize some of the acceptable ambient
concentrations used by Connecticut, Nevada, Philadelphia, Sacramento and
Maine. Table 4 compares acceptable concentrations for asbestos. The
pollutants listed have been studied, are currently being studied, or are
scheduled for study by EPA’s Pollutant Assessment Branch. Chattanooga was
not included because a technology-based approached is used there.
Mississippi uses a median value of several occupational health concentration
levels on a case-specific basis and was not included since acceptable
concentrations may change as newer research emerges.
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TABLE 1. COMPARISON OF SEVEN AIR TOXICS PROGRAMS:
GENERAL PROGRAM ASPECTS
Agency Status Scope General Approach
Chattanooga!
Hamilton County
Planned, not
in effect
99 pollutants,
policies will apply
to new and modified
sources
BACT, may use
ambient guide-
lines in some
cases based on
safety factor
applied to TLV
Connecticut
Planned, not
in effect
853 pollutants,
policies will apply
to new and existing
sources
Ambient guide-
lines based on
safety factor
applied
to an occupa-
tional guideline
Maine
Planned, not
in effect
Interim guidelines:
No specific list of
pollutants, policies
will apply to new
sources.
Risk assessment when
complete: 58
substances, policies
will apply to new and
possibly existing
sources
Interim ambient
guidelines; based
on safety factor
applied to TLV,
NOEL, or LOEL;
while risk
assessments are
being developed
Mississippi
In place
Not limited to a
list of pollutants,
policies apply to
new sources
Guidelines,
acceptable
ambient concen-
trations for
noncarci nogens
based on safety
factor applied to
median of several
occupational
guideline, risk
assessment for
carcinogens
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TABLE 1. COMPARISON OF SEVEN AIR TOXICS PROGRAMS:
GENERAL PROGRAM ASPECTS (Continued)
Agency
Status
Scope
General Approach
Nevada
In
place
Not limited to a
list of pollutants,
policies apply to
new and existing
sources
Regulations
requiring BACT and
attainment of
acceptable ambient
concentrations
based on safety
factor applied to
TLV
Philadelphia
In
place
99 pollutants,
policies apply to
new and existing
sources
Ambient guide-
lines based on
safety factor
applied to
occupational
guideline, NOEL,
or LOEL
Sacramento
In
place
List of carcinogens,
policies apply to
new and modified
sources
Ambient guide-
lines based on
risk assessment
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TABLE 2. COMPARISON OF SEVEN AIR TOXICS PROGRAMS
BASES FOR ACCEPTABLE AMBIENT CONCENTRATIONS
Basis
for
Acceptable
Averaging
Agency Concentration Safety
Factor Time
Chattanooga! ACGIH TLV 1/420 Averaging
Hamilt 1 n time has
County not yet
been set
Connecticut ACGIH TLV, OSHA PEL, Human carcinogens: 30 minutes
NIOSH Recommended 1/200; Suspect and 8 hours
Standards carcinogens, mutagens
or teratogens: 1/100;
Noncarci nogens: 1/50
Maine ACGIH TLVs or NOEL Range from 1/1000 to Range from
or LOEL 1/4, depending on instan-
health effects taneous to
1 week,
depending
on health
effects
Mississippi Median value of 1/100 24 hours
several occupational
guidelines (ACGIH,
NIOSH, OSHA and
standards from Europe
and the USSR) for
noncarci nogens
Nevada ACGIH TLV plus BACT 1/42 24 hours
Philadelphia Carcinogens Noncarcinoqens
ACGIH liv 1/420 1/42 Annual
OSHA PEL 1/420 1/42 (sometimes
NOEL or LOEL (animal 1/4200 2 or 1/420 2 or 24 hours,
inhalation) 1/1000 1/100 depending on
ADI 1/10 1/10 health
effects)
Sacramento Ambient concen- Not applicable Annual
tration may no
exceed 1 x 10
risk level
‘Chattanooga is considering the use of ambient guidelines in some cases.
2 Safety factor is 1/4200 or 1/1000 for carcinogens and 1/420 or 1/100 for
noncarcinogens depending on the animal inhalation study.
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TABLE 3A. COMPARISON OF ACCEPTABLE AMBIENT CONCENTRATIONS OF ORGANIC COMPOUNDSd
TLV_TWAb
Connecticut
1eyada.
PhiladeiphiaC
sacramentoCld
Maine C
Pollutant ppm
ppm
ppm
ppm
ppm
ppm
Aceta ldel ,yde 100.0 2.0 2.381
Acrolein 0.1 0.002 0.00238
Acrylonitrile 2 • 0 e 0,01 0.0476 0.005
Ammonia 25.0 0.5 0.595
Benzene 10.0 0.238 0.024 5.9 x 106
1,3—Butadlene (1000.0) 20.0 (23.8)
Carbon tetrachioride 5 • 0 e 0.05 0.119 0.012
Chlorine 1.0 0.02 0.0238
Chlorobenzenes
Monochlorobenzene 75.0 1.5 1.79
o-D lchlorobenzene 1.0
p—Dlchlorobenzene 7S.0 0.75 1.79
1,2,4—Trlchlorobenzene 0.1
Chloroform 10.0 0.05 0.238 0.024 0.004
Chloroprene 100 e 0.2
Epichlorohydrln 20 e 0.006 0.0476 0.0024
Ethylene dlchloride 10.0 0.02 0.238 0.037 11.4 — 18.9 x 10
Ethylene oxide 1.0 0.01 0.0238 0.0024 Footnote d
Freon 113 (1,1,2—tr ch1oro—
1,2,2—trifluoroethane) 1000.0 20.0 23.8
Gasoline vapors 300.0 6.0 7.14
Hexachlorocyclopentadiene 0.01 0.0002 0.000238
Hydrogen chloride 0.10
Hydrogen sulfide 10.0 0.2 0.238
Methyl chloroform 350.0 7.0 8.33
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TABLE 3A. Continued
TLV TWA ’
Connect icut
Nevada
Philadeiph iaC
sacramentpCd
Maine C
Pollutant ppm
ppm
ppm
ppm
ppm
ppm
Naphthalene 10.0 0.2 0.238
Perchioroethylene 50.0 0.25 1.190 1.2 0.05
Pheno’ 5.08 0.1 0.119 0.12
Phosgene 0.1 0.002 0.00238
Propylene oxide 20.0 0.4 0.476 0.25
Styrene. monomer 50.0 1.0 1.19
Toluene (toluol) 100.0 2.0 2.38 1.7 C 7 day)
15.4 (15 mm)
Toluene dilsocyanate 0.005 0.0001 0.000119
0 Trichioroethylene 50.0 0.25 1.19 1.2 0.087
Vinyl chloride 5.0 0.025 0.119 0.0024 0.013
Vinyl idene chloride 5.0 0.1 0.119
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TABLE 3B. COMPARISON OF ACCEPTABLE AMBIENT CONCENTRATIONS OF INORGANIC AND OTHER COMPOUNDS 8
TLV_TWAb
Cormn ticut
Nevada.
PhiladeiphiaC
Sacraento(2 d
Maine C
Pollutant ug/m 3
ug/m 3
ug/m 3
ug/m 3
ug/m 3
ug/m 3
Arsen1c9 h 200.0 0.05 4.76 0.024
Asbestos — See Table 4
Beryiilum 1 2.0 0.010 0.0476 0.01
Cadmlumh j 50.0 0.5 1.19 0.12
Chromium metal 500.0
Chromium ( II) k 500.0 10.0 11.9
Chromium (III 500.0 10.0 11.9 4
Chromium (VI) Footnote m 3.3 x 10 6
1.08 x 10
water soluble 50.0 1.19 0.12
certain water Insoluble 50.0 1.19 0.12
Coke oven emissions
(coal tar pitch volatlles) 200.0 1.0
Copper
Fume 200.0 2.0 4.76
Dusts and Mists, as Cu 1000.0 20.0 23.8
Managanese, as Mn
Dust and compounds 100.0 24.0
Fume 1000.0 20.0 23.8
Mercury. as Hg
Alkyl compounds 100 e 2.0 0.238 0.24
All forms except alkyl
Vapor 50.0 1.0 1.19
Aryl and inorganic
compounds 100.0 2.0 2.38 0.24
Nickel
Metal 1000.0 5.0 23.8 0.24
Soluble compounds as Ni 100.0 Footnote n 2.38 0.24
Zinc chloride fume 1000.0 20.0 23.8
Zinc chromate as Cr 50.0 0.5 1.19
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TABLE 3B. Continued
Pollutant
ILY_TWAb
ug/m 3
Connecticut
ug/m 3
Nevada
ug/m 3
PhiladeiphiaC
ug/m 3
SacramentoCDd
ug/m 3
Maine C
ug/n1 3
Zinc oxide
Fume
Dust 1
5000.0
5000.0
100.0
119.0
alhe authors of this document performed conversions of units to make values comparable. See Table 2 for averaging time.
bAcGIH Threshold Limit Value — 8 hour averaging time. Parentheses indicate a change In the TLV has been proposed by ACGIH.
CBlank spaces In the tables indicate that acceptable ambient concentrations have not been established by the agency.
dsacramento County addressgs risk in terms of annual dosage (mg/yr) and 3 ln terms of unit risk. The annual dosage reflects the dosage
associated with a 1 x 1 risk level for a 70 kg human breathing 20 m per day. Annual risk associated with ethylene oxide Is 3.9 x
if exposed to 2.01 mg/rn for 4 hours/day, 5 days/week.
eFor TLV . skin.
8 —ct ioroprene.
For TLV, soluble compounds 1 as As.
N.) For Philadelphia. “and compounds”.
iFor Connecticut, “and compounds”.
Dust and salts, as Cd.
kC poufld$, as Cr.
1 Nuisance particulate.
mCarclnogenic Cr (Vt): 0.005; noncarcinogenic Cr (VI); 0.5.
r Carcinogens — 0.075; noncarclnogens — 0.3.
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TABLE 4. COMPARISONS OF ACCEPTABLE ASBESTOS CONCENTRATIONS
ACGIH
TLV—TWA
Connecticut’
Nevada
Philadelphia
fibers >5 urn/cc
(annual
averaging time)
fibers
>5
urn/cc
fibers >5 urn/cc
fibers >5 urn/cc
(24—hour averaging time)
ASBESTOS
0.005
Amosite
0.5
0.0005
0.00119
Chrysotile
2.0
0.0005
0.0476
Crocidollte
0.2
0.0005
0.00476
Other forms
2.0
0.0476
1 Numbers shown are for 8—hour averaging time. Conversion from fibers/rn 3 to fibers >5 urn/cc was made by
authors to make values comparable. To obtain 30—minute standards, multiply by 5. Pe tains to fibers >5 urn
in length. The 8—hour conce trations for tremolite and fibrous talc are 500 fibers/rn . The 30—minute
standards are 25,000 fiber/rn for both.
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Risk Assessment/Risk Management
Of the seven agencies surveyed, four use some type of risk analysis.
Using the EPA risk assessment guidelines, Maine is presently working on risk
assessments for the 58 pollutants of primary concern there. The results of
these assessments will be used to establish pollutant or source specific
guidelines or standards.
Mississippi calculates carcinogenic risk by multiplying the CAG unit
risk factor by the modeled average annual concentration. If no GAG unit
risk factor is available, estimates of risk from other groups are consulted.
If the calculated risk is less than i0 6 , then the risk is termed
insignificant. If above 1O , the risk is considered significant. Between
these two values, risk management decisions would be made on a case-by-case
bas i s.
Sacramento also uses io6 as a guideline for acceptable risk. The
California Department of Health Services determines what ambient
concentration is associated with a io 6 risk level, and then the Sacramento
Air Pollution Control District sets stack emission limits such that the
io6 risk level ‘will not be exceeded.
Nevada’s program is not primarily risk based, but the agency does
conduct informal exposure assessments of predicted ambient concentrations
and numbers of people exposed.
Application, Enforcement, and Public Review and Appeal
The seven agencies described here are at various stages of
implementation of their air toxics programs. The agencies have jurisdiction
over areas that vary in degree of industrial development. Thus, the
experiences with application and enforcement have been varied, making
comparisons of provisions among programs difficult.
Almost all of the agencies reported that the public participated in
development of the air toxics program and/or in public hearings concerning a
specific source.
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Six of the seven agencies currently or plan to require ambient
monitoring and/or stack testing as a permit condition for some air toxic
sources. Only one agency reported that it had no plans for an air toxics
inventory. All but one agency reported that they had provisions for
appealing the Agency’s air toxics requirements. Most of these provisions
allowed for suggesting an alternative to the acceptable ambient
concentration.
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PART II - DESCRIPTIONS OF SELECTED PROGRAM RATIONALE
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SACRAMENTO COUNTY AIR POLLUTION CONTROL DISTRICT
General Program Aspects
The Sacramento County Air Pollution Control District (SCAPCD or the
District) uses informal guidelines as a basis for regulating carcinogens or
suspected carcinogens in the ambient air. The guidelines are based on a
risk assessment approach and are applied to new sources as the sources apply
for permits or permit modifications. Formal airborne toxic control measures
are being developed on a substance-by-substance basis at the State level.
The SCAPCD expects to adopt these measures, where applicable, as they are
developed.
District authority for regulating air toxics is found in District Rule
402 and an identical State regulation concerning public nuisance (Health and
Safety Code Section 41700).
Basis for Acceptable Ambient Limits/Emission Limits
A stack emission limit is specified in each permit issued. The limit
is calculated based on the source’s stack parameters such that the source’s
contribution above the ambient concentration of the particular pollutant
will not exceed a level corresponding to a carcinogenic risk of i0 6 . This
risk level is used by the District because it is the action level suggested
by the California Department of Health Services (CDHS). The ambient levels
corresponding to a carcinogenic risk of io6 used to date, have been
developed upon the District’s request by CDHS. CDHS considers primarily
animal bioassay data, noting the number of cancers at a given dose level and
establishing a dose/response curve. CDHS uses the linear low dose
extrapolation assumption and a conservative approach in converting animal
dosage to human dosage.
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In the future, the District anticipates using CAG unit risk factors to
screen permit applications with review after screening by the CDHS. If
there is no CAG unit risk factor, nor any CDHS unit risk factor, the
District would ask CDHS to develop a risk factor for the pollutant in
question, or require the permit applicant to develop the risk factor. If
the permit applicant supplies the risk factor, it would be reviewed by the
CDHS.
The District currently limits its guidelines to carcinogens because the
District staff feels there is no satisfactory mechanism for establishing
safe guidelines for noncarcinogens, and because there is considerable
disagreement on what factors (e.g., occupational standards divided by safety
factors) should be used to define a safe ambient level for noncarcinogens.
Fugitive emissions have not been a major problem at the sources the
District has considered thus far. Sources are required to give calculations
on fugitive losses (e.g., chemical plant breathing vents), but to date,
these sources have not been required to control fugitives.
In estimating dispersion, the permit applicant is required to estimate
daily emissions from the stack and then to model concentrations at various
receptor sites. Receptor sites are chosen to correspond with the location
of human population. The maximum distance from the source varies, and
depends on the strength of the source and how far downwind a significant
concentration would likely be found. To date, the maximum distance modeled
from a source has been approximately 3 miles downwind.
The District has not settled on a particular model so different
dispersion models are used depending on the nature of a particular project.
When a source recently applied for a permit to perform air stripping to
remove solvent from ground water, the project proponent suggested EPA’s
Industrial Source Complex (ISC) model and the District concurred. PTMAX and
ISC are two models used by the District to date.
Public participation has not been a formal step in the development of
the SCAPCD guidelines for controlling carcinogens. However, public hearings
have been held when there has clearly been public interest in a proposed
project. In addition, District regulations contain a provision where any
person may petition the APCD Hearing Board to reverse the Air Pollution
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Control Officer’s decision to authorize construction. Some informal review
takes place during the permit application process when the risk assessment
is reviewed by the California Air Resources Board (CARB), CDHS, and the
District; CARB, CDHS, and the applicant discuss the particular source.
Risk Assessment/Risk Management
As mentioned above, risk assessment is the primary thrust of the SCAPCD
effort to control carcinogenic air pollutants. The Distr tct regulates any
suspected carcinogen based on the “pollutants having evidence of
carcinogenicity,” as listed in EPA’s 1984 study of the air toxics problem in
the United States’ (Table 5), and based on the CARB list of compounds under
consideration as toxic air contaminants.
The steps in the District’s risk assessment process are:
o estimation of daily emissions by the permit applicant;
o modelling by the permit applicant of concentrations at receptor
sites;
o comparison with the ambient concentration (or range of
concentrations) associated with a cancer risk of 1 in 1 million;
and
o estimation of cancer burden (i.e., the number of cancer cases in
an uniformly exposed population, which is considered to be the
exposed population, over a lifetime of 70 years).
If the modelled concentrations are below the concentration associated
with the ,O risk, then the permit application would be approved. If not,
the District would work with the applicant to consider achieving emission
reduction by means such as additional control or limiting the hours of
operation or limiting the process rate. In some cases, the District would
consider the life of the proposed project and might permit a fairly
short-lived project to exceed the acceptable ambient concentration. The
ambient concentration associated with the i0 6 risk is based on lifetime
(70 years) exposure to the concentration and the District acknowledges that
21
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TABLE 5. POLLUTANTS HAVING SOME EVIDENCE OF
1*
CARCINOGENICITY’ : SACRAMENTO COUNTY
Acryl amide
Acrylonitrile
Allyl chloride
Arsenic
Asbestos
Benzene
Benzo-a-pyrene
Benzyl chloride
Beryllium
1 ,3-Butadiene
Cadmi urn
Carbon tetrachi on de
Chi oroform
Chromium
Coke oven emissions
Di ethanol amine
Dimethylni trosami ne
Dioctyl phthalate
Epi chiorohydnin
Ethyl acrylate
Ethyl ene
Ethyl ene di bromide
Ethylene dichloride
Ethylene oxide
Formaldehyde
Gasoline vapors
Gasoline marketing
4,4 150 Propylidene diphenol
Mel amine
Methyl chloride
Methyl ene chloride
4,4-Methylene dianiline
Nickel (subsulfide)
Ni trobenzene
Nitrosomorphol me
Pent achi orphenol
Perchi oroethyl ene
Products of incomplete combustion
PCBs
Propylene dichioride
Propylene oxide
Radionuci ides
Styren e
Terephthalic acid
Titanium dioxide
Tn chl oroethyl ene
Vinyl chloride
Vinylidene chloride
*The weight of evidence of carcinogenicity for the compounds listed varies
greatly, from very limited to very substantial. Further, the extent of
evaluation and health review performed varies considerably among compounds.
However, for the purposes of Reference 1, a conservative scenario
(i.e., that all compounds examined could be human carcinogens) was assumed.
22
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this would not be the case for a short-term project. Such was the case at
an organic chemical manufacturing plant which was slated to operate for only
two years. The ambient monitoring network around the plant indicated
periodic unexplained exceedances of the guideline. The District staff has
no formal maximum allowable exceedance, but was not concerned in this case
since the ambient levels decreased, and the plant was due to close after two
years.
Exposure assessment (i.e., determining the number of people exposed to
various ambient concentrations of the pollutant) has not been a factor so
far in the District’s analysis. Since the population of metropolitan
Sacramento is about 1 million people, a risk of 1 x io6 would present a
maximum cancer burden of 1 if the entire population were exposed. Because
the action level of 1 x io6 cancer risk reflects exposure to a population
equivalent to the entire metropolitan area, cancer burden has not played a
significant role in the District’s program.
The District is anticipating the completion of a risk assessment manual
being prepared for use by Air Pollution Control Districts Statewide. The
manual is being prepared under a grant and supervision from EPA Region IX,
with review by CARB, COHS, and representatives from various Districts. When
completed, the manual will include guidance on carcinogenic risk assessment
and possibly on risk assessment for noncarcinogens. SCAPCD would then have
a mechanism for regulating noncarcinogenic air toxics based on the manual’s
guidance.
ApDlication and Enforcement
The District’s guidelines for regulating carcinogens are applied by the
District to new and modified sources. Eight applications involving two
industries have been handled thus far. Once a permit is issued, if permit
conditions are met, the permit is renewed annually without additional
requirements being placed on the source. State law precludes the imposition
of new requirements on an existing permit. If additional health effects
data should cause a unit risk factor to be lowered, the District would not
23
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be able to impose stricter requirements in an existing permit. In such a
case, the District might ask the source to comply with the more stringent
guideline in the interest of public health.
Some sources are required in the permit to perform ambient monitoring
and to track equivalent human dose. There is no formal policy about when a
source would be required to conduct ambient monitoring, but the District
makes decisions on monitoring based on the level of public concern, the
availability of monitoring sites, and the source strength. Monitoring would
more likely be required of a large source than a small source.
In tracking equivalent human dose, the source must determine the
average concentration in ug/m 3 for each 3-month period, and then convert
this to the equivalent human dose based on assumptions of the amount of air
inhaled. Based on the District’s conservative assumption of 100 percent
retention of the pollutant, the dose for each quarter is reported. Doses
for each 3-month period are added together. Should the quarterly reports
project that the annual dose specified in the permit will be exceeded prior
to the end of the calendar year, the source would be required to shut down
for the remainder of the year or vent emissions to a control device. The
3-month period was selected on an informal basis to reduce the burden on
industry of more frequent reporting, yet to give a reasonable amount of
notice if the annual dose was likely to be exceeded.
The District has provisions for review and appeal of permit decisions,
but no decisions regarding air toxics have been appealed. The provisions
for appeal allow the permit applicant to appear before the APCD Hearing
Board, which is appointed by the Air Pollution Control Board.
Violators of the District’s requirement are subject to criminal
penalties consisting of a fine of $1,000 per day (i.e., per violation), or
six months in prison, or civil penalties of $1,000 per violation.
24
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REFERENCES
1. Haemisegger, E., A. Jones, B. Steigerwald, V. Thomson. The Air Toxics
Problem in the United States: An Analysis of Cancer Risks for Selected
Pollutants. EPA/OAR/OPPE. Washington, D.C. EPA-450/1-85-OO1,
May 1985.
25
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26
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PHILADELPHIA AIR MANAGEMENT SERVICES
General Program Aspects
Philadelphia Air Management Services (AMS) is the process of
implementing a program to limit emissions of 99 toxic air pollutants
(Table 6). The air toxics provisions are aimed at new and existing sources
and are based on acceptable ambient guidelines.
Basis for Acceotable Ambient Limits/Emission Limits
The Philadelphia air toxics guidelines are aimed at 99 substances or
classes of substances listed in an ordinance (Air Management Regulation VI)
that was signed and became effective in 1981. The list of 99 substances was
compiled by reference to other lists to address concerns about chronic
low-level exposure in the community, and the associated health effects. The
principal reference was the ACGIH carcinogen list.” 2 Cancer is a primary
concern, but the list of pollutants also reflects concern over other chronic
effects such as liver and kidney damage (e.g., mercury). Another selection
criterion was the likelihood of the pollutant being found in Philadelphia.
The AMS believes that any acute, high concentration exposure would be the
result of an emergency situation to which AMS would respond directly.
As part of the process of determining the health hazard potential of
each of the 99 pollutants, AMS examined the toxicity of each pollutant to
humans. To assist AMS in evaluating toxicologic data, an jj ç advisory
committee was appointed by the Health Commissioner. The seven member
committee consisted of health professionals from academic, industry, and
public interest groups in the fields of toxicology, occupational medicine,
and industrial hygiene.
The Committee’s objective was to recommend ambient air quality
guidelines for the 99 pollutants. It was felt that the AMS did not have the
staff and financial resources to perform the exhaustive process necessary
27
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TABLE 6. TOXIC AIR CONTAMINANTS AND AMBIENT AIR QUALITY GUIDELINES
LISTED BY AIR MANAGEMENT SERVICES, CITY OF PHILADELPHIA 3
Pollutant
Ambient Air GuTdèline
(Annual Average Unless
Otherwise Noted)
Acrylonitrile
Aidrin
4-Aminodiphenyl
3-Amino-1,2,4-triazole
Antimony and compounds
Arsenic and compounds
Asbestos
Benzene
Benzidi ne
Benzo(a)pyrene
Beryllium and compounds
BHC
Lindane and isomers
Bis(2-chloroethyl )ether
Bis(chloromethyl )ether
Bis(2-hydroxyethyl)-dithiocarbamic acid,
potassium salt
Cadmium and compounds
Captan
C arbaryl
Carbon tetrachi on de
Chioramben
Chlordane
Chi orobenzi 1 ate
Chloroform
Chioromethyl methyl ether
Chromium and compounds (hexavalent)
5 ppb
0.035 ug/m 3
0.8 ug/m 3
1.8 ug/m 3
1.2 ug/m 3
0.024 ug/m 3
0.005 fibers > 5 urn/cc
24 ppb
30 ug/m 3
0.0007 ug/rn 3
0.01 ug/m 3
1.2 ug/m 3
1.2 ug/m 3
120 ppb
0.0024 ppb
No Guidelinea
0.12 ug/m 3
35 ug/m 3
3.5 ug/m 3
12 ppb
1333 ug/m 3
0.35 ug/m 3
7 ug/m 3
24 ppb
0.02 ppb
0.12 ug/m 3
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
28
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TABLE 6. TOXIC AIR CONTAMINANTS AND AMBIENT AIR QUALITY GUIDELINES
LISTED BY AIR MANAGEMENT SERVICES, CITY OF PHILADELPHIA 3
(Continued)
Poll utant
Ambient Air Guideline
(Annual Average Unless
Otherwise Noted)
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
41.
42.
43.
44.
45.
46.
47.
48.
49.
50.
51.
52.
53.
54.
1.8 ug/m 3
0.1 ppb
No Guidelinea,b
105 ug/m 3
0.035 ug/m 3
120 ug/m 3
0.24 ppb
1.2 ppb
2.4 ppb
24 ppb
2.4 ug/m 3
0.07 ug/m 3
18 ug/m 3
2.4 ppb
37 ppb
2.4 ppb
0.7 ug/m 3
2.4 ppb
4.8 ppb
0.18 ug/m 3
0.48 ppb
0.06 ppb
0.0024 ppb
0.24 ppb
8.8 ug/ 3
0.88 ug/m 3
1.5 ug/m 3
24 ug/m 3
DDT/DDD
1 ,2-Dibromo-3-chloropropane
3, 3-Dichi orobenzidi ne
2,4-Dichiorophenoxy acetic acid
Dieldrin
Di(2-ethyl hexyl)phthalate
Dimethyl carbamyl chi oride
1,1-Dimethyl hydrazine
Dimethyl sulfate
Di oxane
Endosul fan
Endrin
Ethylenebisdithiocarbamic acid salts
Ethyl ene dibromide
Ethylene dichioride
Ethylene oxide
Ethylene thiourea
Epi chi orohydri n
Formaldehyde
Heptachi or
Hexachi orobenzene
Hexachi orobutadi ene
Hexamethyl phosphoramide
Hydrazi ne
Kelthane
Kepone
Lead and compounds
Manganese and compounds
29
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TABLE 6. TOXIC AIR CONTAMINANTS AND AMBIENT AIR QUALITY GUIDELINES
LISTED BY AIR MANAGEMENT SERVICES, CITY OF PHILADELPHIA 3
(Continued)
Pollutant
Ambient Air Guideline
(Annual Average Unless
Otherwise Noted)
Mercury and compounds
Methoxychi or
Methyl bromide
Methyl chloride
4,4-Methylene bis(2-chloroanhl me)
Methyl ene chloride
Methyl iodide
Mirex
Monomethyl hydrazi ne
B-Naphthyl amine
Nickel and compounds
4-Ni trod iphenyl
Ni trofen
2-Ni tropropane
N-nitrosodimethylamine
Parathion
Particulate polycyclic aromatic
hydrocarbons
Pentachi orophenol
Perchi oroethyl ene
Phenol
N-phenyl -B-naphthylamine
Polybrominated biphenyl s
Pol ychi on nated bi phenyl s
Propane sultone
B-Propiolactone
Propylene imine
Propylene oxide
0.24 ug/m 3
35 ug/m
120 ppb
1200 ppb
0.05 ppb
2400 ppb
5 ppb
0.88 ug/m 3
0.5 ppb
19 ug/m 3
0.24 ug/m 3
2.7 ug/m 3
0.75 ug/m 3 1
6 ppb
0.0004 ppb
1.8 ug/m 3
0.48 ug/m 3
12 ug/m 3
1200 ppb
120 ppb
45 ug/m 3
No Guidelinea
0.18 ug/m 3
No Guidelinea,c
No Guidelinea,b
4.8 ppb
250 ppb
55.
56.
57.
58.
59.
60.
61.
62.
63.
64.
65.
66.
67.
68.
69.
70.
71.
72.
73.
74.
75.
76.
77.
78.
79.
80.
81.
30
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TABLE 6. TOXIC AIR CONTAMINANTS AND AMBIENT AIR QUALITY GUIDELINES
LISTED BY AIR MANAGEMENT SERVICES, CITY OF PHILADELPHIA 3
(Continued)
Ambient
(Annual
Pollutant Other
Air
Guideline
Average Unless
wise Noted)
82. Quintozene 2.4 ug/m 3
83. Strobane 7.7 ug/m
84. 2-(p-tert-Butylphenoxy)-i sopropyl-
2-chioroethyl sulfite 18 ug/m 3
85. Tetrachlorinated dibenzo-p-dioxins 0.000035 ug/m 3
86. Tetrachioroethane 24 ppb
87. Tetrachlorvinphos 3360 ug/m 3
88. Thallium and compounds 2.4 ug/m 3
89. o-Tolidine No Guidelinea
90. Trichioroethylene 1200 ppb
91. Trichlorophenol isomers 3500 ug/m 3
92. 2,4,5-Trichiorophenoxy acetic acid I ug/m 3
93. Trifluralin 1150 ug/m 3
94. Toxaphene 1.2 ug/m 3
95. Vinyl bromide 12 ppb
96. Vinyl chloride 2.4 ppb
97. Vinyl cyclohexene dioxide 24 ppb
98. Vinylidene chloride 6 ppb
99. Vinyl trichioride 240 ppb
aNo guideline due to insufficient scientific evidence.
bNoted to be carcinogenic.
CNoted to be highly carcinogenic.
d24_hour averaging period.
31
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for air quality standards. By using guidelines to evaluate the health
hazard potential from these pollutants, problem pollutants and emission
sources are identified for regulation.
AMS has listed some limitations to this approach: 1) the entire
toxicologic data base had to be adapted for the Committee’s purpose which
often meant utilizing data not intended for the development of ambient air
quality guidelines (e.g., occupational exposure standards); 2) lack of
adequate toxicity data for several of the substances made it infeasible to
set guidelines which represent “safe” levels of exposure if “safe” levels
do, in fact, exist; 3) the variability of human susceptibility to chemical
exposure means that it is difficult to design guidelines for the entire
population, although by factoring in a sufficient margin of safety, it is
possible to approach minimal risk levels for even the most susceptible; 4)
due to the nature of toxicity testing (exposure to only one substance),
there are essentially no data on physiological responses produced by
simultaneous multiple exposures as is the typical case in the ambient
atmosphere (this situation may also be handled by factoring in an additional
margin of safety where needed); 5) the type and amount of emissions vary
with time. Any short-term, high level emission situation that posed an
immediate danger to the community would be handled independently by Air
Management Services directly. 3
The Committee designed a guideline-setting methodology to assign a
priority ranking to the toxicologic data and to outline the mathematical
adjustments necessary to derive ambient air quality guidelines from these
data. The methodology is outlined in Table 7.
As Table 7 illustrates, each of the 99 substances was first classified
as either a criteria pollutant, a carcinogen or a noncarcinogen. Criteria
pollutants are those for which there are National Ambient Air Quality
Standards. AMS also included in this group pollutants which have been
listed as hazardous air pollutants by EPA under Section 112 of the Clean Air
Act (National Emission Standards for Hazardous Air Pollutants (NESHAP). To
be considered a carcinogen, the pollutant had to be on at least one of the
following lists: the American Conference of Governmental Industrial
Hygienists list of human carcinogens (Ala and Aib) or industrial substances
32
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TABLE 7. PHILADELPHIA AIR MANAGEMENT SERVICES AMBIENT
AIR QUALITY GUIDELINE - SETTING METHODOLOGY FOR
TOXIC AIR CONTAMINANTS
I. Criteria Pollutants (as defined by EPA).
National Ambient Air Quality Standard (NAAQS)
National Emission Standard for Hazardous Air Pollutant (NESHAP), as
ambient standard
II. Carcinogens (as listed by ACGIH [ Ala, Aib, or A2] or by the National
Toxicology Program [ NTP])
A. Human no observed effect level (NOEL) or lowest observed effect
level (LOEL), inhalation, divided by 420
B. Threshold Limit Value (TLV) or OSHA permissible exposure limit
(PEL), preferably in existence 5 years or more, divided by 420
C. Animal NOEL or LOEL, inhalation, divided by 4,200 or 1,000
depending on study
0. Acceptable Daily Intake (Aol), as inhalation dose, divided by 10
III. Noncarcinogens
A. Human NOEL or LOEL, inhalation, divided by 42
B. TLV or OSHA PEL, divided by 42
C. Animal NOEL or LOEL, inhalation, divided by 420 or 100 depending
on study
0. AOl, as inhalation dose, divided by 10
IV. Additional safety factor added where justified
33
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suspect of carcinogenic potential for man (A2) or the carcinogen list of the
National Toxicology Program (NIP). All other toxics were considered
noncarcinogens .
For the criteria pollutant category, the NAAQS or NESHAP standard (if
expressed as an equivalent ambient standard) was adopted as the guideline.
For carcinogens and noncarcinogens, toxicologic data had to be adjusted to
derive guidelines. This leads to the toxicity data priority ranking. Human
data superseded animal data in all cases since the guidelines were for human
exposures. This is reflected in Table 7. The last priority ranking
concerns the route of exposure. Inhalation data always superseded data
based on ingestion or other exposure routes since inhalation is the dominant
exposure route for ambient air contaminants. Certain mathematical
adjustments were necessary once a suitable response or no-response base-line
level had been selected. If the test data were not based on continuous
exposure, a time-scale adjustment was applied. In most cases, the base-line
level was divided by 4.2. This factor is derived by dividing the usual work
shift of 40 hours (8 hours/day, 5 days/week) by 168 hours (continuous
exposure) and was used whenever the base-line level represented or simulated
occupational exposure. In addition, multiple safety factors of 10 were
applied as required in each of the following cases: when the toxic is a
carcinogen, when utilizing animal data (to allow for species differences
between animals and humans), and when considering differences in human
susceptibility. 3
Base-line levels were abstracted from any scientifically valid source
(as per the priority rankings noted above) and included lowest effect or
no-effect levels (in humans or animals) which elicit a physiological
response (e.g., tumor, kidney or liver damage), the TLV or Occupational
Safety and Health Administration (OSHA) permissible exposure limit (PEL)
(acceptable occupational exposure level), or acceptable daily intake (AD!)
(acceptable daily ingestion level of a pesticide in humans). In those cases
where ingestion data (e.g., an AD!) were used, the ingestion doses were
translated into inhalation doses for a 70 kg (154 pound) man breathing 20 M 3
air per day. Lastly, provisions were made for using additional safety
factors where justified. 3
34
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The guidelines were based on annual averages per agreement by AMS and
the Committee since the 99 listed substances generally pose more serious
health hazards from chronic (long-term) exposure than from acute
(short-term) exposure. The guidelines represent annual average levels to
which the community can be exposed continuously for long periods of time.
There is one exception to the annual averaging period. The guideline for
nitrofen is based on a 24-hour averaging period due to possible teratogenic
effects.
In comparing a source’s contribution to the ambient concentration to
the ambient guideline, AMS uses emission estimates from the source and a
computer dispersion model to determine the source’s annual contribution to
the ambient concentration. If the modelling indicates that the ambient
contribution from the source (i.e., the maximum ground level concentration
in an impacted area) is less than one-third of the guideline then a permit
would be granted. If the ambient contribution exceeds three times the
guideline then the source would be required to achieve additional emission
control. For ambient concentrations greater than one-third but less than
three times the guideline, AMS would review the data used in establishing
the guideline, possibly conduct ambient monitoring, and work with the source
to ensure that existing controls are being used effectively. The lower
limit of one-third and the upper limit of three times the guideline were
based on ambient monitoring study results compared to dispersion modelling
output. This comparison showed the model concentration could vary from the
measured concentration by a factor of three.
For dispersion modelling AMS is currently using EPA UNAMAP approved
models. (UNAMAP is EPA’s User Network for Applied Modeling of Air
Pollution.) Under an EPA grant, AMS has been working to develop its own,
more refined dispersion model that will better represent Philadelphia’s
dispersion conditions. These special conditions include building wake
effects, unusually shaped vents (e.g., goosenecks), refrigerated vents, and
ambient exposure close to the source.
Risk Assessment/Risk Management
Philadelphia does not use a risk assessment/risk management approach.
35
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Application and Enforcement
The Philadelphia program is in the process of being implemented in a
phased approach. The four phases 1 are:
Phase 1 - Control of Health Hazardous due to Toxic Air Contaminant (TAC)
Point Sources
A. Determine TAC emissions from each facility
B. Determine “worst case” receptor air quality
C. Evaluate hazard and negotiate settlement
Phase II - Complete TAC Emission Inventory and Determine Air Quality
A. Conduct engineering studies, source sampling, and source-oriented
monitoring to evaluate emissions from area sources and “exempt
sources”.
B. Develop and employ ambient air monitoring methods.
Phase III - Develop Strategies, Plans, and Regulations for TAC Problem Areas
Determined in Phase II
Phase IV - Implement Phase III Plans and Regulations, and establish a
Maintenance Program
AMS staff members report that work is currently ongoing in all four
phases.
The program is being implemented through the permitting system for new
and existing sources. New sources include newly constructed facilities as
well as existing facilities that have just begun to emit a listed pollutant.
There is no minimum emission level under which sources would be exempt.
However, the regulation specifically exempts combustion sources only using
coninercial fuel, retail dry cleaners, retail and noncon nercial handling of
motor fuels, incineration of waste materials other than industrial wastes,
and minor sources such as laboratory-scale operations.
Air Management Regulation Vi does not specify when sources must comply
with the guidelines. AMS uses the guidelines for evaluating sources rather
than for setting a specific emission restriction. AMS would work with a
permit applicant on scheduling necessary em ssion reduction measures.
36
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The regulation pertaining to toxic air contaminants has a provision for
sources to present data that would lead AMS to revise the guideline
pertaining to a certain pollutant. This provision has not been used by any
sources to date since none have greatly exceeded the guideline.
AMS has the authority to require sources to conduct ambient monitoring
and/or stack testing for enforcement purposes. To date, no sources have
been required to conduct such tests since these would be required in a
questionable situation and such situations have been very rare. The AMS
staff feels such monitoring or stack testing, if required, would be done on
a joint basis with AMS.
Although no sources have challenged any of the air toxics guidelines,
AMS has guidelines for review and appeal of any permit decision. If AMS and
the permit applicant could not reach an agreement on emission reduction and
the permit was denied, the applicant would have recourse to the Licenses and
Inspection Review Board.
37
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REFERENCES
1. Lazenka, C.A, Ciciretti, N.J., Ostrowski, R.T., Reilly, W. Experience
with Toxic Air Contaminants Control in Philadelphia. Department of
Public Health, Air Management Services, Philadelphia, Pennsylvania.
Presented at a conference sponsored by the State and Territorial Air
Pollution Program Administrators and the Association of Local Air
Pollution Control Officials, entitled Toxic Air Pollutants: An
Analysis of Regulatory Strategies.” September 21-22, 1983, Chicago,
Illinois.
2. Threshold Limit Values for Chemical Substances and Physical Agents in
the Work Environment with Intended Changes for 1980 , American
Conference of Governmental Industrial Hygienists, Inc., Cincinnati,
Ohio, 1980. (Reference 1 cites this reference. Updates to this ACGIH
publication are published annually.)
3. Air Management Services and the ! Q Advisory Committee for Toxic Air
Contaminants. Report on Recommended Ambient Air Quality Guidelines for
Toxic Air Contaminants. City of Philadelphia. June 1983.
38
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CHATTANOOGA-HAM! LION COUNTY
AIR POLLUTION CONTROL BUREAU
General Program Aspects
Chattanooga-Hau ilton County’s air toxics program was proposed by the
staff of the Chattanooga-Hamilton County Air Pollution Control Bureau in
1982. The Bureau is the professional staff of, and operates under the
direction of, a 10-member independent Board. The rules of the air toxics
program have not yet been adopted by the Board, the Chattanooga City
Commission, or the Hamilton County Commission. The basis of the program is
two rules, one of which defines a specific list of 99 toxic compounds. A
general rule concerning control of toxic air pollutants is also included as
part of the air toxics program. Best available control technology (BACT) is
often used in Chattanooga-Hamilton County’s program, which applies only to
new and modified sources.
Basis for AcceDtable Emission Limits
The Chattanooga-Hamilton County Air Pollution Control Bureau would
establish acceptable emission limits as a function of BACT.
The Bureau proposed that the initial program be directed toward new and
modified sources because a program addressing existing sources might be too
ambitious. Another reason for directing the program to new and modified
sources was that the Bureau realized that many chemical companies (where one
might find emissions of toxic substances) modify processes or add new
compounds to their product lines. Thus, over a period of time, the Bureau
would be regulating many of the larger sources of toxic emissions in
Chattanooga-Hamilton County by regulating new sources.
Before a permit is issued, the source must demonstrate that emissions
of toxic pollutants would not result in unreasonable risk to human health,
plant and animal life, or property. The Bureau may require best available
39
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control technology (BACT) as a condition of the permit. Sources may appeal
to the Board for relief, providing that the source demonstrates the change
would not create an unreasonable risk.
Unreasonable risk will be determined on a case-by-case basis. Sources
will be asked to submit scientific analyses of the worst case condition
concentration of toxic air contaminants, including such studies necessary to
provide a demonstration of unreasonable risk. The studies may include
independent research and tests and literature reviews. As part of the
permitting process, the Bureau would also consider as a factor (but not the
only factor) whether or not the worst case concentration would exceed a
fraction of the TLV. The Bureau has speculated that the fraction of 1/420
may be used in some cases, but has not yet determined when.
A list of 99 substances has been prepared by the Bureau, identifying
materials considered as toxic air contaminants subject to the rule discussed
above (Table 8). Toxic air contaminants are defined as those materials
which, because of their toxic, teratogenic, mutagenic, and/or carcinogenic
effects, may pose a potential threat to human health (acute and chronic
effects), and animal or plant life. The list of 99 substances was developed
by first reviewing other lists of suspected toxic substances from several
sources. Included among these lists were the list of chemicals regulated by
the Resource Recovery and Conservation Act and the Occupational Safety and
Health Administration. Substances were ranked according to the frequency
with which they appeared on the lists reviewed and a master list was
prepared. The master list was condensed, based on recommendations from a
consultant from a local university. Only those substances known or
suspected to be present in the Chattanooga environment and/or known or
suspected to be toxic, carcinogenic, mutagenic or teratogenic were retained
on the list.
Unreasonable risk to animal and plant life are included because damage
(defoliation) has been noted in a large area of southern Chattanooga.
Emissions from a local chemical facility were thought to be responsible.
The Bureau also realized that the public is concerned about damage to plant
and animal life in the area.
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TABLE 8. LIST OF 99 POLLUTANTS DEVELOPED BY
CHATTANOOGA-HAMILTON COUNTY AIR POLLUTION CONTROL BUREAU
Acrolein
Acryl amide
Acryl oni tn 1 e
Alderlin
Aldrin
4 -Ami nodi phenyl
3-Amino-1,2,4-triazole
Antimony
Antimony hydride
Antimony trifluoride
Antimony trioxide
Arsenic
Arsenic
Arsenic
Arsenic
Arsine
Banvel
Barium
Benzene
Benzidine
Benzo(a)pyrene
Benzotrichl oride
Benzyl chloride
Beryllium oxide
Beryllium sulfate
Cadmi urn
Cadmium chloride
Cadmium fluoride
Cadmium oxide
Cadmium sulfate
Carbon tetrachionide
Chi ordane
Chlorinated diphenyl
Chloromethyl methyl ether
Chromium
Cyanogen
Di borane
Dichioro diphenyl
Dieldrin
Dimethyl mercury
Dimethyl sulfate
Di ni trobenzene
Dioxin
Di phenyl
Endrin
Ethylene chi orohydri n
Ethylene dibromide
Ethylene oxide
Ethyl enirnine
Formaldehyde
51. Heptachior
52. Hexachi orocyci opentad I ene
53. Hydrazine
54. Hydrofluoric acid
55. Hydrogen cyanide
56. Hydrogen sulfide
57. Kepone
58. Lead acetate
59. Lead arsenate
60. Lead chromate
61. Lead oxide
62. Lead tetraethyl
63. Lindane
64. Malathion
65. Manganese
66. Manganese arsenate
67. Mercuric bichloride
68. Mercuric acetate
69. Mercuric cyanide
70. Mercuric nitrate
71. Mercuric oxide
72. Mercurous nitrate
73. Methyl isocyanate
74. Methyl iodide
75. Methyl mercury
76. Mirex
77. beta-Naphthylamirie
78. alpha-Naphthylthiourea
79. Nickel
80. Nickel carbonyl
81. Nickel cyanide
82. Nickel fluoride
83. p-Ni trochl orobenzene
84. 4-Nitrodiphenyl
85. Osmium tetroxide
86. Paraquat
87. Parathion
88. Phenol
89. Phenyl mercaptan
90. Phosgene
91. Phosphine
92. Rotenone
93. Selenium oxychioride
94. Sodium arsenite
95. Sodium selenide
96. Strychnine
97. o-Tolidine
98. 2,4,5-Trichlorophenoxy-
acetic acid
99. Vinyl bromide
pentoxi de
sul fide
trioxide
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
40.
41.
42.
43.
44.
45.
46.
47.
48.
49.
50.
trichioroethane
41
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The list of 99 substances may be revised by the Board (after the
program is adopted) based on the following considerations:
1. Risk of immediate acute or substantial harm to human health, at
concentrations likely to be encountered in the community;
2. Proven or suspected carcinogenicity as shown through
epidemiological or other scientific studies in either human or
animal populations or in laboratory studies of animals and other
experimental media;
3. Mutagenicity and teratogenicity as proven through human, animal,
or other experimental media (Ames tests);
4. Chronic adverse health effects or bloaccumulative effects in human
and other living members of the environment;
5. Findings of the U.S. Environmental Protection Agency (EPA), the
Occupational Safety and Health Administration (OSHA), or other
such agencies regarding toxicity;
6. Extent to which the substance is likely to be found in the
Chattanooga environment; and
7. Other factors necessary to protect the public health and welfare.
The Board, the City Commission and Hamilton County Commission will be
able to delete substances from the list with the Bureau recommending or
proposing such changes. In evaluating health effects studies, the primary
emphasis is on scientific validity rather than human evidence versus animal
evidence.
The second proposed rule addresses general provisions for toxic air
pollutants and is based on use of BACT in permitting. The rule states that
no release of a toxic air contaminant in excess of any emission limitation
imposed by the Director of the Bureau is allowed. A new or modified source
emitting a toxic air contaminant must obtain an installation permit. To
get a permit, the permit applicant must demonstrate that emissions from the
source will not result in an unreasonab’e risk to human health and safety,
plant life, animal life, or property. The Director may require BACT as a
permit condition.
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In the permitting process, the Bureau provides a determination of the
emission limitation which must be met by the source. A BACT determination
for a toxic pollutant would be made as for a criteria pollutant. The Bureau
would review data for control techniques successfully applied at facilities
similar to that of the permit applicant. Although the type of controls
would not be specified in the permit, the Bureau would define the emission
limit and operating parameters which must be met.
A series of public hearings have been held at which the proposed air
toxics program was discussed, both with the public and with industry.
Risk Assessment/Risk Management
The Chattanooga-Hamilton County Air Pollution Control Bureau is not
required by the proposed rules to perform risk assessments; however, they
may be conductedin certain instances. The source must provide
demonstration that emissions will not result in unreasonable risk.
APD1ication and Enforcement
Stack testing and/or ambient monitoring can be required by the Air
Pollution Control Bureau. Generally, stack testing of any new source of
toxic or criteria pollutants will be required. Ambient monitoring may be
required when sufficient concern about emissions from a new facility exists.
A toxics emissions inventory has been developed in conjunction with the
air toxics program. A relatively complete criteria pollutant inventory has
already been developed, and Hamilton County is refining that existing
inventory and adding information on emissions of air toxics.
43
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44
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MAINE BUREAU OF AIR QUALITY CONTROL
General Proqram As çts
In 1984, the Maine legislature mandated the Bureau of Air Quality
Control to complete a toxic air pollutant inventory. The legislature felt
that it was necessary to first determine what toxic pollutants were being
emitted and in what quantities, prior to accepting a regulatory program.
The inventory has been completed and the 58 hazardous air pollutants found
to be emitted in Maine have been prioritized, based on toxicity and the
quantity emitted into the ambient air. The prioritized list is being used
by the Maine Bureau of Health in assessing public health risks.
The Bureau of Health and the Bureau of Air Quality Control will soon
begin using interim exposure guidelines for regulating new sources until
risk assessments are completed. As a first approximation in setting
guidelines, the ACGIH TLVs were modified to account for differences in
exposure duration between occupational and community environments and
sensitive target populations.
Basis for Acceotable Ambient Limits/Emission Limits
Maine’s Bureau of Health has developed an approach to derive interim
exposure guidelines for potentially hazardous air pollutants. The Bureau’s
approach has undergone peer review and approval by the State’s Scientific
Advisory Panel. Under this approach, two categories of substances were
established; substances shown not to have carcinogenic, mutagenic,
teratogenic, or adverse reproductive effects and substances shown to have
the above effects. Under each category, four classes were identified. The
categories, classes, and interim guidelines (IG) are summarized below.
Category A : Substances not shown to be carcinogenic, mutagenic,
teratogenic, or to have adverse reproductive effects by the NTP, NIOSH,
IARC, ACGIH, or in the GENE-lOX data base.
45
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Class 1: Substances with ACGIH TLV-TWAs
A1 = TLV-TWA/60
Class 2: Substances with ACGIH TLV-TWAs and STELs
A2a = TLV-TWA/60, IGA2b = TLV-STEL/1O
Class 3: Substances with ACGIH Ceiling Limits
IGA 3 = TLV-C/10
Class 4: Substances without ACGIH TLVs or substances whose TLVs
are shown to be inadequate based on new information
IGA 4 = NOEL (LOEL) x 0.625 to 0.00625
Category B : Substances shown to be carcinogenic, mutagenic,
teratogenic, or to have adverse reproductive effects by the NIP, NIOSH,
IARC, ACGIH, or GENE-TOX
Class 1: Substances with ACGIH TLV-TWAs
IGB 1 = TLV-TWA/300
Class 2: Substances with ACGIH TLV-TWAs and STELs
IGB 2 = STEL/lO
Class 3: Substances with ACGIH Ceiling Limits
IGB 3 = TLV-C/10
Class 4: Substances without ACGIH TLV5 or substances whose TLVs
are shown to be inadequate based on new information
IGD 4 = NOEL (LOEL) x weight factor x 1/1000
= NOEL (LOEL)/400, IGOA = NOEL (LOEL)/3.3, 33.3, °
o o,C
The Bureau of Health noted that there is general agreement that TLVs
should not be used as a basis for air quality standards without
comprehensive risk assessment on the pollutants. However, the Bureau feels
that TLVs must be considered as the preferred source for developing interim
exposure guidelines after considering the sensitivity differences between
workers and the general population. In this respect, the Bureau of Health
views the use of TLVs as a first approximation for protecting the general
population. Completion of risk assessments can only ascertain the adequacy
of the modified TLV.
As an in nediate source, the Bureau of Health notes that the ACGIH-TLV
should be used in the development of a guideline because the TLVs represent
a body of accessible information, the ACGIH has made available the
46
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documentation for the TLVs, and the values are updated periodically, based
on review of new health information. Each TLV, however, must be evaluated
to determine if the basis of the TLV contains data which can be used
directly to derive a guideline. In addition, the history of each TLV must
be examined to assess the extent to which it has assured worker safety.
Information obtained from NIP, NIOSH, IARC, and data bases available from
the National Library of Medicine (Toxicology Data Bank and Toxline) will
augment the review of each TLV documentation before deriving guidelines.
In the absence of adequate risk assessments, populations at risk would
not be identified. It is for this reason that a 10 kg infant is chosen as
the basis for guideline development. By protecting the infant, a large
segment of the sensitive population would be protected, including infants,
and possibly, the developing fetus.
Rarely are TLVs based on teratogenic effects. For this reason, for
chemicals shown to be teratogenic but void of carcinogenic/mutagenic
effects, the NLM data base shall be consulted to obtain adequate
no-observed-effect-levels (NOELs) or lowest-observed-effect-levels (LOELs)
for teratogenic effects for deriving exposure guidelines based on a 60 kg
standard female.
For both technical and practical reasons, the TLV safety factors have
been pegged to the concentration in an inverse manner. As the magnitude of
the TLV increases, a correspondingly decreased range of fluctuation is
permitted. This is based on the premise that “not to decrease the factor
for TLVs of increasing magnitude would permit exposures to large absolute
quantities, an undesirable condition, and a condition that is minimized at
low TLVs. Moreover, larger factors at lower TLVs are consistent with
difficulties in analyzing and controlling trace quantities.’
The following paragraphs summarize the derivation of interim guidelines
for Maine’s two categories of hazardous air pollutants. 1
Category A : Substances not shown to have carcinogenic, mutagenic,
teratogenic, or reproductive effects.
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Class 1: Substances with TLV-TWAs
1. Conversion from working exposure to continuous exposure:
TLV-TWA 8 hrs er work day 5 days oer work week = TLV-TWA
X 24 hrs 7 days 4.2
2. Population diversity (i.e., conversion to account for the greater
sensitivity of some segments of the population:
TLV-TWA
42 X
3. Expression of body dosage:
Maine’s Bureau of Health notes that for metabolizable,
lipophilic chemicals, the data suggest that dose between species
is related to body weight to the exponent “b” with “b’ having a
value other than the 2/3, which is commonly used as the reference
base for relating body weight to surface area. The value for ubl
varies considerably for different animals and for different
metabolic processes involved, ranging from 0.6 to 0.81 and higher.
Assuming that the majority of the State’s hazardous air pollutants
are lipophilic, a conservative approach to intraspecies dose
extrapolation is used, setting the value of the exponent “b” to
1.0, thereby permitting a linear dose extrapolation on a body
weight basis.
The Bureau of Health feels that inter- and intraspecies
linear dose extrapolation on a body weight basis can also be
justified by pharmacokinetic and pharmacodynamic behavior of
xenobiotics at low doses. Under these conditions, it is expected
that metabolism and elimination would effectively remove most of
the absorbed dose from circulation, thus ensuring that a) uptake
by inhalation never reaches steady-state, and b) uptake would be
linear with time. Assuming this to be the case, the absorbed dose
would not be a function of surface area but a function of alveolar
ventilation rate, cardiac output and blood/gas partition
coefficient.
4. Adult inhalation rate to infant inhalation rate:
Adjusting airborne concentrations to reflect inhalation rate
differences between adults and infants can be accomplished by two
approaches, each using empirically derived data.
3 The first allometric approach assumes an inhalation sate of
20 m /day for a 70 kg adult and an inhalation rate of 4 m /day for
a 10 kg infant. Incorporating the factors for continuous exposure
and population diversity, the equation becomes:
48
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TLV-TWA x (40 hrs ger work week/168 hrs) x 1/10 x 20 m 3 adult
inhalation rate/4m infant inhalation rate x
10 kg infant/70 kg adult = TLV-TWA x 0.017 or TLV-TWA/59
The second allometric approach is rather complex, compared to
the first approach. This approach relies on modeling equations
which were based on experimental data from animals and humans.
The equations relate parameters that affect uptake by inhalation
at low concentrations. Specifically, the parameters addressed are
alveolar ventilation, cardiac output, and the blood/gas partition
coefficient.
Using the first and second approaches, the final form for the
interim guideline (IG) for substances in Category A, Class 1 is:
IGA 1 = TLV-TWA/60
Class 2: Substances with TIV-ThA and STELs.
Substances with TLV-TWA and STELs have two interim guideline values; a
chronic guideline based on the TLV-TWA with an averaging time of one week,
developed as in IGA I , and a shortterm guideline based on the STEL divided
by a safety factor:
IGA2a = TLV-TWA/60 and IGA2b = TLV-STEL x 1/10
The time limit for the TLV-STEL guideline may range from 5 to 30 minutes,
depending on the data base.
Class 3: Substances with TLV ceiling limits.
Given the basis for developing TLV-C, the Bureau of Health feels a
safety factor is the only consideration necessary for deriving interim
guidelines. Thus:
IGA 3 TLV-C x 1/10, not to be exceeded
Class 4: Substances without TLVs or substances whose TLVs are shown to be
inadequate based on new information.
The selected data base shall be consulted to obtain adequate human or
animal NOELs or LOELs (human data takes precedent over animal data) for
chronic effects (unrelated to those listed for Category B substances) for
deriving exposure guidelines based on a 10 kg, 1 year-old child. Thus:
IGA 4 NOEL (LOEL) x 1/uncertainty factor x 10 kg x 1/4 m 3
49
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where:
10 g = body weight of a I year-old child
4 m = assumed daily inhalation rate
Uncertainty factor = ranges from 10 to 1000, depending on
origin and adequacy of data base
therefore:
NOEL or LOEL may be divided by 4, 40, or 400
The selected exposure guideline shall thus be the NOEL/LOEL divided by
one of the above values.
General guidelines for uncertainty factors were provided by the NAS
Safe Drinking Water Committee. These factors are:
10 = is used when extrapolating from valid results from studies on
prolonged exposure by humans. Factor is intended to protect the
sensitive members of human population.
100 is used when experimental results of studies of human inhalation
are not available or when extrapolating from valid results of long-term
studies on experimental animals when results of studies of human are
not available or are scanty.
1000 = is used when extrapolating from less than chronic results on
experimental animals or humans when there are no useful long-term data.
Category B : Substances shown to be carcinogenic, mutagenic, teratogenic, or
to have adverse reproductive effects by the NTP, NIOSH, IARC, ACGIH, or the
GENE-TOX data base.
Class 1: Substances with TLV-TWA
1G 81 = TLV-TWA/300
The value of 300 is based on the approach adopted by the State of New
York Departments of Health and Conservation for their air toxic program
which has been in place for about 20 years. Maine’s Bureau of Health feels
this denominator is arbitrary and certainly less protective than basing a
value on a risk level of 1 in 1,000,000 or 1 in 100,000. However, to be
confident of the latter approach an indepth risk assessment would be
necessary. Given the emissions of other potentially hazardous pollutants
and the need to prioritize chemicals for risk assessment based on toxicity
and exposure, the Bureau of Health and the Scientific Advisory Panel believe
that the above approach is appropriate for addressing chemical carcinogens
as an interim guideline.
If ACGIH did not consider carcinogenicity or teratogenicity in
establishing the TWA, the Bureau of Health would use the NOEL in setting the
guideline (see 1G 84 ).
50
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Class 2: Substances with TLV-TWA and STELs
This class of substances had been assigned two interim guidelines. One
guideline is based on protection against short term exposures using the
following approach:
IG = STEL/lO; time limit may range from 5 to 30 minutes, depending on
da base.
The second guideline value is based on protection against carcinogenic,
teratogenic, or adverse reproductive effects of these substances using Class
4 approach described below or on TWA/60, whichever is smaller. The second
guideline value for substances shown only to have mutagenic properties will
be based on systemic effects or on .j ’j vivo mutagenic data using Class 4
approach or TWA/60, whichever is smaller.
Class 3: Substances with ceiling limits
Substances shown to be carcinogenic, mutagenic, teratogenic, and to
have reproductive effects by the NIP, NIOSH, IARC, GENE-lOX, or the ACGIH,
and whose ACGIH ceiling limits are based on effects other than those listed
in this section shall be assigned two interim guideline values. One
guideline will be based on protection against instantaneous exposures using
the following approach:
IGB 3 = Ceiling limit/lO; not to be exceeded instantaneously
The second guideline value will be based on protection against carcinogenic,
teratogenic, or adverse reproductive effects of these substances using the
Class 4 approach described below. The second guideline value for substances
shown only to have mutagenic properties will be based on systemic effects or
fl viv mutagenic data using the Class 4 approach.
Class 4: Substances without TLVs and/or meeting criteria described in
Classes 2 and 3 of Category B substances or substances whose TLVs are
shown to be inadequate based on new information.
A. Carcinogenic Substances
The Bureau of Health will utilize threshold levels for the purposes of
deriving interim guidelines for carcinogens. The data base (i.e., NLM, NTP,
NIOSH, IARC, ACGIH) shall be consulted to obtain adequate human or animal
NOELs or LOELs values (human data takes precedent over animal data). It is
assumed that the surface area rule applies for dose extrapolation because of
the direct interaction with DNA as suggested by the EPA’s CAG and the NAS.
(The surface area rule is used to estimqe equivalent dose between species.
When dose is measured in milligram per m body surface per day, it is
assumed body weight to the 2/3 power is equivalent to surface area.)
51
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Due to the carcinogenic endpoint, a safety factor of 1,000 is employed.
Thus:
IG = NOEL (LOEL) x (animal body weight/adult human male body
weight) x 70 kg x 1/1000 x 1/20 m
where:
animal body weight = in kg and depends on test species
adul human male body weight = standard 70 kg
20 m = assumed daily inhalation rate
B. Substances Shown to be Mutagenic Only
For the purposes of deriving interim guidelines, the data base (i.e.,
NLM, NIP, NIOSH, IARC, ACGIH) shall be consulted to obtain adequate NOELs or
LOELs values for systemic effects. Where available, adequate human or
animal NOELs or LOELs (human data takes precedent over animal data) for j.
vivo mutagenic effects will be used in place of systemic effects. Thus:
For systemic effects, the guideline will be based on a 10 kg child,
thereby retaining consistency with Category A approach. Due to the
mutagenic concern, a safety factor of 1000 is employed. Thus:
IGB 4 b = NOEL (LOEL) x 1/1000 x 10 kg x 1/4 m 3
therefore:
IGB4b = NOEL (LOEL)/400
For in vivo mutagenic effects, it is assumed that the surface area rule
applies for dose extrapolation as with carcinogens because of the
direct interaction with the DNA as suggested by the EPA’s CAG and the
NAS. Due to the inutagenic end point, a safety factor of 1000 is
employed. Thus:
IG = NOEL (LOEL) x (animal body weight/adult human male body
weight) x 70 kg x 1/1000 x 1/20 m
C. Chemicals with Teratogenic or Adverse Reproductive Activity
For the purposes of deriving interim guidelines, the data base (i.e.,
NLM, NIP, NIOSH, IARC, ACGIH) shall be consulted to obtain adequate human or
animal NOELs or LOELs va’ues (human data takes precedent over animal data)
for deriving guidelines based on a 60 kg adult female. Thus:
IGB4C = NOEL (LOEL) x 1/uncertainty factor x 60 kg x 1/20 m 3
52
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where:
Uncertainty factor = ranges from 10 to 1000, depending on adequacy
of data base as described in Category A.
or: NOEL or LOEL/3.3, 33.3, or 333
The interim guidelines developed by the Bureau of Health have been
recently approved by the State’s Scientific Advisory Panel. The Bureau of
Air will have the responsibility of implementing the guidelines for new
sources through the source licensing process. (Existing sources will be
required to apply best practical treatment as determined on a case-by-case
basis.) Although the guidelines have not yet been used, the Bureau of Air
Quality Control anticipates that dispersion modeling estimates of a source’s
contribution to the ambient concentration will be compared to the guideline.
Sources that approach or exceed the interim guideline will trigger more
discussion among the permit applicant and the Bureau of Air Quality Control
and Health. No decision has been made as to how ambient guidelines will be
related to emission limits applied to the source.
Risk Assessment/Risk Management
Maine’s Bureau of Health has recently begun conducting risk assessments
for the 58 hazardous air pollutants identified in the legislatively mandated
inventory. The Bureau plans to follow EPA risk assessment guidelines. The
results of these risk assessments will be available to the Department of
Environmental Protection to establish pollutant or source-specific
standards. It is anticipated that a guideline approach may be chosen
instead of standards.
The risk assessment process, recently begun for toluene, is made up of
the following steps:
o review of secondary literature sources; such as EPA (air and
water), NAS, NIOSH, WHO, and computerized literature search of NLM
data bases;
53
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o examination of pertinent effects of concentrations expected at
ambient levels and determination if a carcinogenic threshold
exists; and
o recommendation based on existing evidence.
The State’s recent inventory and the scheme used to prioritize
pollutants for future risk assessments are key steps in the risk assessment
process. The legislation that required the State’s inventory required that
the following information be gathered for sources emitting any substance
that may be a potential hazardous air pollutant:
- number of sources,
- location of each source or category of source,
- the quantity emitted by each source or category of sources,
- the total emissions, and
- the percentage of total emissions generated by sources with
existing air licenses.
The inventory was conducted via a detailed questionnaire, which was
sent to approximately 700 sources, including process sources; incineration
sources; storage facilities; and loading, unloading, and transfer
operations. The scope of the inventory was limited to 199 substances
identified as potentially hazardous by the Bureaus of Air Quality Control
and Health. No reporting was required for a use rate below 2000 pounds per
year. (The 2000 pounds reporting cutoff was selected by the Bureau of Air
Quality Control after consultation with an industry committee who reviewed
the inventory questionnaire.) The inventory indicated 58 of the
199 substances were emitted in Maine. 2
The next step after completion of the inventory was to prioritize the
58 pollutants identified for future risk assessment. Two components were
addressed in the ranking system: toxicity and exposure. The Bureau of
Health noted that combining these two components is necessary for a balanced
perception of actual public health risk.
54
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The ranking measured all the pollutants against a standardized set of
criteria, and assigned numerical scores based on these criteria. The Bureau
of Health feels that although the ranking system is not directly
translatable into a measure of public health risk, it provides a relative
index of the pollutants’ potential health threats.
Four main criteria were used in the toxicity component ranking system,
developed to be a general scheme that could be completed quickly for a large
number of pollutants. The toxicity criteria addressed are: carcinogenicity,
mutagenicity, reproductive effects, and acute effects. Scoring for the
toxicity component was based on studies cited in the NIOSH publication,
Registry of Toxic Effects of Chemical Substances (RTECS). Values were
assigned for the four toxicity criteria based on the weight of evidence
found in RTECS. Values for each of the criteria range from zero to four,
except for acute toxicity, which ranges from one to four. Scores for all
four health related criteria are added for the total toxicity component
score.
The Bureau of Health noted that there are several difficulties involved
with the derivation of a general toxicity value for a wide variety of
pollutants. For instance, some scores may be underestimated due to
inadequate data. To compensate for this, the standard deviation of the four
health effects scores was added to the sum of the scores of the four
toxicity criteria.
For the exposure component of the ranking scheme, emission estimates
for all 58 hazardous air pollutants identified in the inventory were
provided by the Bureau of Air Quality Control. The estimates were in the
form of Statewide summations in pounds per year from industrial, commercial,
residential, and mobile sources.
To rank the 58 pollutants, the Bureau of Health listed the pollutants
in order of decreasing toxicity and emissions. The rankings in each list
were added together to produce a total score, such that pollutants decreased
in priority as their total scores increased. The toxicity and exposure
components were not weighted due to the uncertainties involved with the
weighting process. The 58 pollutants are listed in order of priority in
Table 9.
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TABLE 9. PRIORITY RANKING FOR MAI E’S
HAZARDOUS AIR POLLUTANTS
Toxicity
Emission
Pollutant Rank
Rank Total
1. Toluene 18 1 19
2. Tetrachioroethylene 15 6 21
3. Formaldehyde 2 21 23
4. Benzene 2 24 26
5. Epoxypropane 10 19 29
6. Chlorine 27 3 30
7. Methylene chloride 18 13 31
8. 1,1,1-Trichioroethane 30 2 32
9. Lead 18 16 34
10. Styrene 2 32 34
11. Trichioroethylene 15 20 35
12. Benzo-a-pyrene 7 30 37
13. Xylene 34 4 38
14. Methyl mercaptan 31 9 40
15. 1,2-Dichioroethane 15 28 43
16. Methyl cellosolve 36 7 43
17. Methyl methacrylate 28 15 43
18. Hydrogen chloride 18 26 44
19. Bis 2-ethyihexyl phthalate 11 34 45
20. Chlorine dioxide 36 10 46
21. Ethylene glycol ethyl ether 36 11 47
22. Naphthalene 18 33 51
23. Acetone 46 5 51
24. Methyl ethyl ketone 43 8 51
25. Arsenic 1 50 51
26. Hydrogen sulfide 41 12 53
27. Hydrazine 7 49 56
28. Ethylene oxide 11 45 56
29. Formic acid 31 25 56
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TABLE 9. Continued
Toxicity
Emission
Pollutant Rank
Rank Total
30. Chromium 2 54 56
31. Methyl chloride 28 29 57
32. Zinc 11 47 58
33. Cadmium 7 52 59
34. Epichiorhydrin 2 58 60
35. Phenol 24 37 61
36. n-Butyl acetate 49 14 63
37. Diethyl sulfate 26 38 64
38. Butanol 49 17 66
39. Copper 11 55 66
40. Diphenyl methyl 4,4-diisocyanate 51 18 69
41. Manganese 35 35 70
42. Turpentine 51 22 73
43. Nitric acid 47 27 74
44. Ethyl acetate 51 23 74
45. Ethyl benzene 18 56 74
46. Furfural 40 36 76
47. Barium 36 44 80
48. Mercury 24 57 81
49. Biphenyl 43 40 83
50. Cyanide 41 42 83
51. p-Nitrophenol 31 53 84
52. Methyl isobutyl ketone 57 31 88
53. Ethanolamine 51 41 92
54. 1,2-dichlorobenzene 51 43 94
55. Tetrahydrofuran 43 51 94
56. Oxalic acid 47 48 95
57. Titanium oxide 57 39 96
58. Acetic anhydride 51 46 97
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ApDlication and Enforcement
As mentioned above, the Bureau of Air Quality Control plans to
implement the interim ambient air guidelines for new sources, while
individual risk assessments are being developed for the 58 hazardous
pollutants. Existing sources will be required to use best practical
technology until risk assessments are completed. Since the interim
guidelines have not been implemented yet, many of the questions associated
with application have not been addressed. The interim guidelines will be
applied for all toxic pollutants emitted from new sources and implemented
through the existing licensing process. The State does not currently issue
permits to area sources such as dry cleaners and degreasers. Such sources
will be controlled by source-specific regulations.
58
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REFERENCES
1. Shehata, 1., Derivation of Interim Exposure Guidelines for the
Hazardous Air Pollutant Program. Second Draft. State of Maine,
Department of Human Services. Augusta, Maine. March 27, 1985.
21 pp.
2. Bureau of Air
Pollutants in
Department of
Maine. March
Quality Control, Bureau of Health. Hazardous Air
Maine: Emissions Inventory and Ranking System.
Environmental Protection, State of Maine. Augusta,
1985. 76 pp.
59
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60
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MISSISSIPPI BUREAU OF POLLUTION CONTROL
General Program Aspects
Mississippi’s air toxics program is based on informal guidelines and
staff policy. The program has not been presented at public hearings and
does not involve regulations or standards. The program’s emphasis is placed
on new sources. During review of the permit application, the agency
investigates the potential for emissions of toxic pollutants. The
pollutants considered are not limited to a specific list. The decision on
which noncarcinogenic pollutants to address is officially made by the permit
board, with substantial input from the Bureau of Pollution Control. All
known and suspect carcinogens are addressed in the program.
Emissions of air toxics from existing sources are addressed through the
NESFIAP process. If a large number of complaints are received by the agency
concerning an existing source, the agency evaluates those sources on a
case-by-case basis. An opportunity to use the case-by-case approach has not
yet been encountered by the agency.
Basis for Acceptable Ambient Concentrations
The Mississippi Bureau of Pollution Control separates toxic air
pollutants into categories of known or suspected carcinogens and
non-carcinogens. At this time, carcinogens are defined based on guidance
from EPA. For noncarcinogens, a guideline for acceptable ambient
concentrations is determined based on occupational health standards. If
several occupational health standards are available (i.e., NIOSH recommended
standards, OSHA PEL’s, ACGIH TLV (TWA), health standards from Europe or the
Soviet Union), the median of the available values is calculated. The median
of various occupational health standards is used because the occupational
data can not be directly extrapolated to ambient environmental conditions.
Using a median value also helps smooth extremes of data. One percent of
61
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that median value is used as the acceptable ambient concentration guideline
for that chemical. The fact that 1 percent has been used by several other
states in air toxics work was heavily considered in selecting the safety
factor. The Bureau of Pollution Control believes that the 1 percent factor
is conservative enough to use as a guideline.
Mississippi uses a 24-hour averaging time in their evaluations of
non-carcinogens. The 24-hour averaging period was selected to coordinate
easily with dispersion modelling work. The agency believes that the 24-hour
averaging time is also conservative enough to use in developing guidelines.
Models such as PTMAX or PTPLLJ are used to estimate ambient concentrations.
The guidelines are applied during the permitting process. The Bureau
uses permit application data and other references to help determine the
likelihood of a chemicals use or presence in a given process. Thus, far in
the history of the program, a clear, definitive case having an air toxics
problem has not been encountered.
Risk Assessment and Risk Management
For known and suspect carcinogens, the agency uses risk assessment and
risk management. EPA CAG unit risk factors are multiplied by predicted
(modelled) annual average concentrations to obtain an estimate of risk.
Normally the CRSTER model, which predicts annual average concentrations, is
used by the agency. EPA health assessment documents are reviewed to obtain
specific health effects data. If no CAG risk factor is available for a
chemical, the agency attempts to locate risk factors or similar data
developed by other agencies or groups. An annual averaging period is used
to fit with the unit risk factors which are based on annual exposure.
Results of the risk assessment are presented at a public hearing. If
the source disagrees with the agency’s risk estimation, they may present
their own risk assessment. Mississippi’s risk management is based on
definition of significant risk. If the calculated risk is less than or
equal to io6, the risk is considered insignificant. A risk greater than or
equal to 1O is considered significant. If the risk is significant, then
the agency works with the source on a case-by-case basis to reduce the risk.
62
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A grey area exists if the risk is estimated to be between 1O and
i0 6 . Case-by-case decisions are made in such situations. At this point,
no “controversial” cases have been encountered by the state.
Because Mississippi’s program is that of informal guidelines, no real
public or industry participation was involved in program development.
However, the Bureau of Pollution Control routinely involves industry and
manufacturing groups in their activities by annually advising those groups
of the agency’s planned actions for the coming year.
Application and Enforcement
The acceptable ambient concentrations guidelines and risk
assessment/risk management processes are used as guidelines by agency
personnel during the permitting process for new sources. New and existing
sources’ emissions of some noncriteria pollutants are addressed via NESHAPS.
Both new and existing sources are also reviewed for non-NESHAP toxics.
When an acceptable ambient concentration is determined from the health
effects literature, an acceptable emission rate is not generally calculated.
Instead, the proposed emission rate of the source is modelled to compare
predicted concentrations to the acceptable ambient concentration.
Stack testing has been required by the agency when possible because it
is generally considered the best measure of compliance capability. One
facility was tested for dioxins and another for acrylonitrile. Thus far,
the “worst case” situation to undergo the public hearing process involved a
source whose emissions were associated with an estimated risk of 1O . No
objections were noted during the public comment period.
Compliance with permit limits is checked by testing emissions, plant
inspections, and/or plant records. Exceedances of limits are addressed
through the Bureau’s standard enforcement mechanisms which apply to all
regul ated sources.
63
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64
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NEVADA AIR QUALITY CONTROL
General Program Asoects
The State of Nevada has in place air toxics regulations which cover new
and existing sources. The program is based on the application of safety
factors to TLVs and on risk assessment that may be performed on a
case-by-case basis. The pollutants covered by the program are not limited
to a specific list. An emissions inventory is being prepared by the Air
Quality Control Division.
Basis for Acceotable Ambient Concentrations
The State of Nevada devised an ambient air program with the intent of
ensuring public health and safety, since there are no Federal guidelines
established at this time.
Review of other in-place programs (California, Michigan) and a
State-by-State air toxics survey prepared by STAPPA/ALAPCO showed that the
most common approach throughout the United States was the use of TLVs as
established by the ACGIH.
Information provided in the “Documentation of the Threshold Limit
Values” prepared by ACGIH was reviewed. The various chemical substances and
physical agents listed were evaluated to determine:
- if they could become airborne (i.e., are atmospheric exposures
possible);
- if so, the effect they would have on living organisms; and
- the level of exposure considered to be safe.
In terms of health effects, the TLV documentations were reviewed and
the substances to be considered as air toxics assigned to the following
categories:
65
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Irritant : Those substances which would, upon sufficient exposure,
cause an irritation in the test or exposed subject. Substances to which
exposure at even high levels (those to which a subject would not normally be
exposed) were nonlethal. The effects of the irritation were considered
reversible upon removal from exposure or with time.
Warning : A substance which at normal levels of exposure may cause
irritation within the test subject. With exposure at high concentration
(those not normally encountered) the substance may cause irreparable damage
to tissues or systems or be lethal via suffocation, etc.
Toxic : A substance which at even limited levels of exposure may cause
irreparable damage to tissues or systems and, upon sufficient exposure, be
lethal.
Carcinogen : Those substances which are recognized as being
cancer-inducing either by laboratory experimentation or field studies of
exposure victims.
SusDected Carcinogens : Substances which evidence suggest may be
cancer-inducing agents either by laboratory experimentation or by field
studies. (Teratogens and mutagens are not addressed as distinct
categories.) The ACGIH lists of carcinogens and suspect carcinogens were
used by the staff. Classes of irritant, warning and toxic were developed by
the Air Quality Control Division staff, based on data in the documentation
of TLV.
The 8-hour ambient air quality standard (AAQS) is derived by the
following equation: TLV x (1/10) (40 hours work week)/(168 hours per week)
= 1/42 or AAQS = TLV/42. In order to ensure public health and safety but
not cause an economic hardship on business, a 10-fold safety factor was
applied to the TLV.
The safety factor of 10 was chosen after review of the
“Documentation of Threshold Limit Values” and consideration of the fact
that TLVs are designed to protect healthy workers. Populations potentially
exposed to toxic air pollutants include the very young, elderly and
individuals with chronic ailments. After discussions with the public and
industry representatives, a safety factor of 10 was chosen to ensure no
66
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suspected or possible health hazard would arise. The factor is applied to
the time weighted average TLV, but ceiling limits and short-term exposure
levels (STELs) are reviewed by the State as well to obtain additional
information on potential toxicities of chemical substances.
An averaging time of 24 hours is used by Nevada in conjunction with the
factored TLV. The 24-hour period was chosen because itrepresents total
daily exposure.
Formal exposure assessments are not conducted by Nevada. However, the
state does attempt to estimate the number of persons that may be exposed by
location. Also, the regulations address urban and non-urban exposure
scenarios. That is, in urban areas the concentration of a given pollutant
at the sources property line is compared to 1/42 of the TLV. In non-urban
areas, the expected concentration at the closest residence or public use
area is compared to 1/42 of the TLV.
BACT review is required for any source emitting 1/4 pound of a
pollutant per 8-hour period. Air Quality Control models the impact on the
area surrounding the source, identifying the concentration at the property
line or closest residence/public use area. Models used thus far include the
Valley and PTMAX models. If the ambient concentration (l ’42 of the TLV) is
exceeded, then BACT is required to the extent that the source will be below
the standard. This procedure is followed for pollutants in the toxic
carcinogen or suspected carcinogen categories described previously. If the
pollutant is considered to be in the “warning t ’ category, and predicted
concentrations exceed 1/42 of the TLV, the source may appeal BACT decision.
The procedure requires that the source provide documentation that even after
BAd, the concentration of a “warning category pollutant will exceed the
allowable ambient concentration. The 1/42 of the TLV rule may be relaxed
for that source. Emissions of substances classified as “irritant” are
subject to BACT review if greater than 1/4 pound is emitted in a 8-hour
period. BACT determinations for emissions of toxics are made the same way
as for criteria pollutants, using concepts of the Clean Air Act.
During the development of the program, a series of meetings and public
hearings were held to allow industry and public participation. A hearing
was held when the program was proposed (May 1984), and a second public
67
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hearing was held (July - August 1984). Between the hearings, meetings were
held with mining associations, utilities and others. When the program was
presented before the Con ission, State Air Quality Control staff members
report that the State and industry groups were in good agreement over
program aspects.
Risk Assessment/Risk Management
A formal risk assessment/risk management process is not included in
Nevada’s air toxics program. The State does determine the expected
concentration of a given pollutant by modeling and reviewing the number of
people in the area impacted. The State also determines the types of
populations potentially exposed, whether they include businesses or
residential areas and the suspected length of time the population would be
exposed. A general assessment of the number of cases of cancer expected
during the lifetime of the plant may be performed by the source for relief
or variance of regulations. Lifetime of the plant is reported by the
source. This measure of exposure time was thought to be more representative
than a total lifetime exposure.
ADDlication and Enforcement
The State of Nevada administers the air toxics program through the
permitting process. New sources are brought into the program as they apply
for permits. Existing sources are reviewed when their current permits
expire. Sources which are not currently permitted, but are thought to be
emitting greater than 1/4 pound of a pollutant per 8-hour period, will be
investigated by the Division.
Nevada’s permitting process consists of two phases. In the first
phase, a source is granted a construction permit, with emissions information
based on engineering estimates. Then within 180 days after construction is
complete, the source must demonstrate that it meets permit conditions.
Stack testing data are usually the method of demonstration. The source is
then issued a final 5 year operating permit.
68
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The State has calculated emission limits for sources, usually when the
efficiency of the control device is uncertain. When the final permit is
issued to the source, the emission rate is measured.
Monitoring has been performed at some sources in cases when predicted
ambient concentrations were close to (90 percent of) the standard.
Frequency of monitoring depends heavily on the availability of a monitoring
method for the specific pollutant.
Penalties for noncompliance with air toxics regulations in Nevada are
the same as for criteria pollutants. The fine is $5,000 per day per
violation.
An appeal procedure is available to sources that disagree with the air
toxics standards. For pollutants in the “warning” category, the source may
appeal to Air Quality Control. For pollutants in the toxic, carcinogen, or
suspected carcinogen, the source may appeal to the Commission. No source
has made an appeal to either group at this time.
69
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70
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CONNECTICUT AIR COMPLIANCE UNIT
DEPARTMENT OF ENVIRONMENTAL PROTECTION
General Program Asoects
Connecticut’s air toxics program is based on standards for maximum
allowable ambient concentrations derived from safety factors applied to
occupational standards. Different safety factors are used for the three
pollutant classifications developed by the Department of Environmental
Protection. Emphasis is placed on assuring that new sources are included in
the program, but existing sources are also covered. The program is
anticipated to be in effect by the end of 1985.
Basis for Acceptable Ambient Concentrations/Emissions Limits
The Connecticut Department of Environmental Protection (DEP) plans to
develop maximum allowable ambient concentrations (MAACs) based on
occupational limits of ACGIH, OSHA, NIOSH, and any other recognized standard
setting agency. Each organizations’ limits are reviewed and the most
restrictive value is used in developing the MAAC. The Connecticut DEP
includes as hazardous air pollutants:
- The 47 substances identified in Substitute House Bill 7204 (1983).
- Substances identified as carcinogens or suspected carcinogens by
IARC, ACGIH, Nd, and NTP or the United States Public Health
Service.
- Substances for which maximum allowable workplace exposures have
been established by principal compilers of such listings such as
ACGlH, NIOSH and OSHA.
71
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All pollutants considered are divided into three classes or groups
(Table 10). Group I includes proven human carcinogens, defined as chemicals
on NIP List A, IARC Groups 1 and 2A, and ACGIH List Al. In addition, a list
of 16 chemicals of concern have been developed in conjunction with
Connecticut’s drinking water regulations. Group I also includes carcinogens
identified on a list developed by the State (Connecticut General Statutes,
Section 19a-329). Presently, 71 substances are in this group.
Group II chemicals include suspect carcinogens, mutagens, and
teratogens. Specifically, this group includes chemicals contained in NTP
List B, IARC Group 2B, and ACGIH List A-2. NIOSH data, usually from the
Registery of Toxic Effects of Chemical Substances or RIECS, is used to
define mutagens and teratogens. One hundred forty-seven substances are now
classed in Group II.
Connecticut DEP Group III consists of all noncarcinogenic substances of
concern; there will be 635 substances in Group III.
To resolve possible differences concerning identification of
carcinogens and review MAAC(s), the Connecticut air toxics program will
include a seven member Hazardous Air Pollutant Review Panel of health
scientists appointed by the Governor and other political leaders. The panel
will consist of a toxicologist, an epidemiologist, and a physician
specializing in environmental or occupational medicine. The other members
will have experience in related fields such as air pollution, biochemistry,
or biostatistics.
The standards for air toxics or MAACs will be determined by dividing an
8-hour TLV or other occupational standard by a safety factor. The safety
factor differs for each of the three groups of pollutants, as shown in the
table below:
Pollutant Groui Safety Factor
1 200
2 100
3 50
72
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TABLE 10. SUMMARY OF CLASSIFICATION SCHEMES
FOR KNOWN AND SUSPECTED
CARCINOGENS USED BY CONNECTICUT
DEPARTMENT OF ENVIRONMENTAL PROTECTION
Group I: NTP List A - Known carcinogens
IARC Group 1 - Sufficent evidence in epidemiological studies,
causally associated with cancer in humans
IARC Group 2A - Limited evidence in humans, probably
carcinogenic to humans
ACGIH List Al - Human carcinogens
Group II: NTP List B - Reasonably anticipated to be carcinogenic
IARC Group 2B - Sufficient evidence in animals, inadequate
data in humans; probably carcinogenic in
humans
ACGIH List A-2 - Industrial substances suspect of carcinogenic
potential to humans
73
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The lowest or most restrictive occupational limit on a standard is selected
for each chemical from values obtained from ACGIH, NIOSH, and OSHA. When
occupational standards are not available for a given chemical, the Hazardous
Air Pollutant Review Panel will review MAACs proposed by the Department of
Health Services. The DEP will make the final determination of a MAAC.
MAACs are calculated for two averaging periods, an 8-hour and a
30 minute period. The 8-hour MAAC is obtained by dividing the TLV or
occupational standard by the appropriate safety factor (shown above),
depending on group classification of a given chemical. The 30 minute MAAC
is obtained by multiplying the 8-hour MAAC by a maximum allowable excursion
factor of 5. The factor of 5 was chosen because ACGIH sets excursion limits
using a maximum factor of 5. An 8 hour averaging time was selected because
it reflects the averaging time of occupational standards and it conforms to
a working day.
For chemicals which are criteria pollutants, and have a national
ambient air quality standard, the MAAC will be set equal to the NAAQS. For
the criteria pollutants particulates and hydrocarbons, the specific chemical
species of each pollutant will have a MAAC.
The pollutants to be covered in Connecticut DEP’s air toxics program,
along with the MAAC are shown in Table 11 at the end of this chapter. MAAC
may be changed and additional chemicals may be added to the list. The
public or industry may request that the DEP change a MAAC or add a chemical
to the list. The DEP would forward the request by submitting a proposal to
the Department of Health Services (OHS). The OHS would then respond to the
OEP proposal and, together, the agencies would present the request to the
Hazardous Air Pollutant Review Panel. The panel would then accept, reject,
or modify the proposal. A public hearing may be requested by industry or
the public as part of this process.
Emission rate limits are not calculated by the DEP. Instead, sources
must meet maximum allowable concentrations of pollutants in the stack, along
with the 8-hour MAAC (beyond the source property lines). A model was
developed by DEP which calculates allowable stack concentrations based on
each chemical’s MAAC. The model calculates pollutant concentrations at
74
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receptor heights of 20 meters above ground to better identify potential
exposures for elevated receptors. The source must then demonstrate
attainment of the MAAC and the allowable stack concentration.
Risk Assessment/Risk Management
Connecticut DEP does not plan to use risk assessment or risk management
in their air toxics program.
Apolication and Enforcement
The air toxics program in Connecticut will apply to new and existing
sources with special effort aimed at bringing new sources into the program.
The type of pollutant emitted (Groups 1, 2, or 3) also plays a part in
applicability. For Group 1 substances, the program will apply to all
sources. For Group 2 and 3 substances, at first only new sources will be
covered. Existing sources emitting Group 2 and 3 pollutants must meet
program requirements at a later date. If an existing source is thought to
be violating either the 30 minute or 8-hour MAAC for Group 2 or 3
pollutants, that source will be monitored. If the source is in violation of
a MAAC, corrective action would be required.
If a source does not meet stack concentration limits, a compliance
schedule will be worked out with the DEP on a case-by-case basis.
Compliance testing will be performed by DEP staff for stack or vent
emissions from new and existing sources. Testing will be performed for all
chemicals likely to be present, based on process chemistry and physics, and
raw materials used. Existing major sources emitting Group 1 pollutants will
be tested in the beginning of the program. New sources emitting 15 tons per
year VOC will be tested as part of the permitting process.
Sources may apply to the Commissioner for a variance or partial
variance of one or more provisions of the regulations. No variance is
approved unless the applicant provides information to show that discharges
occurring as part of the variance would not constitute a danger to public
75
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health or safety. The applicant may also provide information showing that
compliance would produce practical difficulties or hardship without equal or
greater benefits to the public.
The Connecticut DEP plans to purchase appropriate equipment for ambient
monitoring. At first, monitoring will be conducted primarily to identify
potential problem areas, not to assess compliance. The DEP has taken this
approach because ambient sampling is not likely to detect “worst case”
conditions unless monitoring is performed continuously at many locations
around a source.
Monitoring may be conducted when a violation of a IIAAC is suspected.
If a violation of the 30 minute MAAC is found, DEP will begin a more
extensive monitoring survey to check for compliance with the 8-hour MAAC.
Enforcement of the new program will take two separate approaches,
including source specific ambient monitoring and source inspections.
Inspections for compliance with air toxic standards will be added to the
existing inspection efforts for criteria pollutants.
Currently, DEP requires a source to complete a pre-inspection
questionnaire. Information on potential air toxics will be derived from
completed questionnaires. If a source is determined to be in violation of
the MAAC or stack concentration limits, corrective actions will be required.
These include material substitution, installing controls, curtailment or
shutdown of part or all of the process, or raising the stack and diluting
stack exhaust.
Civil and criminal penalties may be brought about for violation of the
air toxics standards in the same manner as with criteria pollutants.
76
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TABLE 11. MAXIMUM ALLOWABLE AMBIENT CONCENTRATIONS PROPOSED BY
CONNECTICUT DEPARTMENT OF ENVIRONMENTAL PROTECTION
HAZARDOUS SUBSTANCE
LOWEST
THRESHOLD LIMIT VALUE (TLV)
(8—Hour Averaging Time)
ppm m9 1m3
CAS TOXICITY
NUMBER GROUPS
CI NAAC (8-hour)
(vo I ume t r Ic
(ug/m3) units 5 )
ODOR
THRESHOLD
(ppm)
• Group 1: Substances on IARC Lists 1 and 2A. on ACG!H list A1• in NCI Classes i-5. in 19a-329 of the CGS. and on NTP
list A.
Group 2: Substances on IARC List 20 in NCI Classes 5-9. on ACGIH list A?. on NIP list B; also substances identified as
terato ens or mutayens by NIOSH.
Group 3: Other substances.
•‘ na — not available
*** volumetric concentrations are In parts per million per volume (ppmv) unless shown as parts per billion by volume
or as parts per trillion by volume (pptv).
* Connecticut’s “List of 47”
Acetaldehyde
Acetic acid
100
ID
180
25
75-07-0
69-19-7
3
3
3.600
500
0.2
1.00
Acetic anhydride
Acetone
5
246
20
590
108—247
67-64-I
3
3
400
11.800
0.1
5.0
S
Acetone cyanohydrin
Acetonitrile
2-Acetylamino fluorene
Acetylene
Acetylene dichloride
Acetylene tetrabromide
Acetylsalicylic acid
Acrolein
Acrylamide
——-
19.4
---
200
1
——-
0.1
---
—-—
34
—--
790
14
5
0.25
0.3
75-86-5
75-05-8
53—96-3
74-86-2
540-59-0
79-27-6
50-78-2
107-02-8
79-06-1
3
3
1
3
3
3
3
3
3
680
15.800
280
100
5
6
0.39
4.0
0.02
---
2 ppbv
---
100.0
0.21
Acrylic acid
ID
30
79-10-7
3
600
0.01
—.i
Acrylonitr ile
Act inomycin 0
Adiponitr lla
2.0
-—-
4
4.4
—-—
18
107- 13-I
1402-38-6
I
2
3
360
0.08
Adriamycin
-—-
—-—
23214-92-8
2
Af1 to ins
83219-44-7
83219-45-8
1
*Aldicarb
AIdrin
0.15
116—06-3
309-00-2
2
2
1.5
Allyl alcohol
2
5
107-18-6
3
100
0.04
1.40
0.47
Allyl chloride
I
3
10705 1
3
60
Allyl glycidyl ether
5
22
106—92-3
2
220
0.05
AHyl propyl di ulfide
2
12
2179-59-1
3
240
Aluminum metal and oside
---
10
7429-90-5
3
200
Aluminum pyro powders
-—-
5
3
100
Aluminum welding fumes
5
3
100
Carcinogenic substance (Statute 119a - 329)
-------
• Inorganic
• var - variable
TABLE 11. Continued
LOWE ST
THRESHOLD LIMIT VALUE (TLV)
(B-Hour Av.ragthg Time)
ppm mg/m3
ODOR
THRESHOLD
(ppm)
HAZARDOUS SUBSTANCE
CAS TOXICITY
NUMBER OROUP
CT MAAC (8—hour)
(vol ume t r Ic
(ug/ 1n 3 ) units’’’)
Aluminum soluble salts
Aluminum alkyls (not otherwil•
2
3
40
classified)
2
_AminoaflthrOqUifl0fle
l_Amino_2_methYlanthraQuf 0r e
.
92-61I
2
I
-
•
*AminodiPhenY)
2-AminoethaflOl
2-Am lnopyridifle
3-Amino 1,2,4-triazOlS (amitrole)
A,,w onha
2
0.5
—--
25
8
2
———
18
10
141-43-5
509-29-0
61—82—5
7684—417
12125-029
3
3
2
3
3
120
40
360
200
Ammonium chloride-fume
—--
10
7773-06-0
3
200
Anvnonium sulfamate
100
525
123-91-2
3
io.soo
iso-Amyl acetate
lOU
525
628-63-7
3
10.500
1-Amyl acetate
sec-Amyl acetate
tert-Amyl acetate
125
2
650
10
626-38-0
628-63-7
62-533
3
3
3
13.000
—-—
200
Aniline
0.1
0.5
29191-52-4
2
5
‘ — .J
o-An’ssidifle
p-Anisidine
Antimony I compounds (as Sb)
I
(as
Sb)
0.1
---
—--
0.5
0.5
0.5
29191-52-4
1309-64-4
3
3
2
10
10
5
Antimony trio ide. handling
use
---
0.5
1309-64-4
2
5
Antimony trio ide production (as
ANTU ( -Naphthyi thioursa)
---
0.3
86-88-4
3
2
6
•
Aramite
* Arsenic I. compounds (as As)
* Arsenic pento*ide
* Arsenic trio .ide production
(as As)
—--
0.05
001’
---
.05
0.2
7440-38-2
1303—28-2
1327-53-3
1784-42-1
1
I
1
1
Arsine
1332-214
I
•
* Asbestos (see Table 4 )
Asphalt (petroleum) fumes
Atraz lne
5
5
---
8052-42-4
1912-24-9
2465-27-2
3
3
1
100
200
* Auramine
---
446-86-6
I
Azathioprine
0.2
86-50-0
3
4
Azinphos-methY l
Barium (soluble compounds), as Ba
Baygon (propo*ur)
0.5
0.5
0.1
7440-39-3
114-26-1
55-38-9
3
3
3
10
10
2
Beyte
Benomyl
10
---
17804-35-2
98-87-3
3
3
200
Benzal chloride
46.8
1 .00
0.04
0.01
0.5
2.0
2.0
2.5
0.04
1.0 ppbv
2.0 ppbv
0.25 ppbv
0.05
0. 25
1.0
* ConneCtiCUt S uList of 4711
-------
Connecticut’s “List of 47”
TABLE 11. Continued
LOWE ST
THRESHOLD LIMIT VALUE (TLV)
(0-Hour Avera9in9 Time)
ppm m /m3
THRESHOLD
CAS
TOXICITY
(volumetric
HAZARDOUS SUBSTANCE
NUMBER
&ROUP
(u91m3)
units’ 0 5 )
(ppm)
•
k
Benz(a)anthraceoe
Benzene
10
30
71—43-2
2
I
150
0.05
46.8
•
Benzanethi ol
*Benzidine
--—
---
-—-
- ---
92-87-5
3
1
Benzo(b)fluoranthefle
aenzo(r ,s.t) pantaphene
p-Benzoquinorie
Benzotrich ioride
0.1
0.4
-——
106-51-4
98—07-7
2
3
2
8
2.0 ppbv
Benzoyl chloride
--—
---
100
0.02
Benzoyl peroxide
5
94-36-0
2
---
-
Benz(a)pyrena
(see polycycliC aromatic hydrocarbons)
Benzyl chloride
1
-—-
5
50—32—8
100-44-7
3
100
.010
0.02
--—
0.047
Beryllium
—-—
0.002
7440-4)-?
“
Beryllium oxide
Beryllium sulfate
———
-——
1304-56-9
13510-49—1
I
—-—
30
4.0
.06—.29
Biphenyl
0.2
1.5
92-52-4
200
ppbv
Bismuth telluride
10
1304-82-1
3
. .,
Bismuth telluride, Se-doped
Bleomycins
—-—
-—
5
3
3
Dorates. tetra, sodium salts - anhydrous
— --
1
1303-96-4
3
- decahydrate
—-—
5
1303—96-4
3
20
- pentahydrate
Boron oxide
---
—-—
I
10
1303-96-4
1303-86-2
3
200
———
Boron tribromide
1
10
10294-33-4
3
200
Boron trifluoride
I
3
7637—07-2
3
60
0.02
Bromacil
I
ID
3 14-409
3
200
0.02
Brominated biphenyls
2
2.0
0.047
Bromine
0.1
0.7
7726-95-6
3
14
ppbv
2.0
Bromine pentafluoride
0.1
0.7
7789-30-2
ppbv
4.0
Bromoch loromethane/chlOrObrOmOmethafle
200
1,050
74975
21,000
Bromoform
0.5
5
15-25-2
3
100
Butadiane (1,3butadiene)
1.000
2.200
106-99-0
3
44,000
20.0
16.0
Butane
800
1,900
10691 8
3
38,000
30
0.01
1-Butanethiol
0.5
1.5
109—79-5
3
0.01
2-Butaneth lol
0.5
1.5
5 13-53-I
3
4.0
2-Butanone
200
590
78-933
3
11 800
0.5
2-ButoxyethanO l
25
120
111-76-2
3
2,400
3.0
n-butyl acetate
150
710
123-86-4
3
14,200
sec-Butyl acetate
200
950
105-46-4
3
19.000
4.0
4.0
tert—Dutyl acetate
Duty) acrylate
200
10
950
55
540-88-5
140-32—2
3
3
19,000
1,100
0.2
• Carcinogenic substance (Statute 19a — 329
-------
TABLE 11.
Continued
LOWEST
THRESHOLD LIMIT VALUE (TLV)
(8-Hour Averagin9 Time)
ppm m /m3
CAS TO?(!CITV
NUMBER GROUPS
•* The national ambient air quality standards are ID mg/m3, B-hour average and 40
will take precedence. The value shown is entered for comparative purposes only.
Connecticut’s “List of 47”
• Carcinogenic substance (Statute 19a - 329)
mg/m3, i-hour avera9e. The NAAQS
CT MAAC
(8-hour)
ODOR
(volumetric
THRESHOLD
HAZARDOUS SUBSTANCE
(ug/m3)
unit. *’ *)
(ppm)
n -Butyl alcohol
50
150
71-36-3
3
3 .000
1.0
sec-Butyl alcohol
tert-Butyl alcohol
100
100
305
300
78-92-2
75-65—1
3
3
6,100
6.000
2.0
2.0
Butylamine
terl-8utyl chromate (as Cr03)
n-Butyl glycidyl ether (BCE)
n-Buty) lactate
5
—-—
25
5
15
0.1
135
25
109-73-9
1189-85- i
2426-08-6
138-22-7
3
3
2
3
300
2
1,350
500
0.1
——-
0.25
0.1
Butyl mercaptan
0.5
1.5
109-79-5
3
30
0.01
.001 to
.048
o-sec Butylphenol
5
30
89-72-5
3
600
0.1
p-tert- Buty lto luene
10
60
98-5 1-1
3
1,200
0.2
n-butyronitr lle
8
22
3
440
0.16
Cadmium
---
—
7440-43-9
2
---
$Cadtnium dust & salts (as Cd)
‘ Cadmium oxide fume (as Cd)
---
---
0.05
0.05
1440-43-9
1306-19-0
2
2
0.5
0.5
Cadmium oxide production
---
0.05
1306-19-0
2
0.5
‘
*Cadmium sulfate
Calcium arsenate (as As)
Calcium cyanamide
---
---
---
---
---
0.5
10124-36-4
156-62-1
2
2
3
-—-
---
10
Calcium hydroxide
---
5
1305-62-0
3
100
---
Calcium oxide
---
2
1305-78-8
3
40
---
Camphor, synthetic
2
12
76-22-2
3
240
0.04
Caprolactam dust
---
I
105-60-2
3
20
---
Caprolactam vapor
5
20
105-60-2
3
400
0.01
Captafol (difolatan)
---
0.1
2425-06-1
3
2
---
Captan
---
5
*13-06-2
3
100
---
Carbaryl (Sevin)
—--
5
63-25-2
3
100
---
Carbofuran (Furadan)
---
0.)
1563-66-2
3
2
--
Carbon black
---
3.5*
1333-86-4
3
70
---
Carbon disulfide
1
3
75-15-0
3
60
0.02
0.21
Carbon monoxide
36
40
630-08-0
3
800 *s
0.72
*Carbon tetrabromide
Carbon tetrachloride
0.1
5
1.4
30
558134
50-23-5
3
2
28
300
2.0 ppbv
0.05
21.4-100
Carbonyl chloride (Phosgene)
0,1
0.4
75-44-5
3
8
2.0 ppbv
Carbonyl fluoride
2
5
353504
3
100
0.04
-------
TABLE 11.
Continued
HAZARDOUS SUØSTANCE
LOWEST
THRESHOLD LIMIT VALUE (TLv)
(8—Hour Averaging Time)
ppm mg/m3
CAS TOXICITy
l4IJMD€R GROUP’
CT MAAC (8-hour)
I (volumetric
(ug/m3) un Its’’’)
ODOR
THRESHOLD
(ppm)
Connecticut’s “List of 47’
.0005
I
0.
1
0.
1
.003
0.5
0.5
0.5
3
0.3
0.4
Catechol
5
20
120-80-9
3
Cesium hydroxide
--—
2
21351—79-1
3
Chlorambu il
---
305-03-3
1
Ch loramphenicol
56—75—7
2
2-Ch loraniline
106-47-8
3
Ch lordan ,
12789-03-6
1
Chlorinated camphene
8001-35—2
I
Chlorinated diphenyl o*ide
55720—99-5
3
Chlorine
7782-50—5
3
Chlorine dioxide
10049—04-4
3
Chlorine trifluoride
7790-91-2
3
Chiormadinone acetate
3
Chlornaphthazine.
---
--—
494-03-I
Ch loroacetaldehyde
1
3
107-20-0
- Chioroacatophenone (Phenacyl chloride)
0.05
0.3
532-27-4
Chioroacetyl chloride
o.os
0.2
79-04-0
Chlorobenzene
75
350
108-90-7
,-.
Chlorobenzilate
o-Ch)orobenzylidene malonitrile
-—-
0.05
—-—
0.4
510—15-4
2698-41-1
Chlorobromomethane/bromoch)oromethane
200
1,050
74-79-5
2-Chloro-1,3-butadjene
10
45
126-99-8
Chlorocijfluoromethane
1.000
3,500
75-45-6
Chlorocliphenyl (42% Chlorine)
---
1
53449-21-9
Chlorodiphenyl (54% Chlorine)
---
0.5
53449-21-9
l-Chloro.2 ,3-epoxy-propane
2
10
106-89-8
2-Ch loroetrianol
1
3
107—07-3
bis-Chloroethyl nitrosourea (8CNU)
---
---
108-60-1
l-(2 -Chloroathyl)—3-cycloh.xy l-1-nitro —
sourea (CCNU)
400
40
• 06
2.5
2.5
10
60
6
8
60
6
4
7,000
8
21 • 000
900
70 • 000
20
10
200
60
0.1
na
001 ppbv
---0
0.02
2.0 ppbv
2.0 ppbv
0.02
1.0 ppbv
1.0 ppbv
1.5
1.0 ppbv
4.0
0.2
20.0
0.04
0.02
0.314
0.314
3.5
0.016
3
3
3
3
3
3
3
3
3
3
3
2
• Carcinogenic substance (Statute 19a - 329)
-------
TABLE 11. Continued
HAZARDOUS SUBSTANCE
LOWEST
THRESHOLD LIMIT VALUE (TLV)
(8-Hour Averaginy Time)
ppm mg/m3
CAS TOXICITY
NUMBER GROUP•
CT MAAC (8—hour)
(volumetric
(ug/m3) unitsIe*)
ODOR
THRESHOLD
(ppm)
Ch I orof orm
Chioromadinone acetate
• bls-Chiorom•thyl
Chioromethyl methyl •ther
Chioropentaf luoroethane
1 -Chloro- I-nit ro-propana
Chioropicrin
- Ch)oroprene
o-Ch lorostyrene
o-Chl orotoluene
2-Chioro-6-tr ich loromethyl
Chioropyrifos (Duraban)
Chro ,n%c acid and chroinatas (as Cr)
Chromita or, processing (chromat. ). as Cr
Chromium. metal
Chromium (II) compounds, as Cr
Chromium (I I I) Compounds, as Cr
Chromium (Vt) compounds, as Cr
Chromyl chloride
Chrysene
Cisplat in
Clofibrate
Clomipren,
Cloptdo I
Coal tar pitch volatiles
Coal tar products (see polycyclic
aromatic hydrocarbons)
Cobalt metal, dust I . fume (as Co)
Cobalt carbonyl , as Co
Cobalt hydrocarbonyl , as Co
Coke oven emissions
Copper - dusts & mists (as Cu)
Copper fume
Cotton dust, raw
Cray herbicide
p-Cres$d lne
0.025 0.15 14977-6 1-8
218-01-9
15663-27-1
637-07- I
911-45-5
2973-90-6
30
0.2
7440-50-8 3
7440-50-8 3
3
556-22-9 3
2
• Carcinogenic Cr(VI): .001, nonc.rcir,Oger iC C (VI): .025
••• Carcinogenic Cr(V1) .005;
Ie*. Proposed for revIsion
noncarciflogeniC Cr(VI) 0.5
4 Connecticut’s “List of 47”
10
0.00)
3.000
2
0.1
10
50
50
50 67-66-3
3
.003 542-88—I
107-30—2
6,320 78-16-3 3
30 600-25-9 3
0.7 76-06-2 3
45 126-99-3 3
285 1331-28-8 3
250 95-49-8 3
10, 3
0.2 2923—88-2 3
0.06
0.05 1
0.5 7440—47-3 I
0.5 3
0.5 3
• . 5
0.05
5.0 pptv
20.0
0.04
2.0 ppbv
0.2
1.0
1.0
0.5 ppbv
250
0.015
126,400
200
14
900
5,700
5.000
200
4
0 . 25
0.25
2.5
l O
10
. 5.
3
200
2
2
2
20
2
4
300
3
2
2
3
3
3
2
3
a
3
7440-48-4
00000-00-0
36842-03-B
0. 15*5*
0.1
0.%
0.1
0.2
‘S
• Carcinogenic substance (Statute 19a - 329)
-------
TABLE 11. Continued
LOWEST
THRESHOLD LIMIT VALUE (TLV) CT MAAC (8-hour) ODOR
(B-Hour Averayin9 Time) CAS TOXiCITY (volumetric THRESHOLD
HAZARDOUS SUBSTANCE ppm mg/m3 NUMBER GROUP’ (u9/m3) units”) (ppm)
Cresol 2.4 10 1319—77-3 3 200 0.048 0.001
Crotona ldehyde 2 6 123-73-9 3 120 0.04 0.2
Crutomate - 5 229-86-5 3 100
Cumsns 50 245 98-82-8 3 4,900 1.0
Cupferron 2
Cyanamide 2 420-04-2 3 40
Cyanide, as CN 5 51-50-8 3 100
143- 33-9
Cyanogen I C 20 460-19-5 3 400 0.2
Cyanogen chlorIde 0.3 0.8 506-77-4 3 12 6.0 ppbv
Cycasin 2
Cyclamates -—— --- 100-88-9 3
Cyclohe*ane 2300 1,050 110-82-7 3 21,000 46.0
Cyclohe*aflathio l 1569-69-3 3
CycloheManol 50 200 108-93-0 3 4.000 1.0
Cyclohexanone 25 100 108-94I 3 2.000 0.5
Cyclohexene 300 1,015 1I0-838 3 20.300 6.0
Cyclohexylamine 10 40 106-91-8 3 800 0.2
CyClonite 1.5 121-82-4 3 30
Cyclohexylmethane 4,4-difeocyanate -—- 0.55 3 1.1 1.5
Cyctopentadlon. 75 200 542-92-7 3 4.000 6.0
Cyc iopentane 300 850 287-92-3 3 17.000
Cyctophosphainide --- --- 50-18-0 I
Cyhexatin 13121—70-5 3
Dacarbazene -- 4342-03-4 2
Dalapon 1 6 75—99-0 3 120 0.02
Dapsone --- --- 80-08-0 3
Decaborane 0.05 0.3 17102-41-9 3 6 1.0 ppbv
Decanethiol —-— -—- 143-10—2 3
Dejneton 0.01 0.1 8065-48-3 3 2 0.2 ppbv
DOT (Dtchlorodiphenyl—tr lchloroethane) -—— 0.5 50-29-3 2 5
Diacetone alcohol 50 240 123-42-2 3 4,800 1.0
2 4—DiamInoanisoIe sulfate 2
2 ,4-Diam lnotoluene 2
1 ,2—Diaminoethane tO 25 107-15-3 3 500 0.2
o-Disn lsidine --- -—- 119-90-4 2
Diazinon —-— 0.1 333-41-5 3 2
Dlazomethane 0.2 0.4 334-88-3 3 8 4.0 ppbv
Dlbenz(a,h) acridine 2
Dibenz(a,j) acridlne 2
Oibenz(a,h) anthracena 2
II • II
4 Connecticut s List of 47
• Carcinogenic substance (Statute 19a - 329)
-------
TABLE 1].. Continued
LOWE ST
THRESHOLD LIMIT VALU (rLv) CT MAAC (8-pour) ODOR
(B-Hour Avsrs9lng Tim.) CAS TOXICITY (volumetric THRESHOLD
HAZARDOUS SUBSTANCE PP ” mg/m3 NUMBER GROUP’ (uglm3) units”) (ppm)
7H—Dlbenzo(c .g) cerbazo)• 2
Oib.nzo(a,h) pyrene 2
Dlbenzo(ai) pyr.ni 2
D lborane 0.1 0.1 19287-45-7 3 2 2.0 ppbv
D lbro.n --- 3 300-76-5 3 0.04
D lbromochtoropropan. --- .01 96-12-8 I 0.02
* 1,2 Dlbromosthans 20 155 10693-4 1 775 0.1 25
2-n-Dibuty laminoethano l 2 14 107-81-8 3 280 0.04
Dibutyl phosphats I 5 3 100 0.02
D4buty l phthalate --- 5 84-74-2 3 50
Dich loracetylene 0.1 0.4 7572-29-4 3 8 2.0 ppbv
o-D lchlorobenzen. 50 300 95-50-I 3 6.000 1.0
* p-Dlch)orobsnzen. 75 450 106-46-7 2 4.500 0.75
•3.3 -D Ich)orob.nz ld$n. --- —-- 9 1-94-I
D1ch1orodifluorometh .n 1,000 4.950 75-71-8 3 99,000 20.0
1.3-Dichloro-5 .5-dlm.thyl hydantotn --- 0.2 118-52-5 3 4
I , l-Dtchloro.thane 100 400 75-34-3 3 8.000 2.0
12-Dichloroethane 10 40 107-06-2 200 0.05
Otch loro.thy len. 200 790 540-59-0 3 15.800 4.0
Dichioroethyl ether 5 30 111-44-4 3 600 0.1
Dich loromethane 100 350 75-09-2 3 7.000 2.0
Dich loromonof luoroineth ane 10 40 75-43-4 3 800 0.2
1,I-Oich loro-1-nitro.tP ,ans 2 10 594-72—9 3 200 0.04
24-0 (2.4-Dlchloroph .rioxyacetlc acid) --- 10 74-75-9 2 100
Dfchioropropene I 5 542-75-6 3 lOG 0.02
Dichioropropionic acId 1 6 7599 0 3 120 0.02
Dich lorotetrafluorosthane 1.000 7.000 76-14-2 3 140.000 20.0
Dichiorvos (ODVP) 0.1 1 62-73-7 3 20 2.0 ppbv
Dicrotophos (Bidrin) -—— 0.25 141—66-2 3 5
DiCyclohs*yl methane
4.4di isocyanate --- .055 3 1.1
flicyclopentad isne 5 30 77-73-6 3 600 0.1
Dicyclopentadienyt iton -- 10 102-54-5 3 200
Di Idrin 0.25 60-Si-I 3 5
Dienestrol -- — ——- 84-17-3 2
D$epo ybutan . 2
DI -2,3 —epoxypropyl ether -—— 2
Dl thanol amine 3 15 111-42-2 3 300 0.06
Diethy) ether 400 1,200 60-29-7 3 24,000 8.0
4 Connecticut’s “List of 47
• Carcinogenic substance (Statute 19a - 329)
-------
TABLE 11. Continued
LOWEST
THRESHOLD LIMIT VALUE (TLV)
(8-Hour Averaging Time)
ppm mg/m3
CAS TOXICITY
NUMBER GROUP’
CT MAAC (B-hour)
(volumetric
(ug/m3) units”)
4 Connecticut’s “List of 47”
HAZARDOUS SUBSTANCE
O i(2—.thy lheMyl)phthalats
2
Olethyl katone
200
705
98—22-0
3
14,100
4.0
Diethyl phthalate
—--
5
84-66-2
3
100
---
Diethylamine
10
30
109-89-7
3
600
0.2
Diethylaminoethanol
10
50
100-31-8
3
1.000
0.2
Diethyt høMyI phthalate
3
Diethylane triamine
1
4
111—40-0
3
80
0.02
D l.thy lstilboestriOl
——
——
39011—86-4
1
Diethyl sulfate
-—-
—-—
64-67—5
Difluorod lbromomethane
100
860
75-61-6
3
17 .200
2.0
Diglycidal ether (DGE)
0.1
0.5
2238-07-5
3
10
2.0 ppbv
Diisobutyl ketona
23
140
108-83-8
3
2.800
0.46
Dilsocyanates. not listed
.005
——
3
——-
0.1 ppb
Di lsopropy lam ino
5
20
108-18-9
3
400
0.1
Dimethisterofle
—--
79-64-1
3
3-3’-Dimetho*ybenz idifl e
2
Dimetho tymethafle
Dimathyl acetamide
1,000
10
3,100
35
109-87-5
127—19-5
3
3
31.000
700
20.0
0.2
Dimathylamine
10
18
124-40-3
3
50
0.2
•
4—Dimethylaminoazobenzene
4-D lmethy laminobenzene
2
10
13OO-738
2
1
50
0.01
Dimethylaniline
5
25
121-697
3
500
0.1
3 .3 ’-D imethy lbenzidine
2
Dimethyl carbamyl chloride
-—-
——
79-44-7
2
——-
na
Dimathylformamide
10
30
68-12-2
3
600
0.2
1,1-Dimethy lhydrazine
3•3 ’-Dimethy1o ybenzidine
0.5
1
57-14-7
119—90-4
2
2
10
5.0 pPbv
‘A
D$methylphthalate
Dimethyl sulfate
Dlnitolinide
-—-
0.1
---
5
0.5
5
131—11-3
77-78-1
148-01-6
3
I
3
100
2.5
100
-—-
0.5 ppbv
Dinitrobenzene
0.15
1
528-29-0
3
20
3 ppbv
D lnitro—o-cresol
0.2
53452 1
3
4
3,5-Oinltro-o-toluamide (Dinitolmide)
---
5
148-01-6
3
100
-—-
Dinitrotoluene
——-
1.5
121—14-2
2
15
——-
Dlo*ane, Tech. Grade
25
90
123-91-1
1
450
0.125
Dioxathion (Oelnav)
—--
0.2
78-34—2
3
4
---
2,4-0 (2 ,4-Dichlorophenoxyacetlc acid)
Diphonyl
Di thenylamir’e
-—-
---
——-
10
1
10
74759
92-52-4
122-39-4
3
3
3
200
20
200
- ‘
*
Diphenylmethane diisocyanate
Diphenylphthalate
-—-
.05
10;-68-8
3
3
I
Dipropylene glycol methyl ether
100
600
34590—94-8
3
12.000
2.0
ODOR
THRE SHOLD
(ppm)
0.047
46.80
047
100
0.00 I
• Carcinogenic substance (Statute 19a - 329
-------
Continued
TABLE 11.
LOWEST
THRESHOLD LIMIT VALUE (TLV)
(8-Hour Averaging Tim.)
ppm mgim3
CAS TOXICITY
NUMBER GROUPS
CT MAAC (8-hour)
(“a I ume t r $ c
(ug/m3) un ita •’)
HAZARDOUS SUBSTANCE
Dipropyl keton.
123- 193
3
Oiquat
0.5
65-00-7
3
10
Direct a ack 38
---
1937—37—7
2
Direct Blue 6
26 10-05- I
2
Direct 8ro n 95
---
10300-74-0
2
0$- s .c octyl phthalata
5
117-81—7
3
100
-—-—
DIsulfiram
2
97-77--s
3
40
---
Disulfoton
0.1
296-04-4
3
2
---
Disyston
-——
0.1
298—04-4
3
2
—-—
2,6-Ditert butyl-p-cresol
--—
10
126-37-0
3
200
—-—
Diuron
——-
tO
330-54-1
3
200
---
Dtvtnyl benzens
10
50
108-57-6
3
1.000
0.2
Dod.can.thi o l
--—
-—-
3
.
Dyfonate
---
0.1
944-22-9
3
2
Endosulfan
—-—
0.1
115-29-7
3
2
Eridr$n
---
0. )
72208
3
2
Epichiorhydrin
EPN
0.
---
2
0.5
106-89-8
2104-64-5
2
3
20
tO
Estrogens
1
Ethane
---
---
74-84-0
3
---
Ethanol
1.000
1.900
64 175
3
38,000
Ethanolamine
3
8
141-43-5
3
160
0.06
Ethlny lestr$ci lol
——-
---
57-63—6
2
Ethiov,
---
0.4
563-12-2
3
8
---
2—Etho yethanol
5
9
110-80-5
3
180
0.1
2-Etho*yethyl acetate
5
27
111-15-9
3
540
0.1
Ethyl acetate
400
1.400
%4 1-186
3
28 ,000
8.0
Ethyl acrylate
5
20
140-88—5
3
4o 0
0.1
Ethy lam lne
10
18
7504-7
3
360
0.2
Ethyl sec-amyl ketone
25
130
41—85-5
3
2,600
0.6
Ethyl benzene
tOO
435
100-41—4
3
8.700
2.0
Ethyl bromide
200
890
74-96-4
3
17,800
4.0
Ethytbutyl ketone
50
230
106-35-4
3
4.600
1.0
Ethyl chloride
1,000
2,600
75-00-3
3
52,000
20.0
Ethyl ether
400
1.200
60-29-7
3
24,000
8.0
Ethyl formate
100
300
109-94-4
3
6.000
2.0
Ethyl mercaptan
0.5
1
75081
3
20
0.01
Ethyl silicate
10
65
78-10-4
3
1,700
0.2
6.0 ppbv
20.0
ODOR
THRESHOLD
(ppm)
10.00
0.00047
0.00 1
* Connecticut’s “List of 47”
• Carcinogenic substance (Statute 19a - 32 )
-------
TABLE 11. Continued
HAZARDOUS SUBSTANCE
LOWEST
THRESHOLD LIMIT VALUE (TLV)
(B-Hour Avøraging Time)
ppm mg/m3
CAS TOXICITY
NUMBER GROUP’
CT MAAC (8-hour)
(volumetric
(ug/ni3) unite’’’)
ODOR
THRESHOLD
(ppm)
• Proposed for revision
* Connecticut’s “List of 47”
Ethylene
———
———
74-85—I
3
*Ethylenediam e
Ethylene chlorohydrin
*Ethylsne dibromide
10
1
20
25
3
155
107-15-9
107-07-3
106—93-4
3
3
1
500
60
715
0.2
0.02
0.)
Ethylene dichlorida
Ethylene glycol (vapor)
1
50
4
125
107-06-2
1072 1i
3
3
80
2.500
0.02
1.0
Ethylene glycol dinitrate
0.05’
0.3’
628-96-6
3
6
1.0
ppbv
Ethylene glycol monomethyl ether acetate
25
120
110—49-6
3
2.400
0.5
Ethylene gIYCOI. particulate
* Ethylene oxide
1
10’
2
107-21-1
75-21-8
3
2
200
20
0.0)
Ethylene thiourea
*Ethylenim ine
Ethylidene norbornene
-
0.5
5
—-—
1
25
96-45-7
151-56-4
16219-75-3
2
3
3
20
500
0.01
0.1
n-EthylmOrphOlifle
5
23
100-74-3
3
460
0.1
Ethynodiol acetate
---
—--
3
Fensulfothion (Dasanit)
———
0.1
115-90-2
3
2
fenthion
“
0.2
55-38-9
3
4
Ferbam
-——
10
14484-64-I
3
200
Ferrovanadium dust
Fibrous glass (see Table 2A)
I
12604-58-9
3
20
Fluorides (as F)
---
2.5
3
50
Fluorine
0.1
0.2
7782-41-1
3
4
2.0
ppbv
Fluorocarbon polymer decomposition
products
Fluorotr ichl orOmethane
1,000
5,600
75-69-4
3
1)2,000
20.0
5—FluorouraCll
———
———
2
Fonofos
---
0.1
944229
3
2
Formaldehyde
1
1.2
50-00-0
2
12
0.01
Formamide
20
30
75-12-7
3
600
0.4
Formic acid
5
9
64-18-6
3
180
0.1
Furfural
2
8
98-01-1
3
160
0.04
Furfuryl alcohol
10
40
96-00-0
3
800
0.2
Gasoline
300
900
8006-61-9
3
18,000
6.0
Germanium tetrahydride
0.2
0.6
7782-65-2
3
12
4.0
ppbv
Glutaraldehyde, activated or unactivated
0.2
0.7
Ill—3D-B
3
14
4.0
ppbv
Glycerin mist
-—-
—--
56-81—5
3
—--
Glycidol
25
75
556-52-5
3
1,500
0.5
Glyconitrile
-——
3
Guthion (AzinphosMethyl)
-—-
o.z
86-50-0
3
4
Hafnium
---
0.5
7440-58-6
3
10
Hematite
3
10- I .0
I Carcinogenic substance (Statute iq -
-------
Continued
TABLE ii.
LOWEST
THRESHOLD LIMiT VALUE (TLV)
(B-Hour Avenging Tim.)
ppm ing/m3
CAS TOXICITY
NUMBER GROUP’
CT MAAC (8-hcn.,r)
(voIuni trIc
(uglm3) units”)
ODOR
THRESHOLD
(ppm)
• Proposed I or revision
Connecticut’s ‘ List of 47
HAZARDOUS SUBSTANCE
1.000
HsptacMor
Hapten. (n-Heptane)
Heptanethiol
—--
81.5
-
0.5
350
- -
76-44-8
142-82—5
1639-09-4
I
3
3
2.5
He*.cPi lorobenz .ne
2
He *achlorobutadiene
0.02
0.24
76-68-3
2
2.4
HeMach lorocyclohexane
- —
———
3)9—85—7
3
He*achlorocyclopentadtena
0.0)
O.
77-47-4
3
2
He ach )oroethane
1
10
67-72- I
I
50
H. *ach)oronaphtha lene
—--
0.2
1335-87-1
3
4
)4.*id.csnetP lo I
3
HuMaf luoroacetone
0.1
0.7
684-16-2
3
14
He amethyIBn diisocyanate
---
.035
3
0.7
Hexamethylphosphoramide
---
---
680-31-9
2
He*ane (n-hekane)
50
180
110-54-3
3
HeMane, other isomers
500
1.800
1)0-54-3
3
He ansth lot
---
---
111-31-9
3
2-He*anone
5
20
25683-00-5
3
c
Hesone
sec-Heiyl acetate
50
50
205
300
108-10-1
142-92-7
3
3
Hosylene glyco)
25
125
107-41-5
3
Hydra)azIne
---
---
86544
3
*Hydra $ne
Hydrazine sulfide
3. 1
0.1
3020 )2
2
2
Hydrazinobenzene
3
Hydnazobanaena
2
HydrachIon¾d o-an$sidina
3
Hydrogenated terphenyls
0.5
5
92-94-4
3
Hydrogen bromide
3,’
to..
10035-10-S
3
Hydrogen chloride
5
1
7647-01-0
3
Hydrogen cyanide
10
I I
74—90-8
3
Hydrogen fluoride
3.*
2.5*
7664—39-3
3
Hydrogen pero*tde
I
1.4
7722-84-)
3
Hydrogen 5e )entde
0.05
0.2
7783-07-5
3
Hydrogen sulfIde
10
14
7783-06-4
3
Hydroquinone
17*-Hydroityprogesterone caproate
—--
---
3
---
2-Hydroitypropyl acrylate
0.5
3
999-61-1
3
60
1.75
0.2 ppbv
0.2 ppbv
5.0 ppbv
2.0 ppbv
1.0
10.0
0.)
1.0
1.0
0.5
1.0 ppbv
0.01
0.06
0.10
0.2
0.06
0.02
1.0 ppbv
0.2
na
0.01
3 . 600
36. 000
400
4.100
5,000
2 • 500
100
200
140
200
50
28
4
280
10
.00047
• Carcinogenic substance (Statute 19a - 329)
-------
TABLE 11.
Conti nued
L0WL ST
THRESHOLD LIMIT VALUE (TLV)
(8-Hour AvQra9in9 Time)
ppm mg/m3
CAS TOXICITY
NUMBER GROUP’
CT MAAC (8-hour)
o I ume t r 4 c
(ug/m3) units’’’)
• The EPA national ambient dir quality standard, 3-month avera9e. is 1.5 u9/m3.
‘ Connecticut’s “List of 47”
45 95-13-6
10
0.1
0.6
ODOR
THRE SHOLO
(ppm)
HAZARDOUS SUBSTANCE
I ndene
Indeoo(1 ,2,3-cd) pyrena
Indium I Compounds (as In)
Iodine
Lodoform
Iron dextran complex
Iron oxid• fume
Iron pentacarbOnyl
Iron salts, soluble (as Fe)
Isoamyl acetate
Isoamyl alcohol
Isobutyl acetate
Isobutyl alcohol
isobut yron$tr he
IsooCtyl alcohol
Isonicotinic acid hydrazide
I sophorone
Isophorone dilsocyanate
‘.0 Isopropo xyethaflOl
Isopropyl acetate
Isopropyl alcohol
n-Isopropyl aniline
I sopropyl amine
Isopropyl ether
Isopropyl glycidyl ether (IGE)
Isopropyl oils
Kepone
Kerosene
Ketene
Lead. inorg. . fumes & dusts (as Pb)
Lead acetate
* Lead arsenate (as Pb)
Lead chromate (as Cr)
Lead phosphate
0.1
1
1440-74-6
7553-56-2
75—47-8
5
0.08
1309—37-1
13463-40-6
--
100
100
150
50
B
50
———
5
25
250
400
2
5
250
50
525
360
700
150
22
270
-——
25
.045
105
950
980
I D
12
1.050
240
123-92—2
123-51—3
110-19-0
78-83-)
26952-21-6
55-22- I
78-59-1
4098-71-9
109 -59- I
108-21-4
67-63-0
643-28—1
75-31-0
100-20-3
4016-14-2
3
2
3
3
3
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
2
3
.01
900
2
20
200
100
1.6
20
10. 500
7 • 200
14,000
3 • 000
440
5 • 400
460
0.9
2. 100
19.000
19. 600
200
240
21.000
2,400
2.000
18
3’
3
0.5
0.2
2.0 ppbv
12.0 ppbv
2.0
2.0
3.0
1.0
0.16
1.0
0.)
0.2 ppbv
0.5
5.0
8.0
0.04
0.1
5.0
0.5
0.01
0.5
I00
0.9
0.15
143-50-0
3
463 514 3
1439—92-1 3
2
3
2
2
0.15 10102-48-4
0.05 18454- 12-I
• Carcinogenic substance (Statute 19a - 329)
-------
4 Connecticut t s “List of 47”
TABLE 11. Continued
LOWEST
THRESHOLD LIMIT VALUE (TLV)
(8—Hour Averaging Time)
ppm mg/m3
HAZARDOUS SUBSTANCE
CAS TOXICITY
NUMBER GROUPS (ug/m3)
CT MAAC (8-hour)
5
36,000
0.5
Lindane
---
0.5
58-89-9
2
Liquified petroleum gas
Lithium hydride
iooo
---
I.80 0
0.025
7580-67-8
3
3
LynoestrenOl
---
---
52-76-6
3
Magenta
3
Magnesita
—--
---
546-90-0
3
—--
Magnesium oxide fume
—--
o
1309-48-8
3
200
Malathion
-——
10
121-75-5
3
200
Maleic anhydride
0.25
1
108-31-6
3
20
Malonitrile
3
8
3
160
Manganese dust I Compounds (as Mn)
--—
5
7489-96--S
3
$00
Manganese cyciopentadieflyl tricarbonyl
(as Mn)
—-—
0.1
12079-651
3
2
Manganese fume (as Mn)
———
1
7439-96-5
3
20
Manganese tetroxide
—-—
3
20
Medro ypro9est.rOne acetate
Megestrol acetate
——
-—-
3
Muiphalan
---
---
148-82-3
1
6-Mercaptopurine
---
---
50-44-2
3
Mercury (alky Compounds) (as Hg)
0.001
0.01
3
2
‘-.0
Mercury, (all forms e*cept alkyl) (as
vapor
Hg)
0.05
7439-97-6
3
aryl and Inorganic compounds
0.1
3
2
Mesityl oiiide
10
40
141-79-7
3
800
Mastranol
—--
——-
72—33—3
2
Nethacrylic acid
20
70
79-41-4
3
1.400
Methanethiol
0.5
1
74-93-1
3
20
Methanol
200
260
67-56-1
3
5,200
Met.r omyl
---
2.5
16752775
3
50
Methotrexate
---
---
59-05-2
3
Metho*ychl or
---
$0
12435
3
100
2-Methosyethanol
5
16
109-86-4
3
320
2-Methoxyethyl acetate
5
24
110-49-6
3
480
4—Methoxyphenol
5
150-76-5
3
100
Methyl acetate
200
610
79-20—9
3
12 .200
Methyl acetylene
10000
1,650
74997
3
33,000
ODOR
THRESHOLD
(ppm)
100.00
(vol ume t r I C
un iteses)
20
5.0 ppbv
.06
0.02 ppbv
0.2
0.4
0.0I
4.0
0.)
0.1
4.0
20.0
• Carcinogenic substance (Statute 19a - 329)
-------
TABLE 11.
Continued
• Proposed for revision
Connecticut s “List of 47’
LOWEST
THRESHOLD LIMIT VALUE (TLV)
(8-Hour Avera9iflg Time)
ppm m9/m3
ODOR
THRESHOLD
(ppm)
CT MAAC (8-hour)
CAS
TOXICITY
(volumitric
HAZARDOUS SUBSTANCE
NUMBER
GROUP’
(ug/m3)
units”)
Methyl acetylene-propad1er e mi*ture
Methyl acrylate
1.000
10
1.800
35
96-33-3
3
3
36,000
700
20.0
0 .2
0.02
Methytacrylonitrile
I
3
126—98-7
3
20.0
Methytal
Methylasnine
1.000
10
3.100
12
109—81-5
74—89-5
3
3
62.000
240
0.2
.021
Methyl n-amyl ketone
n-Methyl aniline
50
0.5
235
2
110-43-0
100-61-8
3
3
4,700
40
0.01
0.3
Methyl bromide
Methyl butyl ketone
15
5
60
20
74-83-9
591-78-6
3
3
1,200
400
0.1
0.5
20.47
Methyl cellosolve
Methyl cellosolve acetate
Methyl chloride
Methyl chloroform
25
25
50
350
80
120
105
1.900
109—86-4
74-87-3
11-55-6
3
3
3
3
1,600
2.400
2.100
38.000
0.5
1.0
7.0
10.00
Methyl 2-cyanoacrylate
2
8
137-05-3
3
160
Methylcyclohexafle
400
1,600
108-87-2
3
32.000
8.0
MathylcyclohelanOl
50
235
25639-42-3
3
4.700
1.0
0-Methy1CyClOhe aflOfle
50
230
583-60-8
3
4,600
1.0
Methylcyclopentadieflyl manganese
.
4
2.0
tricarbonyl (as Mn)
0.1
0.2
12108-13-3
ppbv
,..
Methylene bisphenyl isocyanate (MDI)
Methylene bis (4—cyclo-hexylisocyanate)
• 4 .4’-Methylene bis (2-chioranhline)
0.02
0.01
0.2
0.11
.003
101-68-8
512430-1
101—14-4
3
3
I
4
2.2
.015
0.4 ppbv
0.2 ppbv
4,4 ’-methylane bis (N.N-dimethyl)benzeflamide
2
Methylene chloride
100
350
75-09-2
3
7.000
4.4—Methylene dianiline
0.1’
0.8’
101-77-9
3
16
ppbv
Methyl n-butyl ketone
1.4
4
591-78-6
3
80
ppbv
Methyl demeton
0.5
8022-00-2
3
10
Methyl ethyl ketOfle (MEK)
200
590
78-93-3
3
11.800
4.0
Methyl ethyl ketone peroxide
0.2
1.5
1338-23-4
3
30
4.0 ppbv
Methyl formate
100
250
101-31-3
3
5,000
2.0
Methyl hydrazine
0.2
0.35
60-34-4
2
3.5
2.0 ppbv
Methyl iodide
5
28
74-88—4
2
280
- Methyl isoamyl ketone
48
230
110—12-3
3
4.600
Methyl isobutyl carbino)
25
100
105-30-6
3
2,000
0.5
Methyl Isobutyl ketone
50
200
10810 1
3
4,000
1.0
Methyl Isocyanate
Methyl isopropyl ketone
0.02
200
0.05
705
624-83-9
563—80-4
3
3
1
14,100
0.4 ppbv
4.0
Methyl mercaptan
0.5
I
74-93-1
3
20
0.0021
• Carcinogenic substance (Statute 19a - 3?9)
-------
TABLE 11.
Cont nued
HAZARDOUS SU8STANCE
LOWEST
THRESHOLD LIMIT VALUE (Tt.V)
(8-Hour Averaging Time)
ppm sng/m3
CAS roxzcrrv
NUMOER GROUP’
CT MAAC (8-hour)
(volumetric
(u9/m3) un$t$S* i)
ODOR
THRE SH0I 0
(ppm)
* See also VM8.P Naptha
** Carcinogens - .075, noncarclnogens - 0.3.
Connecticut’s ‘List of 47’
100
200
50
4)0 80-62-6
0.2 298-00-0
700 107-81-9
6 681-84-5
5 21087-64-9
240 98-83-9
443-46 --
0.1 7786-34-7
0.01
0.21
Methyl methacryiste
Methyl parathion
Mithyl n-propyl kston
Methyl silicate
M i t r thuz In
Methyl styrens
Metronidazol.
Msv lnpho&
Mich)er ’ keton.
Mi res
MOCA
Molybdenum (as Mo) so)ub)• compounds
Molybdenum (insoluble compounds)
Monocrot phos
Monomethyl aniline
Monomethy) hydrazifla
Morphol ir e
Mustard gas
r ., Myleran
Na I ad
Nap t ha
* Naptha lane
NapthaIene di isocyanate
I-Nspthylamlne
• * -Plspthylam$ne
Hicksl carbonyl • as 141
NIckel (metal)
*Nickel. soluble compounds (as Ni)
*Nicke) sulfide
Nickel sulfid, roasting, fume
and duet (as Ni)
Nicot me
Ni trapyr in
Nitric acid
NitrIc 0*10.
t4itrilotriacatic acid
p-Nit roanil ine
5
7439-98-7
—--
10
7439-98-7
——-
0.25
6923-22 -4
0,5
2
100-61-8
0.2
0.35
60-34-4
20
10
-
---
505-60-2
55-98-I
300-76-5
3
400
50
t00
I D
3
3
3
3
3
3
2
3
2
2
3
3
3
3
3
2
3
3
3
3
3
1.3
3
3
3
2
3
O • 200
4
10,600
20
100
4.800
2
100
200
5
40
3.5
350
60
8,000
1,000
0.8
75
5
$8
5
10
200
100
600
60
.05
2.0
4.0
0.02
1.0
2.0 ppbv
2.0 ppbv
2.0 ppbv
0.)
2.0
0.2
0.25 ppbv
0.04
0.5
0.0 l
0.015
.04
.35
9 1-20-3
39394-45-1
134-32-7
91-59-8
13463-39-3
7440-02-2
12035-72-2
0.5
54-Il-S
tO
1929-82-4
2
5
7697-37-2
25
30
10102-43-9
0.5 3 100-01-6
I Carcinogenic substance (Statute 19a -329)
-------
TABLE 11. Continued
LOWEST
THRESHOLD LIMIT VALUE (TLV) CT MAAC (8-hour) ODOR
(8-Hour Averaging Time) CAS TOXICITY (volumetric THRESHOLD
HAZARDOUS SU8STANCE ppm rng/m3 NUMBER CROUP (ug/m3) unitS*S1) (ppm)
5-Nitro-o—anis$d ine 2
Nltrobenzene 1 5 98-95-3 3 100 .02 .0047
p-Nltroch lorobenzene 1 100—00-5 3 20
I * 4-Nitrodiphonyl --- --- 92-93-3 1
Nitroethane 100 310 79-24-3 3 6.200 2.0
Nitrofen 2
Nitrogen dIo lde 3 6 10102-44-0 3 120 0.06
* Nitrogen mustard - --- 55-86-7 1
Nitrogen trifluorlde 10 29 7783—54-2 3 580 0.2
Nitroglycerin .05 0.5 55-63-0 3 10 1.0 ppbv
Nltromethane 100 250 75-52-5 3 5.000 2.0
1-P4 ltropropana 25 90 108-03-2 3 1.800 0.5
2-Nitropropafle 25. 90. 79-46-9 2 900 0.25
NitrosamineS ——— —-- 2
n-Ni trosodI-n-butYIamlnO 2
• * n-Nitrosodimethylamlne 62-75-9 1
n-nltrosodiethenOlamlne 2
n-Nltrosodlethy l am lfl e 2
n-I litrosodiphenylamtne 2
n-Nitroso--N-propylamlflO 2
n-Ni troso-N-ethylurea 2
n-Nitroso-N-methy iurea 2
n-Nitrosomethylvlflylamifle 2
n-Nitrosomorpho l lne 2
n-N ltrosonornIcot lfle 2
n-Nltrosoplperidlfle 2
n-N ltrosopyrrolidffle 2
n-NitrososarCoSifle 2
N ltrotoluene 2 11 99-08 1 3 220 0.04
Nitrous oxide 37 67 10024-97-2 3 1,330 0.73
Nonane 200 1.050 111-84-2 3 21,000 4.0
Nonanethiol - 1455-21-6 3
Norathisterone -—— ——- 68-22-4 2
Norethynodrel 68-23-4 3
Noc-gestrol --— --- 6533002 3
Octach loronaphthalene --— 0.1 2234-13-1 3 2
Octane 72 350 111-65-9 3 7,000 1.4
Octanethiol ——— 1 1 1866 3
Octodecanethiol 3
Oestradio lll-beta 2529-64-8 2
* The national ambient air quality standard (annual arithmetic mean) Is 100 ug/m3. The NAAQS ci )) take precedence.
The value shown is entered for comparative purposes only.
4 Connecticut’s ‘List of 47”
• Carcinogenic substance (Statute 19a - 329)
-------
TABLE 11. Continued
HAZARDOUS SUBSTANCE
LOWEST
THRESHOLD LIMIT VALUE (TLV)
(8-Hour Avera9in9 Time)
ppm mg/m3
CAS TOXICITY
NUM8ER GPOUP•
CT MAAC (8-hour)
(volumetric
(u9/m3) units•’•)
ODOR
THRESHOLD
(ppm)
• The national ambient air quality standard
is entered for comparative purposes on’y.
* e Proposed for revision
Connecticut s “List of 47”
(1-hour) is 235 ug/m3. The NAAQS will take precedence. The value shown
4.0
1.0
pptv
ppbv
2.0 ppbv
0.1 ppbv
Oestrone
——-
—-—
53-16—7
2
-—-
Oil mist, mineral
Osmium tetrosid. (as Os)
0.0002
0.002
8012-95- )
20816-12-0
3
3
1QO
0.4
Oxa)ic acid
-—-
1
144—62-7
3
20
Osygendifluoride
O*ymetholone
Ozone
O.O5’ ’
-—-
0.1
3)55*
---
0.2
7783-41-7
434-07-1
10028-15-6
3
I
3
2
4**
Paraffin wa* fume
2
8002-74-2
3
40
*
Paraquat, respirable sizea
Parathion
- — -
-—-
0.1
0.)
19)0-42-5
56-38-2
3
3
2
2
Pentaborane
0.005
0.0)
19624-22-7
3
0.2
P.ntachloron*phthalen .
-- -
0.5
1321-64-8
3
10
Pentachlorophenol
---
0.5
87-86-5
3
I D
Pentaerythritol
15
1 15-77-5
3
300
Pentane
200
350
109-66-0
3
7.000
4.3
Pentanethiol
110-66-7
3
2-Pentanone
200
700
107-87-9
3
14.000
4.0
.
Perchloroethylene
Perchloromethyl mercaptan
50
0.1
335
0.8
127-18-4
594-42-3
I
3
1.700
16
0.25
2.0
ppbv
Perchloryl fluoride
3
13.5
76)6-94-6
3
210
0.06
Phenacetin
---
---
62-44-2
1
Phenazopyricline
---
---
94-78-0
2
PhenazopyridIna chloride
2
Phene lzine
51-71-8
3
Phenantoin (and sodium salt)
2
Phønob.rbitol
3
Phenol
5
19
108-95—2
3
380
0.1
Phenothiazine
---
5
92-84-2
3
100
Pheno*yacetic acid herbicides
---
—--
2
Phenylbutazone
---
50-33-9
3
p-Phenylene diamine
---
0.1
106-50-3
3
2
---
Phenyl ether (vapor)
1
7
101-84-8
3
140
0.02
Phenyl ether-Dtphenyl mt*ture
(vapor)
I
7
3
140
0.02
Phenyl glyCidyl ether (PGE)
I
6
122-60-1
2
60
0.01
Phenythydrazine
5
20
100-63—0
3
400
0.)
Phenyl mercaptan
0.5
2
10898-5
3
40
0.01
Phenyl- -naphthylamine
-—-
---
135—8806
2
Phenyl-2-oaphthy lamine
---
---
3
Phenylphosphine
0.05
0.25
638-21-1
3
5
1.0 ppbv
4 . 58
.047
• Carcinogenic substance (Statute 19 - 32 ’)
-------
TABLE 11. Continued
LOWE ST
THRESHOLD LIMIT VALUE (TLV)
(8-Hour Averaging Time)
ppm mg/m3
CT MAAC (8-hour)
(volumetric
(ug/m3) units’)
* 8er zene—soluble fraction
4 Connecticut’s “List of 47”
HAZARDOUS SUBSTANCE
CA S
NUMBER
TOXICITY
GROUP *
ODOR
THRE SHOLD
(ppm)
1.0•
Phenytoin
“-
—
57—410
2
Phorate (Thimet)
—--
0.05
298-02—2
3
Phoadrin (Mevinphos)
Phosgene (carbonyl chloride)
0.01
0.1
0.1
0.4
7786—34-7
75-445
3
3
2
8
0.2
2.0
ppbv
ppbv
Phosphine
0.3
0.4
7603—51-2
3
ppbv
Phosphoric acid
—--
1
7664-38-2
3
Phosphorus (yellow)
—-—
0.1
7723—14-0
3
2
Phosphorus oiychloride
Phosphorus pentachloride
Phosphorus pentasulfide
0.1
0.1
---
0.6
1
1
10026-13-8
10026-13-8
1314-80-3
3
3
3
12
20
20
2.0
2.0
—--
ppbv
ppbv
Phosphorus trichioride
Phthalic anhydride
0.2
I
1.5
6
7719—12-2
85 -44-9
3
3
30
120
4.0
0.02
ppbv
m-Phthalodinitri le
5
626—17-5
3
100
--—
Picloram
10 .
1918-02-1
3
200
—-—
Picric acid
—-
0.1
88-89-I
3
2
—-—
Pindone
---
0.1
83-26-1
3
2
—--
j ,
Piperazine dihydrochloride
Pival (2-Pivalyl-1.3-lfldafldiOfle)
5
0.1
142-64-3
83-26-I
3
3
100
2
—--
Platinum (metal)
1440—064
3
20
“
Platinum (soluble salts) (as Pt)
0.002
3
0.4
---
Polybrominated biphertyls
2
Polychiorinated biphenyls:
* 42% Cl
.001
11097-69-I
2
.01
* 54% Ci
Polycyclic Aromatic Hydrocarbons
(PAH)
.001
0.O2
11097-69-I
50-32-6
2
1
.01
0.10
---
Polytetrafluoroethylefle decomposition
products
3
Potassium hydroicide
2
1310-56-3
3
40
Prednisone
53-032
3
Procarbazine
671-16-9
2
Procarbazine hydrochloride
2
Progesterone
---
57-83-0
2
Propane
—--
74-98-6
3
Propane sultone
---
-—-
1120714
2
Propanethiol
• -Propiolactone
---
0.5
1,800
1.5
75-33-2
57-57-8
3
1
36.000
2.5
ppbv
Propargyl alcohol
1
2
101—19-7
3
40
Propionic acid
10
30
79094
3
600
0.2
• Carcinogenic substance (Statute 19a - 329)
-------
TABLE 11. Continued
LOWEST
THRESHOLD LIMIT VALUE (TLV)
(8-Hour Averaging Time)
ppm mg/m3
CAS TOXICITY
NUMBER GROUPS
CT MAAC (8-hour)
(v o I ume t r I C
(ug/m3) units*$*)
ODOR
THR E SHOLD
(ppm)
* Connecticut’s “List of 47”
• Carcinogenic substance (Statute 19a 329)
HAZARDOUS SUBSTANCE
PropIonitrile
6
14
107-12—0
3
280
O,
Propo*ur
n-Propyl acetate
---
200
0.5
840
109-60-4
3
3
10
16.800
—--
4.0
Propyl alcohol
200
500
7 123-B
3
10 .000
4.0
Propylene
-
- -
1 15-07l
3
Propylene dichloride
75
350
78-07-5
3
7,000
1.5
Propylene glycol dinitrate
.05
0.3
6423-43-4
3
6
1.0 ppbv
Propylene glycol monomethyl
ether
ioo
360
107-98—2
3
7.200
2.0
Propylene imine
2
5
75-55-8
2
*00
0.04
Propylene oiide
20
50
75-56-9
3
1,000
0.4
n-Propyl nitrate
25
105
627-13-4
a
2,100
0.5
Propy lthiouracil
—-—
—-—
2
Pyrethrum
---
5
8003-34-7
3
100
--
Pyridins
5
15
110-864-1
3
300
0.1
QuInone
0.1
0.4
106-51-4
3
8
2.0 ppbv
ROX
--—
1.5
121-82-4
3
30
---
R.s.rpin.
---
---
50-55-5
2
Resorc lriol
10
45
108-46-3
3
900
0.2
Rhodium, Metal fume I dusts
(as Rh)
---
0.1
7440—16-6
3
2
---
O
- insoluble compounds
- soluble salts (as Rh)
---
---
I
0.01
3
3
20
.02
-“
—--
Ronnel
---
10
299-84—3
3
200
---
Rosin core solder pyrolysis
products
(as formaldehyde)
o,i
3
2
---
Rot none
5
83-79-4
3
100
2.0 ppbv
Rouge
-—-
1309371
3
<1
Saccharine
---
81-07—2
2
Safrole
2
Selenium compounds (as Se)
---
0.2
7782-49-2
3
4
—--
Selenium hei afIuorIde
0.05
0.2
7783-79-1
3
8
2.0 ppbv
Selenium sulfide
2
Sesone
10
136-78-7
3
200
Si lane
5
7
7803-62-5
3
*40
0,1
Silica, amorphous
—--
---
60676-86-0
3
Silicon
—--
--—
7440—21-3
3
—-—
Silicon carbide
--—
——-
409-21-2
3
Silver, metal
—--
0.01
7440-22-4
3
0.2
Silver, soluble compounds
0.01
3
0.2
“
Sodium azicle
0.1
0.3
26628-22-8
3
6
2.0 ppbv
Sodium bisulfite
---
5
7631-90-5
3
100
- --
Sodium fluoroacotate (1080)
—-—
0.05
62-74-8
3
I
---
Sodium hydro*ide
---
2
1310-73-2
3
40
---
Sodium metabisulfite
--
5
7681-57-4
3
100
---
0.02$
-------
TABLE 11.
Conti nued
HAZARDOUS SUBSTANCE
LOWEST
THRESHOLD LIMIT VALUE (TLV)
(8-Hour Averaging Time)
ppm mg/m3
CAS TOXICITY
NUMBER GROUP’
CT MAAC (8-hour)
(ug/m3)
(volumetric
units * SI)
ODOR
THRESHOLD
(ppm)
* Petroleum solvents generally, except kerosene
“ The short—term EPA national ambient air quality standards for S02 are: 1300 ug/m3 (3—hour average) and 365
ug/m3 (24-hour average). The 8-hour equivalent NAAQS would be 860 ug/m3 , by logarithmic interpolation. The NAAQS
will take precedence. The value shown is entered for comparative purposes Only.
* 5* Proposed for revision
Connecticut’s “List of 47
Sprionolactone
Stibine
—— —-—
0.1 0.5
52—01—7
7803-52—3
3
3
10
2.0 ppbv
Stoddard solvent
61 350’
8052-41-43
3
7,000*
1.22
Streptozotoc ln
2
Strychnine
——- 0.15
57—24—9
3
3
—--
Styrene, monomer
50 215
100-42-5
3
4,300
1.0
Styrene oxide
--- ---
96-09-3
3
---
Subtilisins (proteolytic enzymes as
100%
pure crystalline enzyme)
——- 0.00006
1395-21-7
3
.0012
---
Succinonitrile
6 20
110—61-2
3
400
0.12
Sulfefurazole
-—- ———
127—69-5
3
Sulfal late
2
Sulfamethoxazole
.
723—46—6
3
10’’
Sulfur dioxide
0.2 0.5
7446-09-5
3
20”
4.0 ppbv
Sulfur hexafluorlde
1.000 6,000
2551-62-4
3
120,000
20.0
Sulfuric acid
1
7664-93-9
3
20
---
Sulfur monochloride
l.’’* 6.”’
10025-67-9
3
120
0.02
Sultur pentafluoride
0.025’’’ 0.25”’
5714-22-7
3
5
0.5 ppbv
Sulfur tetrafluoride
0.1’” 0.4”’
7783-60-0
3
8
2.0 ppbv
Sulfuryl fluoride
5 20
2699-79-8
3
400
0.1
. .
Sulprofos
2,4,5-1
---
10
35400—43-2
93-76-5
3
3
20
200
-—-
Tantalum
5
7440-25-7
3
100
hOP (Sulfotep)
0.2
3669-24 5
3
4
Teflon decomposition products
3
Tellerium I compounds (as Te)
0.1
13494-80-9
3
2
Tellerlum hexafluoride, as Te
0.02 0.2
7783-80-4
3
4
0.4 ppb
TemephOs
- 10
3383-96-8
3
200
“-
TEPP
0.004 0.05
107-49-3
3
1
0.08 ppbv
*
Terphenyls
2,3,7,8-Tetractulorodlbenzofuran
0.5 5
——- —--
‘J2-944
51207—31-0
3
3
100
—-—
0.01
Tetrachlorinated dibBnzo-p-dioxins
l,I, 1,2-Tetrachloro-2.2-dif luoroethane
500 4,170
1746-01-6
76-11-9
2
3
---
03,400
10.0
0.047
.016
• Carcinogenic substance (Statute 19a - 329)
-------
TABLE 11. Continued
LOWE Si
THRESHOLD LIMIT VALUE (TLV)
(8-Hour Averaging Time)
ppm mg/m3
CAS TOXICITY
NUMBER &ROUP
CT MAAC (8-hour)
(volumetric
(ug/m3) un1ts S)
HAZARDOUS SUBSTANCE
1,1 ,2,2-T.trach)oro-1.2-d ifluoro.thane
500
4,170
76-12-0
3
83,400
10.0
1,l,22-T.trach loro.thanl
1
6.87
79-34-5
1
34.4
5.0 ppbv
T.trach loronaphthalen.
---
2
1335-88-2
3
40
---
T.tra.thyl lead (as Pb)
—--
0.075
18-00-2
3
1.5
---
Tetrahydrofuran
200
590
109-99-9
3
11,800
4.0
Tetram.thyl lead (as Pb)
—--
0.075
75-74-1
3
1.5
-—-
Tetramsthyl succinonitrils
0.5
3
3333-52—6
3
60
0.01
T.tranitromethan.
8
509-14-B
3
I SO
0.02
Tetrasodium pyrophosphats
---
5
7722-88-5
3
100
---
Tetryl (2 .4,6-trinitrophenyl-
methylnitram lne)
1.5
479-45-8
3
30
Thallium. soluble compounds (as TI)
0.1
7440-28-0
3
2
Thioacetamine
2
4,4’-Thlobts (6-tart butyl-m-CreiOl)
—--
10
96-69-5
3
200
---
Thioglycolic acid
1
5
68-11-1
3
tOO
0.02
Thiotepa
--—
———
52-24—4
2
Thiourea
2
Thiram
5
137-26-8
3
100
Thorium diox dc
Tin, metal
Tin, inorganic compounds, except
2
7440-31-5
I
3
40
SnH4
- --
2
3
40
Tin, organic compounds (as Sn)
---
0.1
3
2
Tin, oxide (as Sn)
—--
2
3
——-
Titanium dioxide (as Ti)
———
15
13463—67-7
3
300
o-ToI id$ne
—--
---
119-93-7
2
180
0.04
To luane
tOO
375
108-88-3
3
7.500
2.0
*
Toluene -2.4-diisocyanate (TDI)
.005
.04
584-84-9
3
0.8
0.1 ppbv
o-Totuidtne
2
9
95-53-4
2
90
0.05
o-Toluidina hydrochloride
2
Toxaphena
0.5
8001-35-2
I
Treosulfan
-
299-75—2
I
Triaziquone
---
---
68768
2
Tributyl phosphate
0.2
5
126-738
3
100
4.0 ppbv
Trichioroacetic acid
I
5
76-03-9
3
20
0.02
• Proposed for revision
ODOR
THRE SHOLD
(ppm)
2.14 to
4.68
2.14
Connecticut’s “List of 47”
• Carcinogenic substance (Statute 19a - 329)
-------
TABLE 11. Continued
• Less when combIned with Co and Ni
S. Proposed for revision
* Connecticut’s “List of 47”
LOWEST
THRESHOLD LIMIT VALUE (TLV)
(6-Hour Avera9ing Time)
ppm mg/m3
HAZARDOUS SUBSTANCE
CAS TOXICITY
NUMBER GROUP’
CT MAAC (B—hour)
(volumet nc
(u /m3) units’’ ’)
ODOR.
THRESHOLD
(ppm)
21.40
4.63
0 .1
7.0
0.05
0.25
20. 0
-O
20.0
0.2
20.0
0.1 ppbv
0.2
0.5
0.04
l.2 ,4—Trich lorobenzefl e
1 ,l ,l-Tn lch loroethane
1 ,1,2-Trich loroethane
Trichloroethy lene
5
350
10
50.”
40
1.900
45
270.”
120-82-1
71-55—6
79-00—5
79-01-6
3
3
1
I
800
36,000
225
1,350
Trichlorof luoromethane
1,000
5.600
75-69-4
3
1 )2,000
Trich loronaphtha lene
5
1321-65-9
3
100
2,4,5 —Trichiorophenol
-
.
.95-95—4
3
2,4 ,6—Trichiorophenol
——-
—-—
88-06-2
1
1,2.3-Tr ich loropropane
1, 1,2-Trichloro 1,2,2—trifluoroethane
50
1,000
300
7.600
96-18-4
76-13—1
3
3
6.000
152.000
Tricyclohexyltin hydroM Ida (p)ictran)
-—-
5
l3i2 1—70-5
3
100
Triethylamina
tO
40
121-44-8
3
800
Trifluoromonobomomethane
1.000
6,100
75-63-8
3
122,000
Trimetalic anhydride
0.005
0,04
552-30-7
3
0.8
Trimethyl amine
10
24
75-50-3
3
480
Trimethyl benzene
25
125
25551-13-7
3
2.500
Trimethyl phosphite
2
10
•12 1459
3
200
2 ,4—6-Tninitrotoluene (TNT)
Triorthocresyl phosphate
Triphenyl phosphate
-—-
,---
0.5
0.1
3
1 18—96-7.
73-30-8
115—86-6
3
3
3
10
2
60
Tris(1-aziridinyl)phosphina sulfide
2
Tr,s (2,3-cllbromopropyl)phosplthte
.
2
Tun9sten I compounds, as W - soluble
---
1
7440-33-7
3
20’
— insoluble
—--
5
a
ioo’
Turpentine
100
560
8006-64-2
3
11.200
2.0
UndecanethiO l
---
---
3
-—-
Uracil mustard
66-75-1
2
Uranium (natural) soluble, as U
.05
7440-61-1
3
i
insoluble
0.20
3
4
Urethane
2
Vale-aldehyde
50
175
110623
3
3.500
1.0
Vanadium, as Pento ide, - Dust
---
0.05
131462 1
3
10
(Fume)
---
0,05
13 1462’-l
3
I
Vinbiastine
-—-
—
8652 1-4
3
Vincristine
———
———
57-22—7
3
Vinyl acetate
IQ
30
108-05—4
3
600
0.2
• Carcinogenic substance (Statute 19a - 329)
-------
TABLE 11. Continued
HAZARDOUS SUØSTANCE
LOWEST
THRESHOLD LIMIT VALUE (TLV)
(8-Hour Averaging Time)
ppm .ng/m3
CAS TOXICITY
NUU8ER GROUPS
CT MAAC (8-hour)
(volume t r c
(ug/m3) units ’)
ODOR
THRESHOLD
(ppm)
* Connecticut’s “List of 47”
• *
Vinyl bromide
Vinyl chloride
Vinyl cyc1ohe eoI dioKidS
Vinyl toluerie
5
10
100
10
60
480
75-01 -4
106-87-6
25013-15-4
75-35-4
1
2
3
3
50
600
9,600
400
25.0 ppbv
0.1
2.0
0.1
Vinylidene chlOride
VM I P Naphtha
Wartarin
5
300
--
20
1350
0.1
8030-30-6
ØI-8 12
3
3
3
27,000
2
100
6.0
---
welding fumes (NOC)+
5
1330-20-7
3
8.680
o-Xylene
m-Xylena
p-Xylene
m-Xylene , ‘-diamir%e
100
100
100
---
435
435
435
o.i
1330-20-7
1330-20-7
1330-73-8
3
3
3
3
8.680
8,680
2
200
Xylidiflo
Yttrium
2
10
1
7440-65-5
7646—85—7
3
3
20
20
Zinc chloride fume
I
13530-65-9
2
0.5
Zinc chromate (as Cr)
0.05
1314—13-2
3
100
Zinc oxide fume
5
557-05—I
a
---
Zinc stearate
7440—67-2
3
100
Zirconium compounds (as Zr)
5
0.47
0.47
O .47
2.0
2.0
2.0
0.04
• Carcinogenic substance (Statute 19a - 329)
------- |