AIR TOXICS INFORMATION
CLEARINGHOUSE
*"jjJ ^ZD^\ Offlea of Air Quality Planning and Standards
ElirA Raaaarch Trlangta Park. Nortft Carolina 27711
STP A fp)f0) A | AH A fBV?3^ Stat* and Territorial Air Pollutipn Program Administrators
11 Z-\Lr If Z-u |/ Zr-u laZr-uir	Association of Local Air Pollution Control Officials
Reprint of the EPA
Air Toxics Strategy
July 1985

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A STRATEGY TO REDUCE RISKS TO
PUBLIC HEALTH FROM AIR TOXICS
U.S. Environmental Protection Agency
Washington, D.C.
June 1985

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TABLE OF CONTENTS
I.	The Nature of the Problem	3
II.	Routine Releases: Programs in Place 	 6
III.	Routine Releases: Needed Actions 	 .... 11
IV.	Sudden, Accidental Releases: Programs in Place ... 22
V.	Sudden, Accidental Releases: Needed Actions .... 30
VI.	Conclusion 			 . 36

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A STRATEGY TO REDUCE RISKS TO
PUBLIC HEALTH FROM AIR TOXICS
EXECUTIVE SUMMARY
U.S. Environmental Protection Agency
Washington, D.C.
June 1985

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A STRATEGY TO REDUCE RISKS TO PUBLIC HEALTH PROM AIR TOXICS
This report presents the results of an eighteen-month
examination of air toxics—whether emitted routinely or sud-
denly, under accidental conditions—and the means to reduce
their risks. Air toxics result from all the activities of a
modern society, from driving a car, to burning fossil fuel, to
producing and using industrial chemicals. Public exposure to
air toxics presents risks to human health that call for an
aggressive and measured response.
As a Nation we must target our efforts on those control-
lable air toxics that present the greatest health risks to the
American public. Controls in place have already made, and
continue to make significant inroads in the problem. Yet this
report concludes that much remains to be done by EPA, the
States, and the private sector. In light of the air-toxics
problem as EPA now understands it, this report sets out a
comprehensive action agenda, calling for both reinforcement
of existing public programs and initiation of several important
new undertakings. Highlights of EPA's action plan are:
National Regulation. While maintaining a strong program to con-
trol industrial (point) sources, EPA will vigorously control
"area" (that is, small, but numerous and broadly distributed)
sources, multiple-pollutant sources, and other non-traditional
sources of complex toxic emissions that appear to account for
a significant portion of the controllable health risk.

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State Air-Toxics Control Programs. The air-toxics problem is
not limited to problems of national concern. In some cases
areas of locally elevated risk may require targeted action by
State or local agencies. EPA will help States to build strong
air-toxics programs of their own and, when appropriate, refer
problems of specifically local concern to States for evaluation
and appropriate action.
Developing Multi-Media Control Methods. EPA will expand its
multi-media studies of local toxic problems as a basis for a
Federal/State partnership to address any areas of localized
risk from multiple sources. The Agency will work with State
and local authorities to measure risks across media and assess
alternative strategies for appropriate abatement.
Sudden, Accidental Releases. EPA will expand its program for
emergency preparedness and response. This expansion includes
evaluating and improving information systems, training State
and local response teams, and planning for emergencies, in-
cluding exercises to test how well systems are working and
how they can be improved. Besides reinforcing existing emer-
gency preparedness, EPA will undertake three new efforts:
1. Step Up Enforcement of Chemical-Hazard Notification
EPA will increase resources to enforce Reportable Quantity
requirements* and require recordkeeping and reporting authorized
under TSCA. This will disclose patterns of chemical mishandling,

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3
heighten industry consciousness of specific chemical hazards,
promote realistic contingency plans, and enable prompt res-
ponse to emergencies.
2.	Issue an Acute-Hazards List.
EPA will prepare and issue a list highlighting substances
most likely to cause serious harm in the event of a large acci-
dental release. It would include substances known for their
acute toxicity and potential for release.
3.	Promote Community Right to Know
EPA will work with those who support a program to ensure
that communities have ready access to information on chemicals
in use for the purpose of realistic contingency planning.
EPA's Acute-Hazards List will support this effort.
I. The Nature of the Problem
Along with the growth of our industrial society, there
has been an increase in the number and types of toxic chemicals
to be found in our environment. The problem we face takes two
forms: risks posed by emissions from the normal activities of
modern society (hereinafter referred to as "routine" releases),
and risks from sudden, accidental releases of substances caoable

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4
of inducing immediate health effects. The two parts of the
problem stem from different causes and therefore demand
separate solutions.
The Problem of Routine Releases
Air toxics enter the atmosphere through many of the
everyday processes of American life, in fact, some of the
most potent releases originate in our most mundane activities,
such as burning wood and coal, or driving cars and trucks.
EPA's job is to determine which chemicals cause the most
serious health effects, identify those that can be controlled,
and apply appropriate tools to control them.
The size of the health-effects problem associated with
routine emissions of air toxics is difficult to define in abso-
lute terms. Available models project statistically the
incidence o£ cancer likely to be associated with long-term
exposure to certain airborne substances. While it is easier
to estimate cancer incidence than that of other diseases, we
believe that controls effected to reduce the risk of cancer
tend to reduce the incidence of other diseases as well.
Reduction of cancer is an important goal for our society,
but it is important to keep in mind the limits on the progress
that can be made by environmental control programs. According
to the National Cancer Society, in 1983 the total number of
deaths due to cancer in the United States is estimated to have

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been 440,000. Diet and smoking appear to account for the vast
majority of these deaths. Of the relatively small number likely
to be associated with exposure to air toxics, only a portion can
be prevented through national intervention. For Federal action
to be effective within such a narrow target area, it is essential
that we select appropriate and efficient tools, and use them
wisely.
The Problem of Chemical Accidents
As for the sudden, accidental release of toxic chemicals,
the Nation is now engaged in a thorough reexamination of the
systems in place for chemical accident prevention, preparedness,
and response. In approaching this problem we must recognize
the fundamental paradox that it presents.
Accidental chemical releases occur in the United States
every day. In 1981, 1665 such releases (other than oil) were
reported to the National Response Center. Although a natural
gas explosion killed 40 as recently as 1973, we must go back
to 1947 to find a chemical accident involving catastrophic loss
of life. In that year a French fertilizer-transport ship explo-
ded off Texas City, Texas, killing 565 and injuring 3000.
Perhaps the most notable factor associated with this acci-
dent, beyond its magnitude, is its singularity and remoteness in
time. Our society's dependence on industrial chemicals has
increased since the accidents of the forties, but so have out1

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defenses against such calamities. A chemical release does not
necessarily equate to an immediate health or environmental hazard.
For people to be hurt, there must be a coincidence of potency,
volume, and exposure sufficient to overwhelm physical and natural
defenses. Based on records of actual injury, these factors do
not coincide very often in the United States. As a matter of
fact, in recent years the chemical industry has often placed
first on the National Safety Council's industrial safety ranking.
In this country, most accidental chemical releases are
quickly controlled so that people are not seriously injured.
Since Bhopal, however, American chemical companies have been
taking a long, hard look at their safety programs, seeking to
prevent serious accidents in the first place, and to prepare
for quick response to contain incipient accidents. The task for
EPA, in cooperation with the Federal Emergency Management Admin-
istration (FEMA), is to reinforce those private efforts at preven-
tion, and to ensure the strongest possible public capability to
prepare for and respond to chemical release accidents if and
when they occur.
II. Routine Releases* Programs in Place
EPA has completed a new study, based on available data and
entitled "The Air-Toxics Problem in the United States: An Analy-
sis of Cancer Risk for Selected Pollutants" (hereafter, "The Air
Toxics Study"). It considers the effect of conventional controls
for criteria pollutants (air pollutants for which ambient standards

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have been set) as well as mobile-source controls, on toxic emis-
sions—and subsequent changes in ambient levels. Such controls
frequently reduce toxic emissions in the process of removing the
pollutant against which they are specifically directed. Based
on a comparison of measured ambient levels and estimated emissions,
the Air Toxics Study estimates the number of cancer cases annually
associated with exposure to a group of air toxics in 1970 to be
about 3600. The estimate for 1980 is better than 50% lower.*
Stationary-Source Controls. Toxic reductions realized from steps
taken primarily for other purposes can be quite substantial. For
example, National Ambient Air Quality Standards (NAAQS) for par-
ticulate attained through State Implementation Plans frequently
control toxic metals from point sources by 80 to 98 percent.
Controls for ozone generally reduce emissions of volatile organ-
ics from 30 to as much as 90 percent, while New Source Performance
Standards are usually from 90 to 99 percent effective for these
pollutants. We can expect the trend toward lower ambient levels
of toxic air pollutants to continue as we sustain the momentum
built into the stationary-source provisions of the Clean Air Act.
*It is important to understand that these figures take into ac-
count only a select group of air toxics chosen for their signifi-
cant toxicity and the ready availability of credible data re-
garding their effects. Estimates are statistical, not actual;
they are probably inaccurate in absolute terms. But it is fair
to compare them in relative terms to determine the direction, and
estimate the degree, of change.

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Mobile-Source Controls. Control of mobile-source pollution
plays a major role in toxic-risk reduction as well. One of the
most important examples of this is the control of ambient lead
through mobile-source standards. During the 1970's and 80's,
the amount of lead in gasoline dropped as EPA's standards
t ightened.
Recently, EPA set new rules that will sharply reduce even
this residual lead in gasoline over the next year, from 1.1
grams-per-leaded-gallon (gplg) to 0.1 gplg, and is considering
a complete ban by as early as 1987. (Use of ethylene dibromide—
EDB—falls along with the lead content of gasoline, implying a
further reduction in toxic risk from these actions.) The Agency
estimates that in 1986 alone this new standard will prevent
172,000 children from exceeding the lead blood level of health
concern set by the Centers for Disease Control.
Other Environmental Authorities. Outside the air program itself,
actions taken or proposed under other authorities, such as
the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA),
the Toxic Substances Control Act (TSCA), the Resource Conserva-
tion and Recovery Act (RCRA), the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA, or Superfund),
and the Clean Water Act (CWA), have implications for air-toxics
reduction. For example, controls being developed under RCRA for
volatile organics from emitted hazardous waste dumps will impede
release of these toxics to the ambient air.

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Installation of pretreatment controls under the Clean Water
Act, already underway, reduces air emissions from municipal
waste treatment plants. Such regulations as FIFRA's control of
carbon tetrachloride and EDB from grain fumigation also have a
direct and immediate impact on toxic air emissions.
National Emission Standards for Hazardous Air Pollutants.
Despite the existence of such varied tools for control of air
toxics, EPA has invested a great deal in the administration of
National Emission Standards for Hazardous Air Pollutants (NESHAPS)
under S112 of the Clean Air Act. Although more NESHAPS standards
will soon be set, the number issued to date (six) reflects the
relative infrequency of the specific set of conditions for which
a national standard under NESHAPS is an effective means to protect
public health. For EPA to set a national standard under NESHAPS,
the Agency requires a finding that a pollutant/source category
presents significant risk to public health nationally (e.g., as
a carcinogen), and that it can be subjected to reasonable and
effective control through the imposition of uniform, national
standards. In fact, an individual pollutant/source category
is often found to account for relatively little national disease
incidence, or is in any case unauited to reasonable control by
national regulation.
For many reasons, too, NESHAPS reviews have concentrated on
pollutant/source categories associated with the chemical industry.
However, several years of experience has led us to conclude that
the chemical industry is not the major source of our national

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air-toxics problem. In fact, we now estimate that point sources
associated with heavy industry (of which chemical manufacture is
but a small part) account for only 20-25% of cancer incidence
from national air toxics. By comparison, over 50% of national
incidence appears due to road vehicles (including gasoline
vapors and diesel particulates) and heating sources (including
fossil fuel burning, coke ovens, and wood stoves).
It i's evident that we must look beyond national regulation
under NESHAPS to add other effective controls for air toxics. in
this regard, work is underway that may soon improve control of
air toxics at the State or local level, a movement which EPA will
foster. As of now, 22 States and local agencies have established
air-toxics control programs, and a number of others are considering
a similar step. Over a dozen States with sources of the carcinogen
acrylonitrile are actively working with EPA to evaluate data on
local sources of this chemical. As announced in another action
today, this cooperation may soon lead to additional, site-specific,
State regulation of sources of acrylonitrile. Unlike a national
standard issued under NESHAPS, State-imposed controls allow more
precisely tailored and efficient control of the relatively few
sources of acrylonitrile across the country. This is because
States are highly competent in setting emission limits for
individual sources (they do this as a matter of daily business
under State Implementation Plans), and because different types
and levels of control may well be required in separate situa-
tions.

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In addition, EPA is sponsoring projects in Baltimore, Phila-
delphia, and the Santa Clara Valley to evaluate site-specific
hazards from air toxics (as well as risks conveyed through other
environmental media) and to seek local control strategies. These
strategies can be targeted to solve geographic-based problems
without introducing the imprecision implied by a single level of
control that must be applied indiscriminately to all situations
throughout the State and Nation.
III. Routine Releases: Needed Actions
Our reexamination of the air-toxics problem from routine
emissions reveals that more can be done, effectively, to reduce
risks. The program outlined below .identifies remaining needs
in our national effort and presents the actions we will take in
response to those needs. In some cases, EPA's program reflects
an evolution in concepts and activities that have been underway
for as long as two years. In other cases, we propose actions
that are substantially new.
National Regulation
EPA will deal aggressively with the remaining routine emis-
sions of air toxics. To ensure maximum benefits for the effort
expended, the Agency must make careful choices concerning which
regulatory targets to emphasize, and make wise use of all appro-
priate authorities, including §112 of the Clean Air Act. In

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some cases this means broadening our scope of action and in
others it means redirecting existing programs to yield greater
risk reduction.
ACTION STEPS
1. Regulate Stationary Sources of Multiple Toxic Pollutants
Although regulating a single pollutant from point sources
will at times prove the right approach, EPA will now broaden
its emphasis by regulating not only single pollutants but also
multiple pollutants from whole source categories. In many cases
this will allow EPA to control several toxic pollutants with a
single regulation.
More importantly/ EPA will now expand its work on air toxics
to encompass "area" and non-traditional sources through a variety
of provisions of the Clean Air Act, such as SSlll, 112, 202, and
211, as well as other relevant statutes. In air-pollution par-
lance, "area sources" are small, widespread sources, such as
degreasing operations, motor vehicles and fuels, and small
combustion sources. Non-traditional sources include hazardous
waste treatment, storage, and disposal facilities (TSDPs) and
publicly owned sewage treatment works (POTWs), which we have
recently recognized as potentially significant sources of air
pollution. This shi£t from EPA's traditional regulatory priori-
ties will allow us to more effectively reduce public exposures
to air toxics, in that (1) we will consider more types of sources

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for needed control, (2) we will seek to evaluate entire emission
streams, rather than isolated chemical constituents, and (3) we
will take into account short-term, as well as long-term exposures
of the public.
In November of 1983 EPA committed to review 20 to 25 indivi-
dual chemicals and to decide by the end of 1985 whether to list
them as substances we intend to regulate under the Clean Air
Act. This decision-making process is on schedule and will be
completed as promised. Although each of these,decisions affects
a single pollutant, in examining them EPA has begun to build the
foundation for the more inclusive approach. For example, several
of the pollutants under review are emitted from the same source
category: several metals are emitted from municipal incinerators,
and several volatile organic compounds originate from POTWs. For
some chemicals, we are considering various area-source categories
for regulatory action.
In this way, while the Agency completes its review of
these chemicals individually, we are also supporting subsequent
regulation of source categories of multiple pollutants where
possible. In this regard, the Agency recently listed an entire
emission stream—coke oven emissions—as a hazardous air pollu-
tant under S112. We will propose regulations for this source
category in early 1986.
We are also reviewing such source categories of multiple
toxic pollutants as chemical production, sewage sludge incinera-
tion, smeIters, metal degreasing operations, sewage treatment

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plants, and gasoline marketing under one or more of several
possible authorities. Under SHI of the Clean Air Act (New
Source Performance Standards), EPA expects to regulate such
categories of multiple pollutants as the synthetic organic chemi-
cals industry and residential woodstoves.
To support further work in this area, the Agency will study
still other source categories to determine which may emit multi-
ple pollutants of concern. Examples of categories to be examined
include chemical production facilities, chemical users, and
combustion operations. EPA's ongoing research programs on the
health effects of exposure to individual airborne chemicals and
complex mixtures will be fed into this effort. Work to character-
ize the major sources of air toxics and identify new candidates
for regulation will take place regardless of competing demands
for chemical-by-chemical review during FY 1986.
Outside of the Clean Air Act itself, the Agency will estab-
lish standards under §3004(n) of the Resource Conservation and
Recovery Act (RCRA) for air emissions from hazardous waste
treatment, storage, and disposal facilities (TSDFs). Table l
presents a list of major air-toxic regulatory actions currently
underway and planned for stationary sources. EPA is also consid-
ering use of TSCA to control air exposures for a variety of sub-
stances, including asbestos and methylene chloride. Table II
lists some actual and potential actions under TSCA and FIFRA
that would have an effect on air toxics.

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TABLE I
Near-Term Regulatory Actions to Control Air Toxics: Stationary Sources
Subject
Listing Decisions
Benzene
Arsenic
Coke Oven
Synthetic Organic Chemical
Manufacturing Industries
(NSPS)
Treatment Storage and
Disposal Facilities
Woodstoves
Source Category
20 hazardous compounds
Coke oven by-products
Copper smelters and glass
manufacturing plants
Wet charging and topside leaks
Reactor gas processes
Volatile organic storage
Air oxidation and distillation
operations
Landfills
Surface Impoundments
Land Treatment
Containers
Waste Piles
Storage Tanks
Transfer Operations
NSPS
Action
Hake decisions
Promulgate
Promulgate
Propose
Propose
Promulgate
Promulgate
Propose
Propose
Propose
Propose
Propose
Propose
Propose
Propose
Date
December 198 5
March 1986
October 198 5
January 1986
July 1985
September 1985
February 1986
hay 19 87
May 1987
May 1987
May 1987
May 1987
May 1987
May 1987
January 1987
Longer-Term Regulatory Actions to Control Air Toxics
Regulatory Actions	Propose	1988 and later
Stemming from 1985
Intent-to-List Decisions

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TABLE II
Decisions In Other Program Areas That May Have Implications For Air Toxics
Subject
Asbestos
1, 3-butadine
Methylene Chloride
Formaldehyde
Maleic Anhydride
Toluene Diisocyanate
Methylene Diphenyliso-
cyanate
Naptha Solvents
Epoxy Resins
Asbestiform Fibers
Carbon Tetrachloride
Termiticides
Wood Perservatives
Source Category
Commercial Products
Manufacturing
Manufacturing and Use
Use in Apparal Manufacturing
and Construction Products
Manufacturing and Processing
Manufacturing and Processing
Manufacturing and Processing
Manufacturing, Processing and Use
Manufacturing, Processing and Use
Manufacturing, Processing and Use
Pesticidal Use
Pesticidal Use
Pesticidal Use
Action
TSCA S6 or §9
TSCA §9
TSCA §6 or S9
TSCA §6 or §9
TSCA §6 or §9
TSCA §6 or §9
TSCA §6 or §9
TSCA §6 or §9
TSCA §6 or §9
TSCA §4, §6 or §9
Agency stops sale
and use
FIFRA
FIFRA
(under adjudicatory
review)
Date
FY 85
FY 85
FY 85
FY 86
FY 86
FY 86
FY 86
FY 87
FY 87
FY 87
December 1985
FY 87
FY 87

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2. Regulate Mobile Sources of the Most Hazardous Air Toxics
Vehicle emissions account for a significant portion of the
air-toxics loadings in urban areas. Historically, motor vehi-
cles have contributed a substantial part of the inventory of
lead, EDB, diesel particulates, benzene, various polycyclic
organic matter (POM) compounds, and other toxic pollutants.
In the past these emissions have been considered separately
from the Agency's air-toxics programs. In the future EPA
will administer both the stationary and mobile-source control
programs related to toxic emissions as two portions of an
integrated air-toxics program.
A number of activities to reduce the risk from mobile-source
toxics are in progress. Besides the lead-reduction rules des-
cribed earlier, beginning in 1985, standards to control evapora-
tive hydrocarbons (including toxic components) become effective
for heavy-duty trucks. Particulate emission standards have
been enacted for light and heavy-duty vehicles. Beginning in
1987, light-duty vehicles will meet standards based on new
technology called trap-oxidizer technology. Heavy-duty engines
will also be required to meet trap-based standards in 1991
(with interim standards in 1988). These standards, expected
to reduce the risk from diesel particulates by as much as 400
incidences o£ cancer annually, will require close monitoring
of technological development and fuel quality.

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Other measures to reduce the risk from mobile-source toxics
are planned. In the near future EPA will consider controls of
gasoline vapors (including benzene) emitted during vehicle
refueling, as well as controls related to fuel volatility due
to high levels of in-use evaporative emissions. The Agency
will also propose standards for health-effects testing of
fuels and fuel additives, and consider action to control the
quality of diesel fuel as a way of insuring the effectiveness
of diesel particulate controls. We will also propose standards
for methanol-fueled vehicles. Table III lists planned mobile-
source regulatory actions that will affect air toxics.
State Air-Toxics Control Programs
The air-toxics problem involves not only problems of
national concern but also localized problems, which may be
best evaluated and controlled by State and local air pollution
agencies. Many States have recognized this fact and have
initiated State-run air-toxics efforts. Several local agencies
also have active programs. EPA considers it essential to
strengthen these State and local programs in order to allow
the fullest possible concentration of effort on all aspects of
the national air-toxics control effort.

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ACTION STEPS
1.	Build State Air-Toxics Programs
EPA is now in the process of negotiating air program grant
awards for FY 1986. EPA will set aside funds within the amount
appropriated for State program support, with the goal that all
States have an operating program for air-toxics control by the
end of FY 1986. EPA will assign an additional $3 million from
other areas in FY 1986 to assist the States as they initiate
or expand this effort, especially to build the data bases they
need to make reasonable regulatory decisions. Working with
selected States, EPA will design a model State air-toxics pro-
gram to guide all States as they develop air-toxics strategies
of their own, tailored to the problems of each jurisdiction.
2.	Referral of Air Toxic Problems of Local Concern
EPA will initiate a Federal/State/local partnership under
which States will evaluate and, if appropriate, regulate large
point sources not amenable to national regulation. States are
in a unique position to deal with problems caused by individual
plants or sources—problems that are not so prevalent as to be
of national scope, but that nevertheless may account for small
areas of high risk in some communities. A State-led examination
of a specific toxics problem on a site-by-site basis can reflect
such locally unique factors as: the actual emissions of the
specific plant, control technology suitable to that specific
plant, and meteorology and population patterns that influence
the degree of exposure of people to the pollutants.

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Near-Term Regulatory Actions to Control
Subject	Source Category
Lead	Refiners/Vehicles
Evaporative Vehicle	Vehicles/Fuels
Emissions (Fuel
Volatility)
Vehicle Fuels and Fuel	Vehicles/Fuels
Diesel Particulates	Vehicles/Fuels
Methanol Vehicle Emission Vehicles
Standards
Vehicle Refueling	Service Stations/
Vehicles
TABLE III
Air Toxics: Mobile Sources
Action
Implement phasedown
Decide ban
ANPRM
Implement evaporative HC
standards for trucks
ANPRM on Testing protocols
Apply car and light
truck standards
Apply heavy truck
standards
ANPRM on diesel fuel
quality
Propose
Decision on controls
Date
July 1985
January 1986
July 1986
September 1985
1985 Model Year
August 1987
1987	Model Year
1988	Model Year
August 1987
September 1985
November 19 85

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EPA is now negotiating the operational details of a "State
Referral" program with State and local agencies. We expect
to complete these negotiations in the next several months. By
early 1986 EPA will identify the first group of pollutants and
source categories to be referred for evaluation by States.
To support these referrals, EPA will make available to specific
States additional financial support (about $1.5 million) and
extensive technical guidance, including information on health
effects, emissions, and exposures with regard to the referred
pollutants and source-categories. States and local agencies
will be expected to evaluate the sources identified in the
program and to control them, if needed. EPA will audit State
activities and provide public information on pollutants refer-
red and State decisions. In order to foster consistency, EPA
may prescribe minimum responses in certain situations, such as
for new sources and in interstate areas. This program will
build on our continuing experience with the pilot acrylonitrile
control project (see p. 10).
3. Inaugurate the Air-Toxics Information Clearinghouse
EPA will soon begin operating the Air-Toxics Information
Clearinghouse, which will facilitate exchange of information
on air toxics among State and local air agencies and provide
those agencies with references to other sources of related
information. The Clearinghouse will be accessible to State
and local agencies by computer link-up.

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Develop Multi-Media Methods To Control Toxic Pollutants
EPA's concern with air toxics must increasingly take into
account comparative risks in other media. For this reason, part
of our overall air-toxics program must include intensive examina-
tion of the cross-media implication of air-toxics controls.
EPA is already putting existing knowledge to work to support
States in practical ways. For instance, EPA has just agreed to
support the State of West Virginia as it seeks to determine
health risks in the Kanawha Valley, where methyl isocyanate
(MIC) is manufactured, and where numerous other chemical
processess are located. EPA's Region III will be supporting
cooperative efforts by State officials and a private organiza-
tion representing community interests to monitor air, water,
and land sites in the Valley for the presence of toxic pollu-
tants. While providing other services, EPA will also help the
State develop an emissions inventory. This will allow West
Virginia to make realistic judgments on the need for further
emissions controls on sources of air toxics in the Kanawha
Valley.
Beyond offering such immediate support to solve current
problems, EPA recognizes the need to consider all pollutants
from all sources; to view air toxics within the context of
pollution loadings in other media; and to obtain as much risk
reduction as possible from a given investment. In undertaking
investigation of multi-media/multi-source issues, we will work

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with States and localities to apply the resources and expertise
of all three levels of government to standard-setting, research,
permitting and enforcement, and the other constituent pieces
of toxic control. We will participate with States and locali-
ties in making the hard decisions that balance environmental
protection on the same scale with the other social goals.
ACTION STEPS
1. Three Area Studies
EPA will undertake three initial projects that will explore
environmental problems in the air and other media. They will
demonstrate the use of locally based multi-media/multi-source
approaches to reach regulatory control decisions in specific
areas. Two of the studies will be extensions of work already
begun in Philadelphia and Baltimore, communities that have
been especially creative in seeking ways to ensure high envir-
onmental quality for their citizens.
The first such project will build on recent work in Phila-
delphia by EPA's Integrated Environmental Management Division
(IEMD). This six-month study will estimate cancer risks from
major air pollutants, and the costs and risk reductions associ-
ated with alternative control options. It will compare options
for tightened standards, and other controls as a basis for dis-
cussions with the City and local industry aimed at selecting
appropriate responses to the problems specific to Philadelphia.

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The second project will build on an IEMD study now under-
way in Baltimore. As in Philadelphia, the Baltimore work
will devise strategies for controlling local air toxics.
Because EPA has been working closely with Maryland and Baltimore
officials throughout the project, we expect the state to be in
a position to implement controls where appropriate and as
information becomes available. This work will last 18 months.
A third project, scheduled over thirty months, will entail a
multi-media assessment of local environmental releases in an
area yet to be chosen.
2.	Conduct Detailed Studies of Personal Exposure
To broaden and deepen the knowledge gained from these
three initial studies, EP\ will conduct a personal-exposure
study. This study would use total exposure assessment method-
ologies (referred to as TEAM) and the Toxics Air Monitoring
System (TAMS) to assess total personal exposure to pollutants
in air and water. The TEAM and TAMS studies will tie together
estimates of emissions, ambient levels, and exposures in a
single, integrated analysis.
3.	Priority Screening of Geographic Areas
As a complement to these pilot projects, CPA will examine
the geographic distribution of air-toxics problems across the
country. EPA will screen areas on the basis of estimated risk
to determine where the Agency should conduct further site-
specific analyses. Available data will not support quantitative
risk assessment on such a scale. Therefore, we will use surrogate

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22
values for toxic exposure (e.g., monitoring and emissions data
for hydrocarbons and total particulates# combined with data on
population distribution). The method will be approximate,
rather than precise, but it should be useful for identifying
locations for "high-payoff" examination.
4. Support Multi-Media Decision-Making By States
EPA is committed to help build State capacity to analyze,
make decisions, and mount effective multi-media control programs.
Recently, EPA awarded grants to several State governments to
fund cross-media priority-setting exercises at the State level.
Participation by industry and public interest groups is an impor-
tant component of these State initiatives, as is the attemot to
build better working relationships among the various levels of
government. EPA will continue to work with States to assess
risks and costs from multiple pollutants and across media as we
continue to devise more efficient and effective intergovernmental
pollution-control programs.
IV. Sudden, Accidental Releases: Programs in Place
The other side of the air-toxics problem is the need to
protect the public from the immediate and lingering health
effects of a sudden, accidental release of acutely toxic
chemicals. Federal Agencies such as OSHA and DOT have rules
affecting accident prevention in the workplace and during
transit. By and large, however, the Federal role—under the

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23
overall coordination of the National Response Team, which includes
EPA, the Coast Guard, FEMA, DOT and other agencies with emergency
authorities — emphasizes preparing the public to safeguard
itself from the consequences of any accident, and responding
to emergencies as they arise.
Accident Prevention
Although EPA does not play a central role in chemical acci-
dent prevention, the Agency's programs probably have an ancillary
effect on reducing the incidence of sudden, hazardous releases.
For example, under TSCA, EPA evaluates the hazards of chemical
products and intermediates, and restricts or imposes controls
on market entry, manufacture, and use of chemicals that present
unreasonable risks. To strengthen this key chemical-regulatory
program, EPA recently proposed a rule that would require manu-
facturers and importers of substances on the TSCA Chemical
Substances Inventory to report current data on the production
volume, plant site, and site-limited status of each substance.
Besides this, compliance with emission standards under the
Clean Air Act reinforces the integrity of systems designed to
limit routine chemical releases to the atmosohere, and thereby
reduces the likelihood of an accidental release.
One of the most important authorities is the set of require-
ments under CERCLA governing Reportable Quantities (RQ). These
rules, recently toughened, serve a dual function. In the first
case, they serve notice to each chemical firm as to the level
of release at which public authorities will involve themselves

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24
in a firm's operations. This exerts pressure on firms to
avoid accidental releases as far as possible, to ensure the
availability of emergency response facilities, and to under-
take such response when needed. Second, public records built
on reports made under RQ rules provide a basis for disciplined
oversight of firms whose performance suggests sloppy practices.
The CERCLA RQ function provides information to support various
governmental enforcement options that can discourage unsafe
industrial practices. Beyond this, of course, the RQ program
provides EPA with early notice of releases, so that EPA or
States can take quick action to protect the environment from
preventable further damage.
Under TSCA §8(C) and §8(e) EPA has other mechanisms to
help identify potential problems. TSCA §8(c) requires anyone
who manufactures, processes, or distributes a chemical to keep
records of significant adverse reactions affecting health and
the environment. These reactions can range from eye irritation
to fish kills to chronic disease, and can be reported by an
individual, whether or not employed by the firm. While these
reports are primarily anecdotal in nature, they often serve as
the basis for further investigations, which may yield new
information on the toxicity of a chemical.
TSCA §8(e) requires firms to notify EPA of any new infor-
mation that a substance presents a substantial risk of injury.
These notices can supplement information obtained under HQ's.
The §8(e) notices serve as the basis for other investigations

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25
by EPA, and are distributed to other Federal agencies, chemical
manufacturers, and users. As a result of information reported
in this way, firms often take voluntary actions to mitigate
potential exposures, such as changing formulations or processes,
or reducing exposure to the chemical. In some cases firms have
simply withdrawn the chemical from the situation of concern.
Programs of other Federal agencies are also relevant in
this regard. For instance, OSHA sets Threshold Limit Values,
or maximum ambient concentrations in the workplace, for chem-
icals of concern and requires a variety of safety measures to
protect workers from exposure to chemical releases. Worker
Right to Know requirements will soon exert pressure on firms
to inform and protect employees against potential dangers.
DOT requires appropriate hazard labeling and regulates trans-
portation of chemicals with acute hazardous characteristics.
DOT requirements include proper classification of materials,
shipping papers, markings on packages, and safety features and
precautions for transport vehicles.
States and localities also contribute in some measure
to chemical accident prevention. Most localities have zoning
ordinances, building codes, and fire codes. Some States
impose annual inspection and certification requirements for
such sensitive equipment as pressure vessels.

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26
Much of the capacity in place to prevent sudden accidental
releases of acutely toxic chemicals is the product of cornorate
self-interest. Fear of a major liability suit, with its impli-
cations for corporate profitability and future insurability,
is undeniably a powerful incentive to promote safe operations
within the chemical industry. Self-interest motivates corporate
prevention of smaller accidents as well, since such accidents
lead to process down-time, implying lost production and profit.
Concern for worker safety is another compelling motive for the
installation of accident-control systems.
Further, most firms are cautious about the introduction
of hazardous chemicals to their plants in the first place. The
cost of hazardous-chemical management is an important consider-
ation in comparing the relative efficiency of alternative pro-
cesses. With accident liability a central concern of corporate
management, both safety and efficiency tend to be prominent fac-
tors in decisions on chemical-process design.
Although sophisticated safety systems characterize the
operations of the major firms in the chemical industry, not
every firm shares the safety consciousness of the industry
leaders; implementation of safety systems can vary from firm
to firm, and from plant to plant within a firm.
The task of "lifting the bottom" performance in the field
of chemical safety is a continuous one that must engage various
sectors of society. No simple or single solution is feasible;

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27
we must instead attack on many fronts. Industry associations
are launching new training and information exchange programs;
insurers are taking a much harder look at the risks soecific
plants impose. Professional associations are active. Citizens
associations are taking responsibility to investigate the safe
operations of local chemical facilities. Ml levels of govern-
ment are taking an active role to ensure chemical safety within
their borders.
Some have said an accident on the scope of Bhopal can take
place only if a great many highly unlikely events occur all at
once, or at least in rapid succession. Nevertheless, such a
chain of unlikely events did take place at Bhopal. Because of
safety measures already in place, the likelihood of such an
occurrence is considerably lower here than in a developing
country. However, we can by no means dismiss the possibility.
For that reason, despite all of society's effort to orevent
accidents, we must be well prepared to deal with them if they
occur.
Emergency Preparedness and Response
Although the United States has rarely experienced a truly
catastrophic chemical-release accident, we have in place a na-
tional system to prepare for and respond to any accident that
might happen. It, too, divides responsibility among Federal,
State, local, and private bodies.

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28
The Federal role in emergency preparedness and response
stresses planning, coordination, and technical support to State
and local agencies. Within EPA.' s jurisdiction, CERCLA provides
a mechanism for drawing together Federal response capabilities
and coordinating comprehensive responses to imminent-hazard
situations. The National Contingency Plan (NCP) prescribes
Federal responses to releases into the environment of hazardous
substances that may present an imminent and substantial threat
to human health or welfare.
Under the National Contingency Plan, the National Response
Team (NRT) carries out national planning and response coordination
and serves as the head of a twelve-agency, Federal emergency-
response network. EPA serves as the NRT chair, and the Coast
Guard as vice-chair. For each of the ten Federal regions there
is also a standing Regional Response Team (RRT) comprising
representatives of the NRT agencies, as well as State and
local governments. Either the National or a Regional Response
Team can be activated for emergency response. They marshal
and coordinate Federal funding, equipment, personnel, and
expertise during major incidents.
EPA and the Coast Guard also maintain trained staffs at
both Regional Offices and Coast Guard districts across the
country. These On-Scene Coordinators direct and coordinate
response actions, summoning expertise and resources from
other Federal agencies as well as private contractors.
EPA also provides technical support through an Environmental

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29
Response Team staffed by specially trained scientists and
engineers.
States play a central role in emergency response, respond-
ing to more releases than do EPA and the Coast Guard. Local
authorities are also key to the system. In most cases, in fact,
the first public agencies to respond to a spill or release are
the local fire and police departments.
With respect to chemical accidents, the quickest (and, for
that reason, most crucial) type of emergency response is that
handled by the chemical firms themselves. Many emergency-
response mechanisms are automatic, such as sprinkler systems
or foam-release mechanisms, and automatic evacuation alarms or
sirens. Many firms, too, set up internal facilities (including,
in many cases, full-scale fire-fighting apparatus) and procedures
that go into effect in the event of an emergency. Each employee
is trained in the event of an emergency, has an assigned station
and function, and can perform interchangeable functions as
needed. Often, a number of neighboring industrial facilities
organize themselves to provide mutual help in the event of a
particularly serious emergency.
The systems in place in the United States to ensure chemi-
cal accident prevention, as well as emergency preparedness and
response, are substantial and, on the record, largely effective.
Nevertheless, they are far from perfect, and in the aftermath
of Bhopal, it is appropriate to reexamine and, Where necessary,
beinfobce dhem, cince they represent a major element of our

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30
national program to protect the public from air toxica. This
reinforcement of the existing systems will be accomplished
through the steps outlined below.
V. Sudden, Accidental Releases: Needed Actions
The Bhopal calamity has had a profound effect on the Ameri-
can chemical industry. Since December 1984 many firms that
have long concerned themselves with safety have increased their
efforts to prevent, prepare for, and respond to accidental chem-
ical releases, a fact that EPA has acknowledged in making our
own plans to promote better emergency preparedness.
For example, the Hazardous Materials Advisory Council
(HMAC) is surveying the chemical industry to assess the state
of emergency response preparedness and contingency planning
and coordination with the public sector. The Chemical Manufac-
turers Association (CMA) has begun the Community Awareness and
Emergency Response (CAER) program to establish or renew community
emergency response plans and communications networks. CMA has
also established the Chemical Response and Information Center
(CRIC) to coordinate responses to requests for information on
chemicals and train non-industry emergency personnel at the
local level. Also, the American Institute of Chemical Engineers
has established a Center for Chemical Plant Safety (CCPS)
to address four issues * hazardous evaluation procedures, bulk
storage and handling of toxic or reactive materials, plant
operating procedures, and safety training.

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31
Parallel with these private initiatives, EPA has begun dis-
cussions with representatives of several labor unions, regarding
joint activity in information dissemination and worker safety
training. Through these means, we expect a substantial number
of workers to become trained in the hazards of toxic chemicals.
There are, however, still further actions needed to forge an
appropriate and comprehensive approach to enhance the nation's
preparedness and ability to respond to environmental emergencies.
The first two actions deal with better planning and coordination
of existing activities? the last three involve a significant
acceleration of ongoing efforts as well as some altogether new
activities.
ACTION STEPS
1. Improve State and Local Capabilities for Emergency Prepared-
ness and Response
Emergency preparedness and response begin at the local
level, Where the initial reaction to an incident takes place.
EPA intends to build State and local capabilities of such
quality that the Federal government need respond directly
only in extraordinary circumstances for whidi State and local
authorities are inadequately equipped or ineffective in their
response. EPA is dedicating 20 workyears on its Regional
staff to enhance emergency preparedness and response at the
Federal, State, and local levels.

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32
With the support and encouragement of many States, EPA's
Regions are offering a variety of services to help orepare
States and localities anticipate and respond to incidents,
including:
o Guidance on suggested standards for contingency planning;
o Technical assistance in the development of contingency
plans themselves;
o Guidance on how to test contingency plans through exer-
cises built around field simulations of hazardous
releases; and
o Coordination and delivery of increased training for
State personnel.
2. Improve Federal Coordination for Emergency Preparedness
and Response
Within its Office of Solid Waste and 'Emergency Response,
EPA will assign a central staff to coordinate EPA policy on
emergency preparedness, as well as response to major emergencies
with the various national program and Regional offices and with
other Federal agencies involved. The Office will serve as a
central point for information gathering and dissemination, and
to facilitate immediate decision-making when warranted.
To support Federal emergency planning, EPA's Office of
Emergency and Remedial Response is analyzing the notification
data bases of the National Response Center (NRC)y the Hazardous
Materials Information Reporting System (HMIR) of the Department

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33
of Transportation; the Pollution Incident Reporting System
(PIRS) of the U.S. Coast Guard, and other Federal and State
information sources. This analysis seeks patterns and trends
in incidents reported in 1933-84. The results will be used bv
both the National and Regional Response Teams to direct Federal
assistance to those areas with the greatest incidence of release.
3. Step Up Enforcement of Chemical-Hazard Notification
EPA is undertaking more vigorous enforcement against those
who fail to report under CERCLA Reportable Quantities regulations.
OSWER will also work with the Criminal Enforcement Office of the
National Enforcement Information Center (NEIC) and the Criminal
Division of the Department of Justice to develoo criteria for
identifying violations that call for criminal enforcement. EPA's
Headquarters Office o£ Solid Waste and Emergency Response, and
the Regional civil enforcement and removal programs, will assist
in the preliminary screening of releases to identify potential
violations that merit further investigation.
EPA has also proposed to Congress amendments to CERCLA that
would toucfhen criminal penalties and for the first time provide
civil penalties for notification violations. Under EPA's
proposal the Agency could impose civil penalties through an
administrative process without the delay occasioned by the need
to involve the Department of Justice or the United States
Attorney. In situations where Reportable Quantities notifications
reveal a pattern of suspected chemical mishandling, EPA will
also consider joining with other Federal agencies and affected

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34
States to inspect plants with apparent safety problems. EPA
is also requesting authority from the Congress under Superfund
to respond to a spill of a substance with hazardous characteris-
tics, even when the substance is not officially listed as a
solid waste.
Similarly, under TSCA, EPA is stepping up implementation
and enforcement of its §8(c) and §8(e) programs. The Agency
is placing increased emphasis on monitoring compliance in this
area during FY 1985 and will further strengthen this program
in FY 1986. EPA has directed its Regions to conduct §8(c)
inspections in conjunction with other TSCA manufacture inspec-
tions this fiscal year. Improved inspection guidance and
inspector-training programs are also under development. In
instances when companies keep indadequate records or fail to
maintain required records, the Agency may take criminal or
civil adminstrative action under TSCA.
EPA also conducts a compliance monitoring program to ensure
compliance with §8(e) notification requirements, and may initiate
criminal or civil administrative actions where violations are
found. To date, the emphasis under §8(e) has been on follow-uo
to "tips" and other complaints. The Agency is reemphasizing
routine §8(e) inspections, particularly in conjuction with §8(c)
inspections, where records on significant adverse reactions
may trigger reporting under §8(c).

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35
4. Issue An Acute-Hazards List
EPA has begun to develop a list of those chemicals that
could lead to accidents resulting in serious acute exposures
threatening human life and health. Most existing lists are
based on*criteria other than those that would indicate the
potential for dispersion of toxic chemicals. They are often
unacceptably narrow, too, in that they do not include all
chemicals of potential concern, such as process intermediates.
EPA's new list will represent EPA's advice to the oublic as to
which chemicals warrant special attention. It will be modified
and amended as further experience presents new and useful data.
Upon completion of the list in late summer, EPA will take the
following specific actions:
o Provide the list to State and local governments, industry,
public interest groups, and emergency and medical officials*
o Develop and supply guidance in the use of the list to
appropriate State and local officials and organizations
as a focal point for contingency planning;
o Supplement the written guidance with workshops, training
programs, and technical assistance through Agency staff
and the Regional Response Teams.
EPA will also review the Reportable Quantities regulation and
revise it as appropriate to be consistent with this list.

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36
5. Advance Efforts to Develop a Community Right to Know Program
The interest in local emergency preparedness and response
has led to several proposals for Community Right to Know legis-
lation. EPA endorses in principle the need for a program in
which chemical firms disclose certain information to communities
about hazardous substances on-site, although it is as yet unclear
how such a program should be structured. However, when fully
developed, such a program would serve as an important basis
for realistic emergency planning at the local level.
The Acute-Hazards List will prove useful in this regard.
To the extent possible, EPA will provide data about listed
chemicals to appropriate officials, including whatever may be
known regarding their location. Although it will be the respon-
sibility of individual communities, working together with
industry, to determine the presence of these chemicals locally,
EPA will respond to inquiries as to the risks they may present
and the proper level of contingency planning to be undertaken.
VI. Conclusion
From the vantage point of the eighties, the challenge of
air toxics seems complex, as did the problem of conventional
pollutants from the perspective of 1970. But this problem, like
the more traditional form of pollution, can be substantially
reduced by a similar application of national will and cooperation.

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37
The enactment by Congress of the toxics-control laws of
the seventies has led to fundamental change in the nature
of environmental action at the national level. Through the
administration of these statutes, we have learned some essential
lessons:
o The need for priorities. Toxic substances are an intrin-
sic component of modern life. Since it is not feasible
to eliminate them entirely we must instead target our
efforts to treat or remove those substances that can be
effectively controlled and that are responsible for the
greatest human harm.
o The need to account for crosa-media transfer. Removing
a substance from the air may be fruitless if it is
merely shifted to land or water, and vice-versa. We
must consider all media, even as we concentrate on one.
o The need to use the right tools* Rote application
of a single program authority will not solve the prob-
lem. We must consider all the tools available and
select the appropriate combination .to deal with* a situ-
ation as complex as that posed by environmental toxics.
o The need to involve States and localities appropriately.
States have a better understanding of locally significant
problems than does a national agency. We need to divide
the labor with States and localities so that each level
of government is able to make its unique contribution.

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SPECIFIC ACTIONS AND INITIATIVES TO
REDUCE RISKS FRCM AIRBORNE TOXICS
The following list indicates actions and initiatives discussed above and
provides time-frames for accomplishing the work. Please consult the text of the
Strategy at the page cited for a more specific reference.
Approximate date of:
initiation completion page
New and Expanded Actions to Control Air Toxics	11
o Routine Releases: National Regulation	12
1.	Regulate Stationary Sources of Multiple
Toxic Pollutants
-	Complete decisions on 20-25	Underway Dec. 1985
specific pollutants.
-	Assess and regulate where appropriate
on a source-category basis:
—	ccke oven emissions
o listing action 	 FY 1934
o NESHflP proposed		 5Y 1986
O NESHAP issued 	 FY 1987
-	Regulate source categories emitting
multiple pollutants using New Source
Perforrrance Standards:
—	synthetic organic chemicals industry	Underway FY 1985 &
(4 source categories) FY 1996
—	residential woodstoves	FY 1985 FY 1988
-	Complete review of need for and if needed. Underway FY 1986
appropriate regulatory mechanism for
regulating gasoline marketing.
-	Establish RCRA standards for air emissions FT 1984 FY 1988
from hazardous waste treatment, storage
and disposal facilities.
2.	Regulate Mobile Sources at the Most Hazardous	15
Air Toxios
-	implement standards for:
—	evaporative hydrocarbons fran trucks	Underway FY 1985
—	particulate emissions Aran li$it ughicles Underway FY 1987
—	BWlfcW&ate emissions frcm heavy duty	Underway FY 1988

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38
o The need to protect against immediate hazards. Long-term
risk from cancer is the natural focus of a public health
agency, but immediate hazards from a sudden release of acute
toxics demand rigorous attention as well.
EPA has developed a comprehensive program for air toxics
which originates with a revised understanding of the nature
and source of the air-toxics problem and which draws on these
essential lessons. As we learn more about this problem, we
will, of necessity, adjust our strategy. In the meantime,
however, 13PA is committed to vigorously implement the most
effective approaches of the past, while immediately initiating
the new activities identified in this report.
EPA solicits the support of the American public, State and
local governments, industry, and the Congress as we work to deal
effectively with the air-toxics problem. By doing so we can
all fulfill our demonstrated national commitment to protect
the public health and the environment for all Americans.

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-2-
o Routine Releases: National Regulation (cont'd)
Approximate date of:
initiation conpletion page
15
2. Regulate Mobile Sources of the Most Hazardous
Mr Toxics (cont'd)



- continue review of appropriateness of a
total ]jan on lead in gasoline
Ongoing
NT.A.
- consider controls on:



-- Mahicle refueling
FY
1986
N. A.
— fuel volatility
FY
1985
NT. A.
— dLesel fuel quality
Fir
1987
N.A.
- propose standards for health effects testing of
fuel and fuel additives
FY
1987
FY 1988
- propose standards for methanol-fueled vehicles
FY
1985
FY 1986
3. Perform Studies to Support Future Regulation
of Sources of Multiple Toxic Air Pollutants



- perform a study to ascertain
which source categories are mitting
FY
1985
FY 1986
se\«ral pollutants of concern.
o Routine Releases: State Control Programs	16
1.	Build State Air-Toxics Programs	17
-	Set aside funds within State program support
grants for support of State air toxics urograms. Ongoing BY 1986
-	Set aside $3 million fran other areas to assist FY 1985 FY 1986
States as they initiate this effort.
-	Design a model State-level air-toxics program. FY 1985 FY 1986
-	Establish a carputerized Air Toxics I nib runt ion FY 1984 FY 1985
Clearinghouse with direct State access.
2.	Prorate State Control of Air-Toxics Problem of	17
Local Concern
-	Negotiate the form of this cooperative	FY 1985 FY 1985
Federal/state/local program with the States.
-	Identify first group of pollutants and source FY 1985 FY 1986
categories to be referred for State action.

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-3-
ApproxiiTVite date of:
initiation conpletion page
o Routine Releases: State Control Programs (cont'd)
2. Promote State Control of Air-Toxics Problems of
Local Concern (cont'd)
-	Provide financial support to States [to do
necessary assessments and to establish
control requirements, vtfiere needed].
-	Provide technical guidance including
information on health effects, emissions,
control technology and exposures.
-	State and local agencies evaluate the
sources identified and control them if
necessary.
-	EPA audits State activities.
-	EPA will provide public information on
natters referred and State decisions.
17
FY 1936	Ongoing
FY 1986	Ongoinc?
FY 1986	Ongoing
5Y 1986	Ongoing
FY 1986	Ongoina
o Routine Releases: Intergovernmental, Multi-Media
Regulation of Toxic Pollutants
1. Area projects to explore the use of multi-media
approaches to the assessment and control of toxics
risks.
-	Project #1: Add to the project already	FY 1985 FY 1986
substantially catpleted in Philadelphia by
examining exposures to and risks frcm metals,
organic particulates, and organic gases.
-	Project »2: Add to the project now underway	FY 1985 FY 1987
in Baltimore. This project considers eco-
logical effects as well as health risks
associated with toxic exposure.
-	Project #3: Conduct a new study (in an area	FY 1986 FY 1988
yet to be selected) to examine the effects of
pollution on human health and the envirormerrt
leading to an assessment of cost-effective
controls.
-	Conduct a personal exposure study using	FY 1986 FY 1988
Total Exposure Assessment Methodologies
and the Toxics Air Monitoring system.

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_4_
Approximate (fete of:
Initiation conpletion page
° Rcutine Releases: I ntergoveraniental, Multi-Media
Regulation of Toxic Pollutants (cont'd)
2. Risk-Based Screening of Geographic Areas	21
- Devise methodology for identifying areas	FY 1985 Uncertain
that would be candidates for future site-
specific studies.
3. Adapt Analytic Methods for State Air-Toxics	22
Programs
- Continue to work with States to assess risks	FY 1985 Ongoing
and costs fran multiple pollutants and across
media.
o Sudden, Accidental Releases	22
1. Improve State and local capabilities	31
for emergency preparedness and response.
- Dedicate 20 work years in the Regional	FY 1985 Ongoing
Offices to act through Regions and
RRT to provide the following to States
and localities:
o assistance in the review of	BY 1986 Ongoing
contingency plans,
o coordination and delivery of	FY 1985 Ongoing
training,
o guidance on how to test	FY 1986 Ongoing
contingency plana in the context
of field simulations of hazardous
naterial releases.
- To support the above activities, use the	FY 1985 FY 1986
recent survey of the National Response Team
on the status of emergency preparedness,
contingency planning, training, and
equipment to identify deficiencies in
capability and direct Federal assistance
to State and local governments.

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-5-
APproximate date of:
initiation conpletion page
o Sudden, Accidental Releases (cont'd)
2. Inprove Federal Coordination for Emergency
Preparedness and Response
-	Establish an integrated EPA coordinating	Underway FY 1985
staff to respond to major emergencies
with the various national program and
Regional offices, and with other Federal
agencies.
-	Analyze notification data bases to	FY 1985 FY 1985
identify patterns and trends in incidents
reported in 1983-84, in order to direct
Federal assistance to areas with the
greatest incidence of release.
3. Step up Enforcanent of Chenical Hazard
Notification
33
Step up enforcanent of Reportable
Quantities Notification requirements
using the current statutory provision
for criminal penalties.
— Work with the Department of Justice
to develop criteria for identifying
violations that call for criminal
enforcement.
FY 1985 Ongoing
FY 1985 FY 1986
—	Set up system for preliminary
screening of release incidents to
determine which merit further
inusstigation.
If Congress provides the necessary
statutory authority, establish a
civil enforcanent program.
—	Request authority £ran Congress
for civil enforcement of reportable
quantities violations.
FY 1986 Ongoing
FY 1985 N.A.

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-6-
approximate date o€:
initiation conpletion page
o Sudden, Accidental Releases (cont'd)
3. Step up Enforcement of Chemical Hazard	33
Notification (cont'd)
-	Explore the potential for joining with other	FY 1985 FY 1986
Federal agencies and affected States to
assess plant safety (with regard to the
potential for accidental releases) when
conducting inspections of the plants to
assess compliance with other regulatory
requirements.
-	Request authority fran the Congress under	FY 1985 N.A.
Superfund to respond to spills of substances
with hazardous characteristics which are
not officially listed.
-	Step up enforcement of the requirements
of §8(c) and §8(e) of TSCA.
— Increase emphasis on compliance
monitoring.
—	EPA Regions conduct §8(c)
inspections in conjuction with
other TSCA rrarufacturer inspections.
—	Develop improved inspection
guidance and inspector training
programs.
—	Take dvil or criminal enforcement
action v%here companies fail to
maintain required records or
maintain inadequate records.
—	Increase monitoring for compliance
with §8(e) reporting requirements,
primarily in conjunction with §8(c)
inspections.
fy 1985 Ongoing
FY 1985 strengthen
further in
FY 1986
Ongoing Ongoing
FY 1985 FY 1985
FY 1985 Ongoing
FY 1985 Ongoing

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-7-
APproximate date of:
initiation conpletion pac^
o Sudden, Accidental Releases (cont'd)
4. Issue an Acute-Hazards List	35
-	Develop list which reflects both degree	FY 1985 FY 1985
of hazard of the chanical and likelihood
of release (i.e., due to volatility, etc).
-	Provide the list to State and local
governments, to industry, to public
interest groups and to emergency and
medical officials.
-	Develop and supply guidance on the use
of the list to appropriate State and
local officials and organizations as
a focal point for contingency planning.
-	Supplement the written guidance with
workshops, training programs, and
technical assistance through Agency
staff and the Regional Response Teams.
-	Review the Reportable Quantities
regulation and revise it as appropriate
to be consistent with the list.
-	Use the list to support current and
future canmuiity ricfit-to-knaw programs.
FY 1985	Ongoing
FY 1985	FY 1986
FY 1986	Ongoing
FY 1986	Ongoing
FY 1985	Ongoing

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Statement of
Lee M. Thomas
Administrator
U.S. Environmental Protection Agency
before the
Subcommittee on Health and the Environment
Committee on Energy and Commerce
United States House of Representatives
June 11, 19bb

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STATEMENT OF
LEE M. THOMAS
ADMINISTRATOR
U.S. ENVIRONMENTAL PROTECTION AGLNCY
BEFORE THE
SUBCOMMITTEE ON HEALTH AND THE ENVIRONMENT
COMMITTEE ON ENERGY AND COMMERCE
UNITED STATES HOUSE OF REPRESENTATIVES
JUNE 11, 1985
Mr. Chairman, Members of the Subcommittee:
Thank you for giving me the opportunity to discuss with
you the action strategy being implemented by the Environmental
Protection Agency to reduce health risks to the public from
exposure to airborne pollutants.
I know that the members of this Subcommittee have directed
considerable attention to the issue of toxic air pollution, and
I assure you that EPA has as well. Indeed, since my confirmation
as Administrator, the Agency has initiated a number of activities
that have resulted in a major expansion and redirection of the
its activities with regard to air toxics.
Last week, I provided each member of'this Subcommittee with
a copy of a major air toxics strategy document prepared under
my direction. This strategy sets forth a greatly expanded and
significantly redirected federal program for the regulation of
toxic air pollutants. It also calls for significant Federal
support to state air toxic programs. I would like to describe
the specifics of that stategy for you this morning.
My view of the air toxics problem in the United States is
that air toxics can present significant risks to the public
health, and that the problem is widespread enough to demand
aggressive but appropriate action on EPA's part. The strategy

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to be implemented by the Agency includes the following actions
which are designed to reduce the public exposure to air toxics,
both from routine releases and from accidental releases:
o An expanded and redirected air-toxics control program
for problems of national scope;
o A new Federal program to strengthen and improve State
capability to deal with air toxics;
o An expanded effort to devise strategies to reduce risks
from multi-media/multi-source pollutants in specific
localities where problems may exist;
o Reinforcement of emergency preparedness and response
capability at all levels of government; and
o Three new or accelerated actions to provide additional
tools for public authorities to prevent, prepare for,
and respond to accidental releases that might occur.
The Nature of the Problem
Although emissions of air toxics from the normal operation
of a modern economy (routine releases) are a cause of serious
concern, ambient levels of these substances appear to account
for a relatively small portion of the national incidence of cancer.
As a result, plants routinely emitting low levels of air toxics do
not necessarily pose a significant public health risk. In order
to use our regulatory resources most effectively, we must identify
those substances and source-categories that are associated with the
greatest health risk. Further, we must be practical and creative
in our selection of authorities under which to control them.
In the case of sudden, accidental releases, we must ensure
that, to the extent possible, we continue to minimize the harm

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-3-
from such incidents. Although releases of varying severity
occur often in the United States, major accidents involving
serious injury and loss of life are uncommon. It is important to
note that the chemical industry, one of the most potentially
dangerous in the Nation, has often ranked first in the National
Safety Council's rating of workplace safety. In addition to
public and governmental pressure, a major reason seems to be
industry's own self-interest in preventing and controlling hazar-
dous releases, due in large part to concern for liability in
the event of a major accident. EPA must reinforce that private
self-interest in order to promote chemical-industry safety,
while aggressively building public-sector capabilities to pre-
pare for and respond to environmental emergencies.
Routine Releases: Programs in Place
EPA has reviewed the nature of routine air toxics releases
and has come to four major conclusions, based both on analytical
work performed by the Agency as well as discussions with many
outside parties. First, air toxics are created by all the
activities of a modern society—from the use of motor vehicles, to
burning fossil fuel, to producing and using industrial chemicals.
Second, air toxics present a significant risk, one that calls
for an aggressive and measured response. Third, there is
remarkable variation in risks from place to place. And fourth,
controls in place have made and are making significant inroads
in the problem. Yet new and expanded efforts by EPA are appropriate
EPA's review of the air-toxics problem indicates that
existing State and EPA controls on mobile and stationary sources
have already reduced toxic exposures to a certain extent.

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For example, controls for particulate matter, imposed under
State Implementation Plans, frequently reduce toxic metals by
80 to 98 percent. In 1986 alone, mobile-source standards for
lead will prevent 172,000 children from exceeding the blood
level of concern set by the Centers for Disease Control.
Actions taken under other environmental statutes provide still
further benefits.
However, further action is required in completing regula-
tions under these authorities and in expanding the universe of
sources covered. Use of §112 of the Clean Air Act to control
individual pollutant/source categories on a national basis can
no longer be viewed as our sole tactic against air toxics. We have
expanded the number of regulatory tools we use at the Federal
level in order to maximize our effectiveness in dealing with
multiple pollutants from individual point sources. We are also
developing effective approaches for controlling emissions from
area sources—which we now believe contribute significantly
to public health risks—and for addressing areas of locally
elevated risk.
Routine Releases: Needed Actions
EPA's action strategy for routine releases covers three main
areas: national regulation, expanding and enhancing State programs,
and developing multi-media methods to control toxic pollutants.
National Regulation. EPA will complete its existing
commitment to Congress to consider 20-25 chemicals for regula-
tion under §112 of the Clean Air Act, and continue to use the
listing and development of NESHAPS under §112 to address individual

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-5-
toxic chemicals for which there are source categories causing
significant aggregate risk. We will also regulate entire
emissions streams under SI12 when not one, but a complex
combination of toxic chemicals is being emitted. We have
already used this approach in listing coke oven emissions.
In addition, we are aggressively employing other regulatory
mechanisms. Among these are;
o Use of Sill (New Source Performance Standards) to control
classes of area sources such as wood stoves, and the
synthetic organic chemical industry.
o Use of various authorities under Title II of the Clean Air
Act to set standards for motor vehicles and fuels to
address the significant risks resulting from their use.
We will place special emphasis on the emission of
toxic particulates by diesel-powered vehicles and evaporative
hydrocarbon losses. Our program to reduce such losses
will significantly reduce exposure to benzene and
other hazardous substances.
o Reduction of evaporative losses from sewage treatment
plants - which can be a serious source of toxic emissions -
through continued vigorous implementation of pre-treatment
programs for water pollution sources that discharge into
municipal sewers.
o Control of toxic air pollutants from hazardous waste
treatment storage and disposal facilities by setting
strict standards, and restricting wastes from land
disposal under the authority of RCRA.

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Control of other volatile chemicals through vigorous
application of our authorities under TSCA.
In short, we will continue to use §112 in the traditional
way, but at an accelerated pace, for those situations where it
is applicable. At the same time, we will apply §112 in less
traditional ways to address sources of multiple pollutants, we
will also make extensive use of a large number of other authorities
under the Clean Air Act and virtually all of our other statutory
authorities to reduce the risk associated with exposure to air
tfoxics.
Building State Air-Toxics Programs. In addition to operating an
expanded Federal regulatory program, EPA will also work to
strengthen State capabilities. The principal purpose for building
State programs will be to ensure that States can play the same
vigorous role in enforcing requirements for toxic air pollutants
that they now play for conventional air pollutants. It is clear
that Congress intended States to have a central role in our
national effort to control conventional pollutants as expressed
in the Clean Air Act amendments of 1970. This control effort
has also led to a substantial reduction in air toxics emissions.
I intend to ensure that State and local air pollution agencies
have the technical and financial capability to continue to have
a key role as we begin to increase our efforts to control air
toxics. Our goal in this regard is to to have an effective air
toxics program in every state by the end of FY 1986.

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Another way in which we will work with state and local air
pollution control agencies to reduce public exposures to air
toxics is embodied in our expansion of their capacity for data
collection and assessment. In our assessment of the risks posed
by certain pollutants and source categories, we have observed
situations in which the health effects were not widespread enough
to warrant setting a Federal standard, but in which local risks
of concern were observed at a limited number of facilities. In
these cases, we will provide technical and financial assistance
to the affected state and local agencies for extensive directed
data collection and evaluation of such problems. The Agency is
implementing this approach on a pilot basis with emissions of
acrylonitrile. At present, 14 states are committed to working
with the Agency to evaluate and review regulatory options on
emissions of acrylonitrile from selected facilities within their
jurisdictions.
We are currently in the process of discussing the parameters
of this program with the state and local agencies (that is, what
criteria to be used in selecting a pollutant or source category,
what type of guidance to provide to the agencies by EPA and what
type of control options would be available for the state/local
agencies and EPA) and hope to have many of these parameters
worked out in the near future. Given the proven successful
track record of state/EPA partnerships that has typified the
criteria pollutant program, I feel confident that this initaitive
will be implemented aggressively.
Let me conclude my discussion of the state/local initiative
by noting that the establishment of this program is itself

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-8-
another aspect of the expansion of our national effort to
control air toxics. Under the state/local initiative, EPA will
take a number of strong steps to promote appropriate analysis of
action required to address localized problems that may be caused by
pollutants or sources.
Multi-Media Methods to Control Toxic Pollutants. EPA will
expand its current studies of local toxics problems and will
work more closely with States and localities on how best to
consider multi-media/multi-source interactions in controlling
areas of localized risk. EPA will apply lessons from geographic
investigations and personal monitoring studies to develop procedures
for integrated environmental management.
Sudden, Accidental Releases: Programs in Place
With regard to accidental releases, there is an informal
but workable division of activity in effect between the private and
public sectors. Much of the capability in place to prevent
accidents is the product of corporate self-interest. Additionally,
while some Federal controls tend to promote accident prevention,
the role of government centers on technical information sharing,
guidance, and emergency preparedness and response.
One of the most important Federal authorities for emergency
preparedness and response is the reportable quantities provision
under the Comprehensive Environmental Response, Compensation, and
Liability Act (Superfund). This set of rules, which requires a
release of specified amounts of identified substances to be
reported by the responsible party, promotes safe chemical handling

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9
and provides EPA and States with needed information in the event of a
release, either to initiate emergency response, or to identify needs
for further emergency preparedness. Other important tools are the
authorities of TSCA, which require record-keeping and reporting of
certain chemical-related hazards that might be observed. Statutes
administered by the Occupational Safety and Health Administration and
the Department of Transportation are directly related to accident
prevention, and like those of DOT's Coast Guard, provide important
authorities for emergency preparedness and response as well. As
for States and localities, they are almost always the first to
respond to a spill or release.
Also in place is the National and Regional Response Team mechanism.
The National Response Team (NRT), which EPA chairs with the Coast
Guard as vice-chair, includes among its membership representatives
from every Federal agency having, significant hazardous substance
emergency preparedness and response authorities and responsibilities;
its Regional component, the Regional Response Teams includes the same
Federal agencies plus representation from State and local governments as
well. A preparedness committee has been established and a national
assessment of state/local emergency preparedness capability is
currently being conducted. The National Contingency Plan, originally
designed in the 1960's around oil spill issues, was thoroughly
revised after Superfund was passed in 1980 and has just undergone
a major revision which strengthens it in the essential areas of
coordination, planning and response.

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10
Sudden, Accidental Release: Needed Actions
There is much concern and activity underway within the chemical
industry itself to evaluate and upgrade its safety systems. While
this is appropriate, EPA believes that it must at the same time
reinforce systems in place for emergency preparedness and response.
EPA is taking a number of steps to enhance State and local
capability for emergency preparedness and response. By adding
to its Regional staff and establishing a headquarters staff
to specifically focus on these efforts, EPA will be able to
offer a number of needed services to States and localities in the
area of contingency planning, technical assistance, training, and
response. EPA is taking strong steps to coordinate and improve
national policy and planning for emergency preparedness and response
through the National Response Team and the National Contingency Plan.
The Environmental Response Team is increasing its training efforts
targeted for State and local authorities and adding staff to increase
its capability of providing technical assistance to States and
local governments in response as well as in planning and preparedness.
The Agency is also taking three major actions to reinforce
existing programs or add new activities. First, EPA will revise
operating guidance, increase resources, and provide expanded staff
training to enforce reportable quantity requirements, as well as
recordkeeping and reporting under TSCA. These actions will pro-
vide the data to assure a prompt response to emergencies and will
also achieve a higher level of comprehensive reporting on spills
and releases upon which to base contingency planning. Where
reports indicate a pattern of chemical mishandling, EPA will join

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11
with other agencies and States to inspect facilities or situations
where chemical practices may be unsafe. The Administration has
also requested that additional civil enforcement authorities be incorpor
ated into the CERCLA statute to provide increased opportunity for
enforcement action on reportable quanity violations.
Second, EPA will advance efforts to develop a Community Right
To-Know program. While the specific structure and details of this
program are still being developed, we believe that such a tool will
prove to be an important basis for realistic, focused contingency
planning at the local level and also assure that the local citizens
have the data necessary to make conscious and informed choices.
Third, EPA will prepare and issue an Acute-Hazards List. This
list will include chemicals which, if involved in an accidental
release, would be most likely to result in serious harm to those
exposed. It will identify substances that are likely to cause
either acute or chronic serious health effects from a short-term,
high level exposure, and which have characteristics such as volatility
and ignitibility which add to the potential for increased human
exposure in the event of an uncontained release.
We decided that a new list was required after our review revealed
that no existing lists are quite on target. Sane lists were either
too broad in that they did not address the potential for rapid
dispersion of a chemical, such as its volatility or others were
too narrow in that they did not include all chemicals of potential
concern in accident situations, such as process intermediates.
The list will be used in several ways. First, it will be
provided to the States and local governments along with guidance
to assist in the development of focused follow-up actions, such as

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12
inspections, audit programs, community awareness programs or in-
creased preparedness and response efforts, which are best undertaken
at the local level.
Second, EPA will use the list to target federal emergency
response and preparedness efforts. Thus, our efforts to increase
technical assistance to States and local communities in the
areas of contingency planning, training and response will be
focused on those areas where the listed acute hazard chemicals
are handled - stored, processed, formulated or manufactured. It
will also allow site-specific contingency planning to be accomplished
locally, with Federal technical assistance and guidance, in
dealing with the specific requirements and characteristics of
the community.
Finally, we believe that the chemicals identified in the acute
hazards list should provide the focus for Community Right-to-Know
programs. I believe that, without such a focus, local communities
will not be equipped with the necessary information to make priority-
setting decisions. Without such federal guidance, these communities
may be faced with either so little information as to make effective
action difficult, or so much information as to overwhelm the ability
of the community to evaluate and act on it. Providing a targeted
focused list of chemicals should greatly aid communities in
determining how best to address their specific potential problems.
In conducting our far-ranging review of existing and emerging
programs, we noted several significant principles at work. These
principles characterize the Agency's approach to environmental
protection after fifteen years of experience, and are reflected in
the Agencies strategy to deal with airborne pollutants. They are:

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13
o The need for priorities. We cannot do everything at
once, so we must target our efforts where we can get
the greatest environmental improvement soonest.
o The need to account for cross-media transfer. We cannot
clean the environment by pushing pollutants from one
medium to another. We must consider the effects on all
media, even as we concentrate on one.
o The need to use the right tools. We cannot protect the
environment by rote. We must exercise ingenuity in
developing new ways to apply existing authorities or
combinations of authorities in order to get things done
as effectively and efficiently as possible.
o The need to involve States appropriately. States have a
better grasp on locally significant problems than can any
national Agency. We need to organize work so that each
level of government makes its unique contribution.
o The need to protect against immediate hazards. Long-term
risk from cancer is a natural focus of a public health
agency, but immediate hazards from sudden releases of
chemicals that, by the nature of the release, present other
serious health effects deserve vigorous attention as well.
EPA solicits the support of the American public, State
and local governments, industry, and the Congress as we work
to deal effectively with the air-toxics problem. By doing so
we can all fulfill our demonstrated national commitment to
protect public health and the environment for all Americans.

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14
Mr. Chairman, in your letter of invitation you asked me
to provide the views of the Agency on H.R. 2576, the Toxic
Release Control Act of 1985. While the Agency's assessment of
the bill is preliminary, I believe it is revealing. I would
like to state at the outset that we both share the view that
air toxics pose a serious and difficult problem which must be
addressed. Where we disagree is in our assessment of the
scope of the problem and the magnitude of the program needed
to address it.
The two main concerns we have regarding the effects of this
bill are that it would impose huge costs on society for limited
environmental gains and that it could result in serious environmental
opportunity costs. I am afraid that while the pollution control
community is spending its time and resources on implementing
the vast requirements of H.R. 2576, other real and in some
cases severe environmental problems would receive inadequate
attention.
The range of sources and pollutants likely to be covered by
the bill is enormous. An initial list of 85 substances is
designated as hazardous. Some are carcinogens but not particularly
potent, some are acutely hazardous, some are volatile, some
are not. The same broad-brush remedial measures are assigned
to all of them. In addition, within a year of enactment,
another group of 300-400 substances must be added to the
designated list. Covered under the proposed legislation is
anyone who manufactures, processes, stores, or releases more

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15
than one metric ton in any month of a designated substance
into the air. Someone burning more than ten metric tons in any
month is covered also. Let me cite a few examples of the kind
of sources that we believe would be affected:
o 200,000 public gasoline outlets and perhaps another 200,000
privately owned gasoline tanks owned by taxicab companies,
rental car companies, municipalities, etc.
o 165,000 industrial boilers and possibly over one million
space heating units, e.g. furnaces or boilers in medium-
sized buildings (over 15,000 square feet) that burn
fuel for space heating — a 20-unit apartment building,
a small office building, or a medium-size department store,
o 15,000 dry cleaners.
o 50,000 vapor degreasers that use solvents (most metal
fabrication .and other diverse cleaning operations),
o Diesel engine production (cars, trucks, buses, farm
equipment) could be affected severely,
o About 175,000 commercial pesticide applicators involved
primarily in agricultural applications appear to be
subject to the bill. Almost one million private
certified applicators, mostly farmers, also may be
subject. Cotton and orchard crops would be especially
affected because they require frequent and high
application rates.

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-16-
o Wastewater treatment facilities would be affected.
15,500 municipal and 20,500 industrial treatment
plants could be covered; coverage could be expanded
to include all pump stations, storm water treatment
facilities, vented manholes, and even on-site septic
systems.
o About 7000 municipal wastewater treatment facilities
use chlorine as a disinfectant. Another 8000 municipal
wastewater treatment facilities use aeration in
large open tanks or lagoons as the main secondary
treatment process; these would also be covered.
I have just cited an.incomplete list of sources likely to be
affected. Once an owner or operator comes under the purview
of the bill, he must meet a long list of requirements:
o He must get a permit to operate, build, or modify an
emissions unit.
o He must file a statement describing that year's emissions
of each designated substance from each emissions
unit.
o He must install or use the "best available leak control
devices."
o He must label any pipe, storage tank, or container used
to store, manufacture, or process a designated substance
if there is a reasonable likelihood of a release threatening
health or the environment;

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17
o He must install and use the most stringent controls
achievable. The level must be set based on maximum
technological feasibility. If the standards of control
are not determined by EPA within the time specified,
the standard for that category must be no "detectable
release."
o He must monitor releases from the source, if necessary,
to insure that he is meeting the permit requirements.
Owners of "large sources" must also monitor ambient
air in the affected community to mesure the level of
the substance.
I would now like to turn my attention to the emergency res-
ponse and right-to-know sections of this legislation. Clearly,
these are areas of major concern to us all, and to the extent these
proposals lead to a higher level of preparedness and awareness,
developed and paid for by industry and accomplished by the State
and local governments and its citizens, we are in agreement.
Where we are not in accord is on the methods of getting there.
These proposed provisions require that response plans be prepared
by local industry in coordination with the local community. They also
require enforcement by the Federal government. Further, if the
States do not take action to establish the Emergency Response
Districts, the EPA Administrator must designate the District, and
assume the responsibilities of the emergency response committee
within each of these districts. These would include the obligation
for review and the development of these plans, communicating
their content to the public, exercising the plans and inspecting the
facilities. These site specific actions are clearly the responsibility

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18
of the local community and not a duty the Federal Government should
assume. It is the local community which must understand the issues
and be prepared to meet any contingency since it would be the
first to respond and the most affected by such an emergency. These
observations are quite apart from the enormous Federal resources
such a program would require. We perceive the more appropriate Federal
role as one of providing guidance, technical assistance and training
for development of these plans. In any event, I believe the
details of the emergency response plan ingredients are better left
to policy development by the Agency through the National Contingency
Plan rather than legislation.
On the matter of Community Right-To-Know, I surely share
the view of this legislation that citizens are entitled to a
great deal of information about the potential threats in their
community. To that extent, I support a program which would
result in the sharing of data by industry. Again, it is a matter
of degree. This bill would require enormous amounts of data to be
made available to virtually everyone regarding virtually all
chemicals in the community. This could result in a tremendous
amount of information which, by its sheer mass, could overwhelm
the local communities' capability to manage it. It also establishes
a significant role for the Federal government in the receipt and
maintenance of the information. I suggest that EPA focus more
specifically on those chemicals identified on the acute hazards
list, and assist the community in developing programs around the
sharing of that data and its uses for preparing contingency plans,
identifying proper protection procedures, and advising the
local emergency and medical authorities of the characteristics

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19
of the chemicals and the proper treatment of any citizens who
may become injured. After this initial effort, when the community
will have become organized to deal with the data, and will have
developed priority programs to protect against the most acutely
hazardous chemicals, it could then expand its efforts to include
other items of local interest as well.
In conclusion, while I believe your concern and intent is well-
placed, I fear that enactment of this proposal would have serious
adverse impacts on many parts of our society while important
environmental gains may be sacrificed. In sum, our assessment
of H.R. 2576 is that its implementation would be impossible and
its objectives unattainable. I hope that we can work together
as the Agency learns more about the nature of toxic air pollutants
and moves to address the problems we face. I do believe that
the strategy I have described today is a thoughtful and aggressive
move in the right direction. I will be happy to take your questions.

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