United States Federal Facilities Enforcement EPA 300-B-96-009A
Environmental Protection Office (2261A) May 1996
Asency
Pollution Prevention and
the Clean Air Act:
Benefits and Opportunities
Federal Facilities - Volu
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Table of Contents
Chapter 1 Introduction 1
Chapter 2 The Federal Facility View of the
Clean Air Act 3
Introduction 3
Role Of Operating Permit Program 5
Applicable Requirements 10
Complying With The CAA And Other Environmental Programs 16
Chapter 3 Responding with the P2 Approach .19
Pollution Prevention And The Waste Management
Hierarchy 19
Pollution Prevention Planning 20
True Cost Accounting .24
Life Cycle Analysis 26
Added Benefits Of Pollution Prevention .21
The P2 Approach 28
Appendix A List of Chemicals Regulated Under the Clean Air Act
Appendix B Information Resources
List of Figures
Figure 1 Simplified CAA Activity Diagram 4
Figure 2 Pollution Prevention Program Overview 22
List of Tables
Table 1 Major Source Definition in Nonattainment Areas 6
Table 2 Summary of Major CAA Programs 12
Table 3 Costs and Benefits of Environmental Projects 25
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CHAPTER 1
INTRODUCTION
This is the first of two reports on Clean Air Act pollution prevention opportunities at
Federal facilities. It provides an overview of the Clean Air Act and describes how Federal
facilities can facilitate compliance with the statute by taking advantage of pollution prevention
opportunities. The second report is a two-part document that describes Clean Air Act pollution
prevention opportunities resulting from cleaning and degreasing activities and from painting and
depainting activities.
The generation of waste at the source, i.e., pollution prevention or source reduction, was
established as national policy with the passage of the Pollution Prevention Act in 1990. The
importance of this concept for Federal facilities has been reaffirmed by Executive Order 12856,
"Federal Compliance with Right-to Know Laws and Pollution Prevention Requirements" signed
by the President on August 3,1993. With the expanding programs under the Clean Air Act,
many Federal facilities have the opportunity to utilize pollution prevention techniques in
developing compliance strategies. Reducing air discharges through the use of pollution preven-
tion techniques will also help federal facilities meet the challenge of the pollution prevention
planning goals in Executive Order 12856.
Federal facilities are facing a steady slate of increasing obligations as a result of the
implementation of the Clean Air Act. Since the passage of the 1990 Amendments, the
Environmental Protection Agency and State/local air pollution control agencies have been
working diligently to put in place the regulatory framework required by Act. Many of these
requirements will impact directly on the operations occurring at Federal facilities.
Historically, many Federal facilities have had a somewhat limited focus of Clean Air Act
concerns, typically compliance issues with fuel combustion (boilers) requirements. But now the
scope of attention has been significantly expanded, potentially addressing all Federal facility
operations particularly those relying on chemicals to carry out their functions. Volatile Organic
Compounds (VOCs), Hazardous Air Pollutants (HAPs), and Ozone Depleting Chemicals (ODCs)
are all terms which apply to categories of materials regulated by the Clean Air Act. These
materials may show up in cleaning agents, paints and coatings, fire fighting agents, cooling
systems, and many other areas now subject to the Clean Air Act. Under the Act, States are
developing permit programs to implement these new requirements. These permits will be explicit
contracts with each facility to define compliance expectations for each air pollution source. All
releases'of regulated substances must be accounted for and will be the target for assessment of
annual emission fees under the Act.
Federal facilities are also being asked to develop strategies to reduce their environmental
discharges through pollution prevention. Executive Order 12856 requires Federal agencies to
develop plans to reduce their releases of chemicals reported to the Toxic Release Inventory (TRI)
by more than 50 percent by 1999. To the maximum extent possible, these reductions are to be
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achieved through pollution prevention. Many of the TRI chemicals are the same compounds
regulated by the Clean Air Act. Thus, Federal facilities have the opportunity to focus their
pollution prevention plans on the same chemicals presenting compliance concerns under the Clean
Air Act.
Federal facilities, by investing in source reduction strategies to achieve compliance with
the Clean Air Act, can also minimize future regulatory burdens. Choosing alternative processes
and materials, rather than focusing narrowly on traditional (end-of-pipe) control approaches, can
lead to compliance solutions which decrease reliance on regulated compounds.
This report is intended to provide Federal facility managers with a baseline understanding
of the breadth and scope of programs established under the Clean Air Act, and how Federal
facilities can incoiporate pollution prevention approaches into compliance decision making. In
Chapter 2, the potential Clean Air Act impacts on Federal facilities is described. What are the
different programs? What are their objectives? What materials and operations are affected?
What are the compliance expectations? These are but a few of the questions addressed in Chapter
2. Chapter 3 describes some of the basic concepts which embody a pollution prevention program
and how a more reasoned approach to considering the cost and benefits of control will lead to
greater use of pollution prevention. Appendix A identifies the array of compounds regulated
under the Clean Air Act. Appendix B includes a list of key documents to review for further
consideration of the pollution prevention concepts discussed in the report.
In addition to this report, EPA has undertaken a pilot effort to provide specific
information to environmental management personnel at Federal facilities to assist in the Clean Air
Act compliance decision making process. To date, two reports have been generated:
"Pollution Prevention and the Clean Air Act at Federal Facilities - Cleaning and
Degreasing Activities"; and,
"Pollution Prevention and the Clean Air Act at Federal Facilities - Painting and
Depainting Activities".
These processes are widespread throughout the Federal government and have traditionally relied
on the use of organic solvents. Opportunities exist to move away from the use of organic
solvents through pollution preventative approaches. Additional processes are being considered
for future profile reports.
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CHAPTER 2
THE FEDERAL FACILITY VIEW OF THE CLEAN AIR ACT
INTRODUCTION
The Clean Air Act (CAA) is arguably the most complex environmental legislation to date.
The Act itself is nearly 500 pages long. The U.S. Code of Federal Regulations holds thousands of
pages of prescriptive emission limitations and methods for showing compliance. State and local
agencies have file cabinets full of plans for reducing air pollution from sources ranging from
lawnmowers and bakeries to power plants and refineries.
Federal facilities must comply with these rules in virtually the same way that private
business must comply. Environmental managers at large Federal facilities, such as military bases
and power plants, are often quite familiar with these requirements. However, the Clean Air Act
Amendments of 1990 strengthened and broadened the requirements for air pollution control. As a
result, managers of many Federal activities that were previously considered "insignificant" must
now address the issue of air quality compliance.
This Chapter is intended to help Federal facility managers understand their long-term
compliance responsibilities under the CAA. It is impossible to summarize in a'few pages all of the
important features of the CAA. However, it is possible to present in a few pages the major issues
presented by the CAA and to gain an understanding of the actions needed to plan for compliance.
This Chapter discusses three major topics:
The CAA Title V operating permit program - this program is intended to pull
together in one document all of the enforceable requirements concerning air
emissions that apply to each permitted source.
The specific CAA programs that establish emission limitations or control
requirements; these programs often contain overlapping and sometimes redundant
pollution control requirements.
The overlap between a Federal facility's CAA responsibilities and other
responsibilities associated with Executive Orders on pollution prevention planning.
Despite the complexity of clean air rules, a Federal facility manager can begin to comprehend the
CAA by considering its major components as shown in Figure 1.
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Figure 1
Simplified CAA Activity Diagram
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ROLE OF OPERATING PERMIT PROGRAM
Perhaps the key component of the 1990 CAAA was the Title V operating permit program.
The following are major features of Title V:
Operating permits are required for all major emitting facilities and all other
facilities covered by Federal regulatory programs;
Permits must set forth all those requirements of the Clean Air Act that apply to the
facility, as well as monitoring and reporting procedures that help enforce those
requirements;
States must develop permit programs to review and approve permits;
Permit applicants must submit a permit fee of at least $25 per ton of regulated
pollutant emitted to support the State permit program;
EPA may veto a State permit that fails to comply with Federal law.
Title V (and the implementing regulations contained in 40 CFR Part 70) does not establish new
emission control requirements, but rather simply translates existing requirements into
individualized enforceable conditions for each requirement.
Is Mv Facility Required To Obtain An Operating Permit?
Whether a particular facility of air pollution must obtain an operating permit depends on
how badly the local air is polluted and on the kinds and quantities of pollutants that the facility
emits into the air. The most important factor for determining whether a facility needs an
operating permit is the quantity of emissions generated. This determination is not based on the
amount of pollution typically generated, but rather on the amount of pollution that a facility is
capable of generating when operating at maximum capacity and worst case operating parameters
(this is referred to as "potential to emit"). In general, a facility must obtain an operating permit if
it meets any one of the following requirements:
General: any facility with the potential to emit 100 tons per year or more of any
regulated air pollutant regardless of geographic location. Appendix A contains a
listing of regulated air pollutants.
Sources of Hazardous Air Pollutants: any facility with the potential to emit 10
tons per year or more of any of the 189 listed hazardous air pollutants (see
Appendix A for a complete list), or with the potential to emit 25 tons per year or
more of two or more such pollutants. For example, if the facility has the potential
to emit 9 tons each of benzene, methanol, and chlorine, then its total potential to
emit is 27 tons per year and the facility would be considered a "major source".
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Sources Subject to New Source Performance Standards: any facility with
individual sources subject to a standard of performance for new stationary sources
is required to obtain an operating permit.
Sources in Nonattainment Areas: lower potential to emit thresholds exist for
certain criteria pollutants depending upon the severity of the air quality problem.
Table 1 (shown below) shows the major source emission thresholds for nonattain-
ment areas.
TABLE 1
MAJOR SOURCE DEFINITION IN NONATTAINMENT AREAS
Pollutant
Nonattainment Status
Major Source I
Threshold I
Ozone (VOC and NO.)
Marginal or Moderate
100tpv
Serious
50tpv
Severe
25tpv
Extreme
lOtpy
Transport Region (portions of ME,
NH, VT, MA, CT, RI, NY, NJ, PA,
DE, MD, DC, Northern Virginia that
are not in severe or extreme areas)
50tpy VOC
100 tpy NO,
Carbon Monoxide
Serious Areas
50 tpy |
PM-10 Particulate Matter
Serious Areas
70 fr
Even if a facility is "major" for only one pollutant, the Part 70 regulations require an accounting in
the permit for all emission sources in the facility regardless of their size or quantity of the
regulated pollutants they emit.
In some circumstances, a facility may be able to reduce its potential emissions below the
threshold -vel by agreeing to implement certain federally enforceable control measures. This
would av w'id the need for obtaining an operating permit. These agreed-to control measures couln
involve commitments to install specific emission control equipment, reduce the source's operating
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time, or switch to different processes or products that are less polluting. The EPA has coined the
term "synthetic minor" or "conditioned major" to refer to sources which take such measures.
Currently, non-major sources (including "synthetic minors") are exempted from the
Federal operating permit program. However, many States have established minor source permit
programs that may require minor sources to obtain permits.
What Must I Submit In Mv Permit Application?
All "major sources" must submit applications to the State or local permitting agency for
approval. The timetable for submitting applications has not been finalized and will vary from
State to State. Most States will begin processing permit applications in 1995.
Permit application forms vary from State to State. In general, the required information in
the application will included:
Facility Information - such as name, location, owner, plant manager, and other
officials responsible for the permit;
Facility Description - a description of emission generating processes, including
production rates, fuels and raw materials used, and emissions data;
Air Pollution Control Equipment - includes devices or work practices that
reduce pollution;
Description of Applicable Requirements - all federally enforceable emission
limitations or standards must be identified;
Monitoring, Recordkeeping, and Reporting Procedures - a listing of the
specific test methods or monitoring that will be used for demonstrating compli-
ance, along with the frequency of such testing or monitoring;
Compliance Plan - sets specific timeframes for achieving all provisions for which
the source is not currently in compliance;
Periodic Certification of Compliance - set schedule for annual verification of
compliance which must by signed by a responsible facility official with regards to
the truth, accuracy, and completeness.
Permit applications may range in size from about 10 pages to several hundred pages of supporting
information for large facilities.
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In addition, the source must pay a permit fee. The amount and manner of computation
varies from State to State, but in general is of the order of $25 per ton of emissions.
Who Reviews And Approves Mv Application?
Permit applications and other required documentation must be submitted to the State or
local permitting agency for review and approval. Each permit may be reviewed by as many as five
different groups:
Permitting agency review - The State or local agency makes substantive
determinations as to whether the permit should be issued or denied, and must
respond to any adverse comments received from other parties.
Affected state review - Any state within SO miles of the source (and whose air
quality is being impacted) can object to a permit's issuance if the affected state
finds the permit does not meet either the applicable requirements or the Part 70
regulations.
Public Participation - A 30 day public comment period is required before any
permit is issued, and a public hearing may be requested.
EPA Review - EPA is required to review all proposed permits within 45 days and
must veto permits that fail to assure compliance with all applicable requirements.
Judicial Review - There is also an opportunity for judicial review of all decisions
made by the permitting agency.
The overall time frame for the permitting agency to issue permits is 18 months after the submittal
of a complete application.
How Do I Certify Compliance With Permit Conditions?
A compliance certification must be included in all applications. The certification must
state the source's current compliance status with all applicable regulations and the methods used
to determine compliance. For Federal agencies, the compliance certification must be signed by a
"principal executive officer...having responsibility for the overall operations of a principal
geographic unit of the agency (e.g., a Regional Administrator)". False statements in a compliance
certification, even those made unintentionally, may subject the responsible official to fines or
criminal penalties for deliberate falsification of permit records.
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The Part 70 regulations require permitted sources to periodically test and monitor their
emissions. For certain larger sources, proposed Part 64 regulations require monitoring to assure
compliance. Examples of the types of monitoring or testing that may be required include the
following:
Continuous emission or opacity monitoring systems.
Continuous process or control device parameter monitoring systems.
Emission calculations using accepted engineering estimation techniques.
Maintenance and analysis of records of fuel or raw materials usage.
Periodic verification of emissions, process parameters or control device parameters
using portable or in situ measurement devices.
Recording results of a program or protocol to conduct specific operation and
maintenance procedures, leak detection, fugitive dust control, or other work
practices.
In addition to in-house monitoring and testing, State agencies and EPA have the right to conduct
facility inspections to determine compliance. A permitting agency may enter a facility at any time
to inspect a source's permit documents and other reports, observe the operation of control
equipment, and take samples of air emissions. The permitting authority may immediately assess
fines and other penalties for permit related infractions that are discovered.
How Can I Change Mv Permit?
Permits are generally issued for a 5-year period. During that time, there are a number of
circumstances that can cause the permit to be modified. For example, EPA may promulgate a
new regulation or the facility may want to expand operations or add a new source. Permitting
requirements depend on the type of change being contemplated:
States or EPA can initiate the reopening of a permit to incorporate new
requirements established by federal or state regulations;
A source can submit an administrative amendment for small changes or
corrections that do not affect emissions; the State agency must review the
proposed changes, but there are no provisions for EPA or public review.
A source can submit a minor permit modification for certain operational changes
necessary to respond with flexibility to emerging business opportunities. Small
increases in the quantity and types of pollutants emitted are allowed.
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A source can submit a significant modification which is subject to the same
review procedures as the initial permit.
New sources or mqjor modifications at existing facilities are subject to a rather
complex new source review permitting program that is discussed in the following
section.
Federal facility managers should be aware that the time required to modify air permits may
seriously complicate facility planning processes.
APPLICABLE REQUIREMENTS
Perhaps the most critical step in the permitting process, and probably the most complex, is
determining applicable emission limitations or standards. As noted previously, air quality
regulations consist of a hodgepodge of Federal and State rules that have evolved over the past 25
years in attempt to resolve specific air quality problems. Some of the requirements are
technology-based and require pollution controls that are either the best available or that can be
practically applied. Other requirements are risk-based and the level of control depends upon the
severity of the problem.
Determining whether a particular air quality management strategy affects your facility
depends upon a number of factors, including:
Geographic location - some emission standards apply nationally to all sources in a
given category, others apply only to sources located in areas where air quality
exceeds threshold values (i.e. nonattainment areas), still other State-specific rules
apply only to sources located in that State. For example, National Emission
Standards for Hazardous Air Pollutants (NESHAP) apply nationally, while
Reasonable Available Control Technology (RACT) requirements can apply only in
nonattainment areas.
Date of construction - some emission standards apply only to sources constructed
after a certain date, other rules apply only to newly constructed sources, and stilt
other rules apply to all sources regardless of construction date. For example, Ni-u.
Source Performance Standards (NSPS) apply only to sources built after the date
the NSPS was promulgated, whereas RACT requirements apply to all existing
sources.
Pollutants emitted - nearly every emission standard is targeted towards a specific
pollutant or groups of pollutants that are causing a particular air quality problem
For example, the Maximum Achievable Control Technology (MACT)
requirements target 189 hazardous air pollutants, while the National Recycling and
Emission Reduction Program targets a few dozen ozone depleting substances.
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Size of the source - most emission standards apply to sources above a certain
emission or size threshold (so-called major sources), others apply to all sources
regardless of size. The threshold depends upon the geographic location, pollutants
emitted, and applicable regulatory program.
Federal managers confused by the these distinctions should not despair of their analytical
capabilities. Defining and distinguishing between these requirements have challenged private
business, the EPA, State and local agencies, and the courts for years. Table 2 summarizes
important aspects of each of the major air regulatory programs. The following paragraphs
provide a synopsis of each program.
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TABLE2
SUMMARY OF MAJOR CLEAN AIR ACT PROGRAMS
PROGRAM
FEDERAL
OR STATE
PROGRAM
GEOGRAPHIC
COVERAGE
PRIMARY
POLLUTANTS
OF CONCERN
NEW OR
EXISTING
SOURCES?
CONTROL
TECHNOLOGY
REQUIREMENT
SIP
State
Nonattainment
Criteria
Existing
RACT (Reasonable Available Control Technology)
Control techniques
NSPS
Federal
National
Criteria plus TSP,
dioxin, fluorides,
hq. as
New
NSPS (New Source Performance Standards)
Hazardous Air
Pollutants
Federal
National
189 hazardous air
pollutants
New and
Existing
MACT (Maximum Achievable Control Technology)
Prevention of
Significant
Deterioration
State
Attainment
Criteria plus NSPS-
/NESHAP
New
B ACT (Best Available Control Technology)
New Source
Review
State
Nonattainment
Criteria plus
NSPS/NESHAP
New
LAER (Lowest Achievable Emission Rate) 1
Add Rain
Federal
National
Sulfur dioxide
Oxides of Nitrogen
Existing
Specific controls are not required. Each of 111 affected I
sources are given an emissions allowance and are free to 1
reduce emissions below the allowance in any manner they I
choose, including buying and selling emission credits. 1
Stratospheric
Ozone
Protection
Federal
National
Ozone Depleting
Substances
New and
Existing
Complete ban on the production of certain ozone depleting 1
substances. 1
Stale Programs
State
State
New and
Existing
Control requirements vary widely for State-specific
programs. Some programs provide the source flexibility in
choosing control techniques, while other programs require
the installation of specific pieces of control equipment.
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State Implementation Plans
Many urban areas experience air quality levels that fail to meet standards for human health
(i.e. National Ambient Air Quality Standards, or NAAQS). NAAQS exist for six "criteria"
pollutants. Areas that fail to meet the standards are called "nonattainment areas". Of these six
NAAQS, ground-level ozone air pollution has been the most difficult problem to solve because of
the complex interaction of meteorology and emissions of volatile organic compounds and oxides
of nitrogen, the two pollutants which react to produce ozone.
The degree of control required depends upon the existing air quality in the urban area:
areas are ranked from marginal to extreme, with the more polluted areas required to institute
more rigorous controls. State and local agencies develop State Implementation Plans (SIPs) to
reduce air pollution from stationaiy and mobile sources to ensure that healthy air quality levels are
achieved. At a minimum, stationary sources are required to install Reasonably Available Control
Technology (RACT). Stricter controls may be required in heavily polluted areas. Many smaller
facilities (such as bakeries, printing plants, auto paint shops, dry cleaners) that were previously
exempt from control requirements now are subject to RACT requirements.
EPA has developed Control Techniques Guidelines (CTGs) for dozens of source
categories that identify control techniques that are presumed to represent RACT. For source
types not covered by a CTG, the individual source is responsible for preparing a source-specific
RACT determination that must be approved by the State or local agency and EPA. As noted
before, control requirements may be more stringent than RACT to ensure continual progress
toward attainment of the NAAQS.
Performance Standards For New Sources
The C AA has historically imposed stricter controls on new sources than on existing
sources. This is based upon the premise that it is easier to incorporate state-of-the-art control
technology in new (or substantially modified) plants than to retrofit such control on older plants.
EPA originally developed New Source Performance Standards (NSPS) for a few dozen
source categories in the 1970's. The NSPS were to apply uniformly across the U.S., irrespective
of the air quality in the area where the plant was being built. The NSPS were technology-based
standards representing the "best technological system of continuous emission reduction" at the
time the standards were set. Afford-ability of the control systems was one factor in setting the
NSPS. Over time, NSPS must be continually upgraded in order to represent improvements in
"state-of-the-art" control technology.
In the 1977 amendments to the CAA, Congress decided that standards for new sources
locating in nonattainment areas should be stricter than standards for sources located in attainment
areas. Sources locating in nonattainment areas became subject to a New Source Review (NSR)
permitting program. In order to receive a permit to construct a new source, the source would
have to install controls that represent the lowest achievable emission rate (LAER). In addition,
the source would have to obtain emission reductions (or "offsets") from other sources within the
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plant or from other facilities to offset any increase in emissions from the new source. Obtaining
offsets has been a difficult problem for new sources trying to locate in heavily polluted areas such
as Los Angeles, New York, and Philadelphia.
New sources locating in attainment areas are subject to the Prevention of Significant
Deterioration (PSD) permitting program. This program imposes a best available control
technology (BACT) requirement. A BACT determination requires a case-by-case, "top-down"
ranking of all available control technologies. The most effective technology is considered BACT
unless the applicant can demonstrate that technical considerations or economic impacts justify that
the most stringent technology is not "achievable". More stringent controls than BACT may be
required if the emissions from the source cause local air quality to deteriorate beyond an
incremental amount (so-called PSD increments) in clean areas. For certain pristine areas, such as
national parks or wilderness areas, very little air quality deterioration would be allowed. Visibility
must also be protected.
Standards Fur HararHnns Air Pollutants
The 1970 CAA established a program to regulate a category of unique pollutants because
of their toxic or hazardous properties and the localized contamination problems they posed.
Originally, EPA developed National Emission Standards for Hazardous Air Pollutants (NESHAn)
to ensure that communities were not exposed to excessive cancer risks. EPA found it very
difficult to regulate emissions because of the scientific uncertainty concerning the linkage between
emissions and cancer risks. EPA often found itself in the position of banning economically
important substances that are potentially carcinogenic. As a result very few NESHAP standards
were developed prior to 1990.
The 1990 CAA Amendments dealt with the problem of hazardous air pollutants in several
ways. The primary method called for EPA to develop Maximum Achievable Control Technology
(MACT) for hundreds of categories of industrial sources for 189 individual Hazardous Air
Pollutants (HAPs) listed in the CAA. The MACT standards are scheduled to be developed over
the next 10 years. A second method is for EPA to develop residual risk determination procedures
to control categories of sources whose emissions still present health risks even after the applica-
tion of MACT. A third method is for EPA to develop accidental release prevention regulations
that require certain facilities handling extremely hazardous, "regulated toxics," substances to
develop detailed risk management plans. The lists of HAPs and regulated toxic substances are
included in Appendix A.
Prior to 1990, the slow Federal pace in regulating hazardous air pollutants led several
states to establish their own "air toxics" programs. Many states established emission standards or
procedures for determining control requirements for as many as 800 "air toxic" pollutants.
Although the 1990 CAA Amendments addressed the problem of air toxics, most of these state air
toxics programs remain in place. If EPA fails to meet its schedule for developing MACT
standards, the States also become responsible for administering a case-by-case MACT
determination program.
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About half of the 189 HAPs are also volatile organic compounds regulated under the SIP
provisions described earlier. In many cases these VOC emission sources will be subject to new
RACT emission limits prior to the MACT emission standards. Federal facility compliance
programs must consider the impact of both RACT and eventual MACT requirements and make
certain that a compliance strategy is sufficient for both standards. The potential for having to
control twice is a reality which must be considered.
Acid Rain Program
The acid rain program is intended to reduce emissions of sulfur dioxide by 10 million tons
per year and oxides of nitrogen by 2 million tons per year. Mainly large electric generating units
are affected by the program. Emission reductions are to be achieved by the application of
emission allowances for a fixed set of large sources. This allowance system enables sources to
minimize cost and maximize flexibility by allowing the transfer of allowances from one source to
another. This will facilitate the use of a variety of options for controlling emissions, such as the
use of low sulfur fuels, flue-gas desulfurization, phasing out older units, etc.
Stratospheric Ozone Protection
Although ground-level ozone adversely affects human health, stratospheric ozone found in
the upper atmosphere is necessary to filter out harmful radiation from the sun that might cause
skin cancer. An international agreement, the Montreal Protocol, committed all nations to the
phase out of materials which deplete stratospheric ozone. The CAA was expanded to include
provisions to comply with the Protocol in the U.S. EPA has developed regulations mandating a
phase-out of ozone depleting chemicals (ODCs). This group of chemicals includes many that are
currently commonly used in many operations such as refrigeration, air conditioning, fire fighting
agents, foam blowing, and precision cleaning.
State Programs
While State agencies must enforce Federal emission control requirements, States are five
to establish emission standards that are more stringent than Federal requirements. As mentioned
above, many States developed air toxics programs that in some cases include additional hazardous
air pollutants and impose special permitting requirements.
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COMPLYING WITH THE CAA AND OTHER PROGRAMS
As can be seen from the previous discussions, developing a long-term CAA compliance
action plan can be a quite complex undertaking. Making matters worse for the Federal facility
manager, other environmental programs establish requirements that must be considered in
developing a CAA compliance action plan. There are many overlapping and at times redundant
requirements. Developing a holistic approach to these requirements will be the challenge of every
Federal facilities manager. The next Chapter presents the basics on developing a holistic
approach, namely, the pollution prevention approach. The remainder of this chapter briefly
describes some non-CAA requirements facing Federal facility managers and how these
requirements intersect with CAA requirements.
EPCRA And Pollution Prevention Planning
Executive Order 12856, entitled: "Federal Compliance with Right-to-Know Laws and
Pollution Prevention Requirements," was signed by the President on August 3,1993. This
Executive Order requires all Federal facilities to comply with the Emergency Planning and
Community Right-to-Know Act of 1986 (EPCRA, also referred to as Title m, Superfund
Amendments and Reauthorization Act (SARA)) including reporting to the Toxic Release
Inventory (TRI). It also initiated a pollution prevention planning process for all Federal agencies.
Federal facilities are now required to file annual reports on releases to the environment and ofi&ite
transfers for over three hundred chemicals and chemical categories. Reporting is required for
facilities which manufacture or process 25,000 pounds or more or otherwise use 10,000 pounds
or more of any listed chemical. The 1990 Pollution Prevention Act (PPA) expanded the TRI
reporting requirements to include information on waste generation and the use of source
reduction and recycling to limit waste generation. A "Form R" is used for reporting. For 1987
through 1993 reporting was required for over three hundred chemicals and chemical categories.
EPA then added 32 chemicals and 2 chemical categories to the list of TRI substances, requiring
reporting for the first time for calendar year 1994 (12/1/93,58FR63496 and 58FR63500). An
additional 286 chemicals were added for the 1995 calendar year reporting requirements
(11/30/94,59FR61432), bringing the number of listed chemicals to over 600.
The TRI will serve as the accounting system for demonstrating compliance with the
pollution prevention planning goals established by EO 12856. Federal agencies are committed to
achieving a 50 percent reduction in reported TRI levels (in aggregate) for all their facilities by
1999. To the maximum extent possible the reductions are to be achieved through pollution
prevention. The baseline for this planning process will be defined by the 1994 reports (due July 1,
1995). Each facility must develop a facility plan which outlines their contribution in reducing
waste generation. The EO requires development of these plans by the end of 1995.
Many of the chemicals subject to reporting to TRI are also those regulated by the Clean
Air Act. Thus, steps to comply with the Clean Air Act will also contribute toward meeting the
goals of EO 12856. In Chapter 3, the concept of facility planning to achieve pollution prevention
will be discussed as a means to meet both the Clean Air Act requirements and EO 12856.
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Pollution Prevention Procurement
Federal agencies are also required to implement programs to encourage the purchase of
"environmentally preferred" and recyclable products by Executive Order 12873. This Executive
Order, titled: "Federal Acquisition, Recycling, and Waste Prevention" was signed October 20,
1993. EPA is charged with the responsibility of working with Federal agencies to develop
guidance on what criteria should be should be used to identify acceptable products. The criteria
are expected to favor the use of products which will facilitate compliance with the Clean Air Act
(limited use of VOCs, HAPS, and ODCs).
Federal facilities were also encouraged to accelerate their phase out of the use of ozone
depleting chemicals. Executive Order 12843, "Procurement Requirements and Polices for Federal
Agencies for Ozone-Depleting Substances" (April 21,1993) directs Federal agencies to change
procurement policies to specify use of non-ozone depleting materials in advance of the 1996
deadline required by the Clean Air Act.
Conservation And Alternative Fuels
Federal facilities were tasked with expanding their focus on energy and water conservation
with the signing of three additional Executive Orders.
EO12844 - "Federal Use of Alternative Fueled Vehicles" - encourage the
purchase of alternative fueled vehicles as a means to reduce air pollution,
encourage the use of alternative energy sources, and stimulate the U. S. economy.
EO 12845 - "Requiring Agencies to Purchase Energy Efficient Computers" -
requires Federal agencies to purchase energy efficient computer equipment as
participants in the "Energy Star Computer" Program.
EO 12902 - "Energy Efficiency and Water Conservation at Federal Facilities" -
established goals for Federal facilities to reduce energy usage in buildings and
industrial processes. Facilities are also required to conduct comprehensive audits
of energy and water consumption.
Implementing these Executive Orders may lead to changes in equipment and practices which may
also be impacted by requirements of the Clean Air Act. Activities to reduce energy consumption
may also reduce air emissions from the facility.
Media Programs
Many of the chemicals regulated by the Clean Air Act are also regulated by the "other"
media programs, those to protect water quality and control waste disposal on land. Many of the
same chemicals are listed in criteria for hazardous waste under the Resource Conservation and
Recovery Act (RCRA). They are also regulated in water discharges through permit programs
17
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under the Clean Water Act (CWA). The compliance burdens of these programs add to the
complexity of responding to Clean Air Act requirements.
Approaching compliance through pollution prevention is one way address all of these
requirements. Pollution prevention eliminates waste generation to all media and minimizes
transfers between environmental media, from air to hazardous waste or air to water. Chapter 3
discusses several concepts useful in developing a pollution prevention compliance strategy to
address the broad array of requirements facing Federal facilities.
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CHAPTER 3
RESPONDING WITH THE P2 APPROACH
This Chapter will present some key concepts and approaches to implementing pollution
prevention. Chapter 2 identified a wide array of Clean Air Act programs which will to some
degree impact all Federal facilities, now, or in the future. So how do you minimize the impact of
the Act? How do you reduce your compliance expenditures? Many believe the environmental
management principles of pollution prevention will lessen the burden of the Clean Air Act and
reduce compliance expenditures. This Chapter provides some ideas on how to incorporate a
pollution prevention ethic into facility decision making. The concepts of a waste management
hierarchy, pollution prevention planning, true cost accounting, and life cycle analysis are
presented. These concepts lead to greater recognition of the benefits of source reduction relative
to treatment approaches when considering alternative to complying with Clean Air Act
requirements.
POLLUTION PREVENTION AND THE WASTE MANAGEMENT
HIERARCHY
Pollution prevention (P2) is the use of materials, processes and practices that reduce or
eliminate the generation of wastes at the source. EPA has defined pollution prevention as "source
reduction" a term described in the Pollution Prevention Act (PPA):
"...any practice which ~ (i) reduces the amount of any hazardous sub-
stance, pollutant, or contaminant entering any waste stream or
otherwise released into the environment (including fugitive
emissions) prior to recycling, treatment or disposal: and (ii) reduces
the hazards to public health and the environment associated with
the release of such substances, pollutants, or contaminants the
term does not include any practice which alters the physical,
chemical, or biological characteristics or the volume of a hazardous
substance, pollutant, or contaminant through a process or activity
which is not integral to and necessary for the production of a
product or the providing of a service."
The PPA established as national policy, a clear preference for source reduction or P2 through a
hierarchical approach to waste management:
"....pollution should be prevented or reduced at the source whenever
feasible; pollution that cannot be prevented should be recycled in an
environmentally safe manner, whenever feasible; pollution that
cannot be prevented or recycled should be treated in an
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environmentally safe manner whenever feasible; and disposal or
other release into the environment should be employed only as a
last resort and should be conducted in an environmentally safe
manner."
Looking at source reduction options first, is a simple concept, but a fundamental change to
traditional environmental decision making. In the past, as environmental problems surfaced, the
first consideration was, how can I treat this? Or, where do I dispose of this? But with a pollution
prevention perspective, the question becomes, how did I get this problem in the first place?
Solving environmental problems through pollution prevention is usually not a one shot
exercise. A proactive commitment is needed, usually involving several steps over time and a
greater understanding of the processes generating the waste stream. You are committed to
continually reducing your waste generation. The traditional "treatment" approach for a waste
stream is simpler. Generally you are in a reactive posture, working to meet a required limit by a
fixed deadline. You simply size a control device to meet the limit and hope the limit doesn't
change in the future. But with a pollution prevention approach, the required limit is a milestone
you will achieve (or obviate the need to achieve) and hopefully exceed as you work toward the
longer term goal of minimizing waste generation.
With the traditional approach, everything is understood, this level must be met by this
date. But with pollution prevention, the process appears to be unbounded. What waste streams
are important to tackle? Why? What's technically and economically feasible? What are the
environmental implications? Are their political roadblocks? Pollution prevention requires the
establishment of a planning process to consider these issues. The process requires the develop-
ment of opportunity assessments and a facility plan-
POLLUTION PREVENTION PLANNING
Pollution prevention planning is a process which integrates environmental decision making
into the resource planning process at a facility. The planning process generates a facility pi^n
which identifies what steps are to be taken, when, and with what resources to reduce waste
generation. Projects to implemented through the plan are usually identified through the
development of opportunity assessments. The facility plan reflects a continuous and
comprehensive planning process requiring reassessment and updating on a regular schedule. The
planning process and periodic reassessment reflect the proactive nature of pollution prevention.
Federal Facilities are committed to a facility planning process in response to Executive
Order 12856. Pollution prevention planning goals under this EO challenge Federal agencies to
achieve a 50 percent reduction by 1999 from their 1994 reported releases and offsite transfers to
the Toxic Release Inventory (TRI). To the maximum extent possible, federal facilities are
expected to achieve these reductions through source reduction. The EO requires the development
of facility plans by the end of 1995.
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EPA's Office of Research and Development has developed a Facility Pollution Prevention
Guide (5/92, EPA/600/R-92/088) which describes the pollution prevention planning process and
how to conduct an opportunity assessment. Figure 2 taken from this report provides an overview
of a pollution prevention planning program. Key aspects of this approach are:
Commitment from top management through policy and resources to conduct
planning;
Baseline assessment of waste generation and the setting of priorities for further
review;
Detailed opportunity assessment of waste reduction alternatives for priority waste
streams;
Commitment to projects supported by the opportunity assessment;
Establishment of ways to measure progress; and
Periodic reassessment of priorities and opportunities.
The planning process requires input from all those potentially impacted by its implementation.
This includes, for example, personnel representing management, procurement, facility operations
and maintenance. A facility plan developed without their input has many potential pitfalls. It may
not reflect reality, will be difficult to implement, and will not benefit from the knowledge of the
personnel closest to the problem. The importance of the concept of "empowering the people"
couldn't be more true than in pollution prevention planning.
The requirements emanating from Clean Air Act programs may drive the priority setting
process and the focus of the facility plans at Federal facilities. Air emission streams resulting from
the use of VOCs, HAPs, and ODCs will be prime targets for the investigation of source reduction
alternatives to meet the pollution prevention goals of EO 12856. Conducting opportunity
assessments is the process by which the technical, economic, environmental and political
feasibility of source reduction alternatives are investigated for priority waste streams.
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Figure 2
Pollution Prevention Program Overview
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Opportunity assessments generally follow this approach:
Establish an assessment team with representatives from key facility organizational
units, i.e., operations, maintenance, procurement, health and safety, etc.;
Review available data, determine information needs to define material flows and
characterize sources of waste generation;
Design site visit to fill information needs and gain the perspective of personnel
most knowledgeable of the operations;
Conduct site visit and interviews to gain targeted information;
Organize information and propose comprehensive list of potential options in
accordance with waste management hierarchy;
Screen options to identify priority options for detailed feasibility analysis;
Conduct detailed analyses for priority options of the technical, economic,
environmental and political feasibility;
Establish priorities for implementing options; and
Report the results of the detailed analyses and priorities for implementation.
The results from the opportunity assessment provide the basis for identifying projects to
include in the pollution prevention plan. It should also serve to identify areas where further
investigation may be warranted. For a more detailed description of the pollution prevention
planning process, the reader is referred to the Facility Pollution Prevention Guide.
The feasibility analyses are an important part of the opportunity assessment. The
evaluation of costs and benefits can be critical when comparing source reduction alternatives with
treatment options. Some of the costs associated with waste treatment can be difficult to identify
or missed and, therefore, some options may be misrepresented. The concept of true cost
accounting attempts to capture the full cost of potential projects. True cost accounting is
important in developing feasibility assessments.
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TRUE COST ACCOUNTING
True cost accounting, total cost accounting, total cost assessment, full cost accounting,
and total cost analysis are all terms for accounting practices which seek to present a more
accurate accounting of environmental costs. Table 3 lists many of the different costs which can be
associated with capital investment projects as potential environmental expenditures. Historically,
however, only the direct costs are considered in project decisions. Indirect and liability costs and
less-tangible benefits associated with environmental issues are rarely considered. Many
environmental costs are tracked in aggregate for facilities as overhead and not allocated to the
specific waste generating operation creating the costs. Ignoring environmental costs in financial
analyses results in actual costs exceeding projected costs in the long run. When comparing
alternatives, the more expensive option may be chosen by mistake.
Source reduction projects can be misrepresented when only direct costs are considered.
Source reduction projects almost always will have reduced indirect and liability costs in
comparison to the waste treatment alternative. In some instances, source reduction approaches
may have higher projected direct costs, but these costs may be offset by cost savings in other
areas. For example, converting to a powder (solvent free) coating system may have greater
upfront expenditures than enclosing a conventional solvent-based coater and venting it to a
control device, yet significant savings would be achieved over time as a result of reduced
expenses for compliance demonstration and worker protection. If only direct costs are
considered, the more expensive option may be perceived as the best buy.
Accounting for these hidden costs requires more work. It requires careful review of how
each option under consideration will impact the many cost categories shown in Table 3. Current
cost data, such as for on-site waste management, may need to be disagregated to the specific
process operation under consideration to provide a baseline to assess potential changes in costs in
the feasibility analysis. Many environmental costs occur over time. Source reduction benefits
would be realized over that same timeline. In analyzing these costs and benefits, the financial
analysis must take into account the time value of money over time, with a time horizon which
reflects the long-term costs and benefits of the alternatives considered.
Not all costs and benefits can be quantified particularly the less-tangible benefits or
"social" costs, such as community relations. An effort should be made to compare in a qualitative
sense the impact of alternatives on the less-tangible aspects. Recognizing the benefits of pollution
prevention alternatives, such as improved working conditions, even in a qualitative sense can be
factored into the feasibility analysis.
EPA has been working with the cost accounting community to develop a better
understanding of the importance of environmental cost accounting and approaches to improve
consideration of these costs. Several reports available on the topic are identified in Appendix B.
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Table 3
COSTS AND BENEFITS OF ENVIRONMENTAL PROJECTS
Direct Costs
Capital Expenditures
Operation and Maintenance
Buildings
Raw Materials
Equipment and Installation
Labor
Utility Connections
Waste Disposal
Project Engineering
Water and Energy
Utilities
Value of Recovered Material
Indirect Costs
Administrative Costs
Insurance
Regulatory Compliance Costs
Workman's Compensation
Permitting
On-Site Waste Management
Recordkeeping and Reporting
On-Site Pollution Control Equipment
Monitoring
Manifesting
Testing
Preparedness
Protective Equipment
Closure/Post Closure Assurance
Liability. Health and Safety Costs
Penalties and Fines
Economic Loss
Personal Injury
Natural Resource Damage
Cleanup Costs
Worker Illness
Supeifund
Down Time from Accidents/Spills
Corrective Action
Reduced Health Costs
Property Damage
Less-Tangible Costs and Benefits
Changing Sales or Utilization Due to:
Improved Relationships with Regulators
Improved Product or Service Quality
Improved Recruiting and Employee
Enhanced Image
Retention
Consumer Interest in Green Products
Enhanced Image in Budget Process
Increased Productivity due to Improved
Improved Relationships with Suppliers
Employee Relations
Improved Community Relations
Avoided Future Regulatory Costs
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LIFE CYCLE ANALYSIS
Life cycle analyses can provide a different perspective when comparing alternative
projects. Life cycle analysis is a systems approach to evaluating the environmental ran«fqIIPncM
of a particular product, process or activity from "cradle to grave." Environmental effects associat-
ed with any given activity are evaluated from the initial gathering of raw materials from the earth
until the point at which residuals are returned to the earth. Life cycle analyses provide
organizations with a better understanding of the environmental impacts of their actions.
The concept of life cycle analysis is receiving increased acceptance in the public and
private sector. Public issues such as paper versus plastic grocery bags, and disposable versus
cloth diapers have been the subject of life cycle analyses. The evaluation of "green" products will
increase the development of the concept and use of life cycle analyses in the future. There are no
fixed ground rules or accepted practices to developing life cycle analyses and different
interpretations can result from analyses prepared using different approaches. EPA's Office of
Research and Development has initiated an effort to develop consensus with the sri^tific
community on guidelines for conducting life cycle analyses.
Life cycle analyses usually contain three components:
Life Cycle Inventory - process of quantifying energy and raw material
requirements, releases to air, water and solid waste streams, and other
environmental factors throughout the life cycle of a product, process or activity.
Life Cycle Impact Assessment - assessing the impact of the environmental
burdens quantified in the inventory on ecological and human health and also for
social, cultural, and economic impacts.
Life Cyde Improvement Analysis - analysis of opportunities to reduce or
mitigate the environmental impacts throughout the life cycle.
Each of these components are not unique exercises; they overlap and build on each other in their
development. The focus of most life cycle analyses prepared to date has been limited to
developing life cycle inventories. Developing the inventory component for a project or competing
alternatives helps define the overall resource requirements and potential targets for resource
reduction efforts.
Federal facilities may want to consider developing a life cycle analysis to characterize
baseline resources and impacts or compare alternatives for major new projects. For additional
information on the concept of life cycle analyses, see the reports identified in Appendix B.
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ADDED BENEFITS OF POLLUTION PREVENTION
Pollution preventative approaches to complying with the Clean Air Act bring about a
number of added benefits. These benefits should be recognized in the development of facility
plans or in the conduct of life cycle analyses. The recognition of these benefits can be key factors
in project decision making. Benefits to look for include:
Compliance Demonstration - as described in Chapter 2, demonstrating
compliance is a continuous burden on sources. Pollution prevention options which
move away from the use of regulated compounds can significantly reduce these
burdens. Some aspect of monitoring, recordkeeping, and reporting requirements
are generally associated with all Clean Air Act limits. Eliminating applicability of
the requirements, eliminates these burdens.
Workplace - source reduction options generally lead to improved workplace
conditions and less concern for compliance with occupational exposure standards.
Treatment options generally require use of a system to capture emissions and send
them to the control device. Capture systems tend to concentrate emissions in the
workplace and may lead to requirements for use of personal protective equipment
such as respirators. Respirators carry with them the requirements for periodic fit
testing and worker training. Source reduction techniques generally reduce
workplace concentrations, provide for a more heathy workplace environment, and
improve worker comfort. Improved workplace conditions lead to improved
worker relations and productivity.
Resource Utilization - source reduction options conserve resources, both through
the elimination of material losses and the elimination of materials consumed by
treatment systems, such as energy and water for scrubbers and steam stripping of
carbon beds. More efficient use of materials also leads to cost savings.
Community Relations -the corporate "greening" of America is driven by many
companies quest for the economic benefit of improved image in the public eye.
Communities react favorably to facilities' efforts to reduce waste generation. With
Federal facilities reporting to the Toxic Release Inventory (TRI), communities now
have a means to access changes in waste generation and the use of source
reduction. Clean Air Act compliance efforts through source reduction will be
visible to communities through the TRI. Facilities have the opportunity to gain
positive recognition in the community for their efforts.
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THE P2 APPROACH
The pollution prevention approach to Clean Air Act compliance has potential benefits not
achievable through the traditional treatment approach. Source reduction won't always be the
answer, but the opportunities for source reduction should always be investigated. Facility
planning is the backbone of a pollution prevention program and provides a systematic process for
setting priorities for reducing waste generation and investigating source reduction opportunities.
This process can also be used to investigate alternatives to comply with current and future Clean
Air Act requirements. Source reduction solutions to the Clean Air Act will go a long way in
helping Federal facilities support their agency in achieving the pollution prevention goals of
Executive Order 128S6.
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APPENDIX A
LISTS OF CHEMICALS REGULATED UNDER THE CLEAN AIR ACT
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LIST OF REGULATED AIR POLLUTANTS
I. Pollutants For Which An NAAQS Has Been Established
lead
sulfur dioxide
nitrogen dioxide
carbon monoxide
particulate matter (PM10)
ozone, including precursors:
nitrogen oxides (NO, N02, N03, N20, N203, N204, N205)
volatile organic compounds (VOC's)
As defined in 40 CFR 51.100(s), the term VOC includes any compound of carbon
(excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and
ammonium carbonate) which participates in atmospheric photochemical reactions. The EPA has
developed a list of substances (which is subject to change) which are excluded from the VOC
definition because of their negligible reactivity. The EPA's proposal to exclude perchloroethylene
from the definition was published in 57 FR 48490 (October 26,1992) and acetone in 60 FR
31633 (June 16,1995).
The following organic compounds are excluded from the definition of VOC because of
they have been determined to have negligible photochemical reactivity:
acetone
methane
ethane
methylene chloride (dichloromethane)
1,1,1 -trichloroethane (methyl chloroform)
1,1,1 -trichloro-2,2,2-trifluoroe thane (CFC-113)
trichlorofluoromethane (CFC-11)
dichlorodifluoromethane (CFC-12)
chlorodifluoromethane (CFC-22)
trifluoromethane (FC-23)
1,2-dichloro 1,1,2,2-tetrafluoroethane (CFC-114)
chloropentafluoroethane (CFC-115)
1,1,1 -trifluoro 2,2-dichloroethane (HCFC-123)
1,1,1,2-tetrafluoroethane (HFC-134a)
1,1-dichloro 1-fluoroethane (HCFC-141b)
1-chloro 1,1-difluoroethane (HCFC- 142b)
2-chloro-l,.l,l,2-tetrafluoroethane (HCFC-124)
pentafluoroethane (HFC-125)
1,1,2,2-tetrafluoroethane (HFC-134)
1,1,1-trifluoroethane (HFC-143a)
1,1-difluoroethane (HFC-152a)
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List of Regulated Air Pollutants - continued
page two
perfluorocartxHi compounds which fall into these classes:
(i) Cyclic, branched, or linear, completely fluorinated alkanes;
(ii) Cyclic, branched, or linear, completely fluorinated ethers with no
un saturations;
(iii) Cyclic, branched, or linear, completely fluorinated tertiary amines
with no unsaturations; and
(iv) Sulfur containing perfluorocarbons with no unsaturations and with
sulfur bonds only to carbon and fluorine.
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List of Regulated Air Pollutants - continued
page three
n. Pollutants Regulated Under New Source Performance Standards
Criteria pollutants (including VOC's and NOx) plus:
dioxin/furan (defined in 40 CFR 60.53a to mean total tetra through octachlorinated dibenzo-p-
dioxins and dibenzofiirans)*
fluorides
hydrogen chloride*
hydrogen sulfide (H2S)
sulfuric acid mist
total reduced sulfur
reduced sulfur compounds
total suspended particulate
* The new source performance standard (NSPS) for municipal waste combustors (MWC)
controls emissions of dioxin/furans and hydrogen chloride gas (40 CFR 60.S3a and 60.54a) as
surrogates for controlling emissions of organic compounds and acid gases which are emitted in
the exhaust gases from MWC units. Thus, the indicated dioxin/furan compounds and hydrogen
chloride are regulated pollutants.
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List of Regulated Air Pollutants - continued
page four
m. Class I And Pass II Substances Under Title VI
Class I Substances
carbon tetrachloride
chlorofluorocarbon-11 (CFC-11)
chlorofluorocarbon-12 (CFC-12)
chlorofluorocarbon-13 (CFC-13)
chlorofluorocarbon-111 (CFC-111)
chlorofluorocarbon-112 (CFC-112)
chlorofluorocarbon-113 (CFC-113)
chlorofluorocarbon-114 (CFC-114)
chlorofluorocarbon-115 (CFC-115)
chlorofluorocarbon-211 (CFC-211)
chlorofluorocarbon-212 (CFC-212)
chlorofluorocarbon-213 (CFC-213)
chlorofluorocarbon-214 (CFC-214)
chlorofluorocarbon-215 (CFC-215)
chlorofluorocarbon-216 (CFC-216)
chlorofluorocarbon-217 (CFC-217)
halon-1211
halon-1301
halon-2402
methyl chloroform
Class II Substances
hydrochlorofluorocarbon-21 (HCFC-21)
hydrochlorofluorocarbon-22 (HCFC-22)
hydrochlorofluorocarbon-31 (HCFC-31)
hydrochlorofluorocarbon-121 (HCFC-121)
hydrochlorofluorocarbon-122 (HCFC-122)
hydrochlorofluorocarbon-123 (HCFC-123)
hydrochlorofluorocarbon-124 (HCFC-124)
hydrochlorofluorocarbon-131 (HCFC-131)
hydrochlorofluorocarbon-132 (HCFC-132)
hydrochJorofluorocarbon-133 (HCFC-133)
hydrochlorofluorocarbon-141 (HCFC-141)
hydrochlorofluorocarbon-142 (HCFC-142)
hydrochlorofluorocaibon-221 (HCFC-221)
hydrochlorofluorocarbon-222 (HCFC-222)
hydrochlorofluorocarbon-223 (HCFC-223)
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List of Regulated Air Pollutants - continued
page Ave
Class II Substances - continued
hydrochlorofluorocarbon-224 (HCFC-224)
hydrochlorofluorocarbon-225 (HCFC-225)
hydrochlorofluorocarbon-226 (HCFC-226)
hydrochlorofluorocarbon-231 (HCFC-231)
hydrochlorofluorocarbon-232 (HCFC-232)
hydrochlorofluorocarbon-233 (HCFC-233)
hydrochlorofluorocarbon-234 (HCFC-234)
hydrochlorofluorocarbon-235 (HCFC-235)
hydrochlorofluorocarbon-241 (HCFC-241)
hydrochlorofluorocarbon-242 (HCFC-242)
hydrochlorofluorocarbon-243 (HCFC-243)
hydrochlorofluorocarbon-244 (HCFC-244)
hydrochlorofluorocarbon-251 (HCFC-251)
hydrochlorofluorocarbon-252 (HCFC-252)
hydrochlorofluorocarbon-253 (HCFC-253)
hydrochlorofluorocarbon-261 (HCFC-261)
hydrochlorofluorocarbon-262 (HCFC-262)
hydrochIorofluorocarbon-271 (HCFC-271)
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List of Regulated Air Pollutants - continued
page six
IV. Pollutants Regulated Under Section 112
Pollutants for which national emission standards for hazardous air pollutants (NESHAP*s)
established prior to the passage of the 1990 Clean Air Act Amendments:
arsenic
asbestos
beryllium
benzene
mercury
radionuclides
vinyl chloride
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List of Regulated Air Pollutants - continued
page seven
V. Pollutants listed in Section 112(bV.
The following 189 pollutants were listed as Hazardous Air Pollutants (HAPs) in section
112(b) of the 1990 Clean Air Act Amendments. The section 112(b) list contains some technical
errors which will be corrected in subsequent rulemaking. The majority of the technical
corrections likely to be made are noted below.
CAS number
Chemical name
75070
Acetaldehyde
60355
Acetamide
75058
Acetonitrile
98862
Acetophenone
53963
2-Acetylaminofluorene
107028
Acrolein
79061
Acrylamide
79107
Acrylic acid
107131
Acrylonitrile
107051
Allyl chloride
92671
4-Aminobiphenyl
62533
Aniline
90040
o-Anisidine
1332214
Asbestos
71432
Benzene (including benzene from gasoline
92875
Benzidine
98077
Benzotrichloride
100447
Benzyl chloride
92524
Biphenyl
117817
Bis(2-ethylhexyl)phthalate (DEHP)
542881
Bis(chloromethyl)ether
75252
Bromoform
106990
1,3-Butadiene
156627
Calcium cyanamide
105602
Caprolactam
133062
Captan
63252
Carbaryl
75150
Carbon disulfide
56235
Carbon tetrachloride
463581
Caibonyl sulfide
120809
Catechol
133904
Chloramben
57749
Chlordane
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List of Regulated Air Pollutants - continued
page eight
CAS number Chemical name
7782505 Chlorine
79118 Chloroacetic acid
532274 2-Chloroacetophenone
108907 Chlorobenzene
510156 Chlorobenzilate
67663 Chloroform
107302 Chloromethyl methyl ether
126998 Chloroprene
1319773 Ciesols/Ciesylic acid (isomers and mixture)
95487 o-Cresol
108394 m-Cresol
106445 p-Cresol
98828 Cumene
94757 2,4-D (2,4-Dichlorophenoxyacetic acid, including salts and esters)
DDE [recommended technical correction: CAS number 72559]
(1,1 -dichloro-2,2-bis(p-chlorophenyl) ethylene)
334883 Diazomethane
132649 Dibenzofiirans [recommended technical correction: Dibenzofuran]
96128 1,2-Dibromo-3-chloropropane
84742 Dibutylphthalate
106467 1,4-Dichlorobenzene(p) [recommended technical correction:
1,4-Dichlorobenzene]
91941 3,3-Dichlorobenzidene [recommended technical correction:
3,3-Dichlorobenzidine]
111444 Dichloroethyl ether (Bis(2-chloroethyl)ether)
542756 1,3-Dichloropropene
62737 Dichlorvos
111422 Diethanolamine
121697 N,N-Diethyl aniline (N,N-Dimethylaniline) [recommended technical
correction: N,N-Dimethylaniline]
64675 Diethyl sulfate
119904 3,3-Dimethoxybenzidine [recommended technical correction:
3,3'-Dimethoxybenzidine]
60117 Dimethyl aminoazobenzene
119937 3,3',-Dimethyl benzidine [recommended technical correction:
3,3',-Dimethylbenzidine]
79447 Dimethyl carbamoyl chloride [recommended technical correction:
Dimethylcarbamoyl chloride]
68122 Dimethyl forrnamide [recommended technical correction:
N,N-Dimethylformamide]
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List of Regulated Air Pollutants continued
page nine
CAS number Chemical name
57147 1,1-Dimethyl hydrazine [recommended technical correction:
1,1 -Dimethylhydrazine]
131113 Dimethyl phthalate
77781 Dimethyl sulfate
4,6-Dinitro-o-cresol, and salts [recommended technical correction to
remove CAS number]
51285 2,4-Dinitrophenol
121142 2,4-Dinitrotoluene
123911 1,4-Dioxane (1,4-Diethyleneoxide)
122667 1,2-Diphenylhydrazine
106898 Epichlorohydrin (l-Chloro-2,3-epoxypropane)
106887 1,2-Epoxybutane
140885 Ethyl acrylate
100414 Ethyl benzene [recommended technical correction: Ethylbenzene]
51796 Ethyl carbamate (Urethane)
75003 Ethyl chloride (Chloroethane)
106934 Ethylene dibromide (Dibromoe thane)
107062 Ethylene dichloride(l,2-Dichloroethane)
107211 Ethylene glycol
151564 Ethylene imine (Aziridine) [recommended technical correction:
Ethyleneimine (Aziridine)]
75218 Ethylene oxide
96457 Ethylene thiourea
75343 Ethylidene dichloride (1,1 -Dichloroethane)
50000 Formaldehyde
76448 Heptachlor
118741 Hexachlorobenzene
87683 Hexachlorobutadiene
77474 Hexachlorocyclopentadiene
67721 Hexachloroe thane
822060 Hexamethylene-1,6-diisocyanate
680319 Hexamethylphosphoramide
110543 Hexane
302012 Hydrazine
7647010 Hydrochloric acid [recommended technicalcorrection:
Hydrochloric acid (hydrogen chloride)(gas only)]
7664393 Hydrogen fluoride (Hydrofluoric acid)
123319 Hydroquinone
78591 Isophorone
-------
List of Regulated Air Pollutants - continued
page ten
CAS number Chemical name
Lindane (all isomers) [Recommended technical correction:
1,2,3,4,5,6-Hexachlorocyclohexane (all stereo isomers, including
lindane)]
108316
Maleic anhydride
67561
Methanol
72435
Methoxychlor 74839 Methyl bromide (Bromomethane)
74873
Methyl chloride (Chloromethane)
71556
Methyl chloroform (1,1,1-Trichloroethane)
78933
Methyl ethyl ketone (2-Butanone)
60344
Methyl hydrazine [recommended technical correction:
Methylhydrazine]
74884
Methyl iodide (Iodomethane)
108101
Methyl isobutyl ketone (Hexone)
624839
Methyl isocyanate
80626
Methyl methacrylate
1634044
Methyl tert butyl ether [recommended technical correction:
Methyl tert-butyl ether]
101144
4,4-Methylene bis(2-chioroaniline) [recommended technical correction:
4,4'-Methylenebis(2-chloroaniline]
75092
Methylene chloride (Dichloromethane)
101688
Methylene diphenyl diisocyanate (MDI) [recommended technical
correction: 4-4' Methylenediphenyl diisocyanate (MDI)]
101779
4,4,-Methylenedianiline
91203
Naphthalene
98953
Nitrobenzene
92933
4-Nitrobiphenyl
100027
4-Nitrophenol
79469
2-Nitropropane
684935
N-Nitroso-N-methylurea
62759
N-Nitrosodimethylamine
59892
N-Nitrosomorpholine
56382
Parathion
82688
Pentachloronitrobenzene (Quintobenzene)
87865
Pentachlorophenol
108952
Phenol
106503
p-Phenylenediamine
75445
Phosgene
7803512
Phosphine
7723140
Phosphorus
85449
Phthalic anhydride
-------
List of Regulated Air Pollutants - continued
page eleven
CAS number Chemical name
1336363 Polychlorinated biphenyls (Aroclors)
1120714 1,3-Propane sultone
57578 beta-Propiolactone
123386 Propionaldehyde
114261 Propoxur (Baygon)
78875 Propylene dichloride (1,2-Dichloropropane)
75569 Propylene oxide
75558 1,2-Propylenimine (2-Methyl aziridinc)
91225 Quinoline
106514 Quinone
100425 Styrene
96093 Styrcne oxide
1746016 2,3,7,8-Tetrachlorodibenzo-p-dioxin
79345 1,1,2,2-Tetrachloroethane
127184 Tetrachloroethy lene (Perchloroethy lene)
7550450 Titanium tetrachloride
108883 Toluene
95807 2,4-Toluene diamine [recommended technical correction:
2,4-Toluenediamine]
584849 2,4-Toluene diisocyanate
95534 o-Toluidine
8001352 Toxaphene (chlorinated camphene)
120821 1,2,4-Trichlorobenzene
79005 1,1,2-Trichloroethane
79016 Trichloroethylene
95954 2,4,5-Trichlorophenol
88062 2,4,6-Trichlorophenol
121448 Triethylamine
1582098 Trifluralin
540841 2,2,4-Trimethylpentane
108054 Vinyl acetate
593602 Vinyl bromide
75014 Vinyl chloride
75354 Vinylidene chloride (1,1-Dichloroethylene)
1330207 Xylenes (isomers and mixture)
95476 o-Xylenes [recommended technical correction: o-Xylene]
108383 m-Xylenes [recommended technical correction: m-Xylene]
106423 p-Xylenes [recommended technical correction:p-Xylene]
0 Antimony Compounds
-------
List of Regulated Air Pollutants - continued
page twelve
CAS number Chemical name
0 Arsenic Compounds (inorganic including arsine)
0 Beryllium Compounds
0 Cadmium Compounds
0 Chromium Compounds
0 Cobalt Compounds
0 Coke Oven Emissions
0 Cyanide Compounds [1]
0 Glycol ethers [2]
0 Lead Compounds
0 Manganese Compounds
0 Mercury Compounds
0 Fine mineral fibers [3]
0 Nickel Compounds
0 Polycylic Organic Matter [4] [recommended technical correction:
Polycyclic Organic Matter]
0 Radionuclides (including radon) [5]
0 Selenium Compounds
NOTE: For all listings above which contain the word "compounds" and for glycol ethers
the following applies: Unless otherwise specified, these listings are defined as including any
unique chemical substance that contains the named chemical (i.e., antimony, arsenic, etc.) as part
of that chemical's infrastructure.
1 X'CN where X = H* or any other group where a formal dissociation may occur.
For example KCN or Ca(CN)2
2 Includes mono- and di- ethers of ethylene glycol, diethylene glycol, and triethylene
glycol R-(OCH2CH2)n-OR' where
n= 1,2, or 3
R = alkyl or aiyl groups
R' = R, H, or groups which, when removed, yield glycol ethers with the structure:
R-(OCH2CH)-OH.* [recommended technical correction: R-(OCH2CH2)-OH] Polymers are
excluded from the glycol category.
3 Includes mineral fiber emissions from facilities manufacturing or processing glass, rock,
or slag fibers (or other mineral derived fibers) of average diameter 1 micrometer or less.
4 Includes organic compounds with more than one benzene ring, and which have a boiling
point greater than or equal to 100°C." [recommended technical correction: Limited to, or refers
to, products from incomplete combustion of organic compounds (or material) and pyrolysis
processes having more than one benzene ring, and which have a boiling point greater than or
equal to 100°C.]
5 A type of atom which spontaneously undergoes radioactive decay.
-------
List of Regulated Air Pollutants - continued
page thirteen
VI. Pollutants l isted Under Section 112M;
Section 112(r)(3) requires that EPA promulgate an initial list of at least 100 substances
with threshold quantities which would cause or may reasonably be anticipated to cause death,
injury, or serious adverse effects to human health or the environment if accidentally released.
EPA's rule to implement 112(r)(3) was published in the Federal Register on January 31,19943
(59 FR 4478). Tlie list of substances includes 77 acutely toxic substances, 63 flammable gases
and volatile flammable liquids, and commercial explosives (classified by the Department of
Transportation in Division 1.1). The listed pollutants are shown on the attached Tables 1 and 2
from the FR notice.
-------
TABLE 1 TO §68.130 - LIST OF REGULATED TOXIC SUBSTANCES AND THRESHOLD
QUANTITIES FOR ACCIDENTAL RELEASE PREVENTION
[ALPHABETICAL ORDER - 77 SUBSTANCES]
Chemical Name
CAS No
Threshold Basis
Quantity for
(lbs) Listing
Acrolein [2-Propenal]
107-02-8
5,000
b
Acrylonitrile [2-Propenenitrile]
107-13-1
20,000
b
Acrylyl chloride [2-Propenoyl
chloride]
814-68-6
5,000
b
Allyl alcohol [2-Propen-l-ol]
107-18-6
15,000
b
Allylamine [2-Propen-1-amine]
107-11-9
10,000
b
Ammonia (anhydrous)
7664-41-7
10,000
a,
Ammonia (cone 20% or greater)
7664-41-7
20,000
a,
Arsenous trichloride
7784-34-1
15,000
b
Arsine
7784-42-1
1,000
b
Boron trichloride [Borane, trichloro-]
10294-34-5
5,000
b
Boron trifluoride [Borane, trifluoro-]
7637-07-2
5,000
b
Boron trifluoride compound with methyl
ether (1:1) [Boron,
trifluoro[oxybis[metane]]-, T-4-
353-42-4
15,000
b
Bromine
7726-95-6
10,000
a,
Carbon disulfide
75-15-0
20,000
b
Chlorine
7782-50-5
2,500
a,
Chlorine dioxide [Chiorine oxide
(C102)]
10049-04-4
1,000
c
Chloroform [Methane, trichloro-]
67-66-3
20,000
b
Chloromethyl ether [Methane,
oxybis[chloro-]
542-88-1
1,000
b
Chloromethyl methyl ether [Methane,
chloromethoxy-]
107-30-2
5,000
b
Crotonaldehyde [2-Butenal]
4170-30-3
20,000
b
Crotonaldehyde, (E)- [2-Butenal, (E)-]
123-73-9
20,000
b
Cyanogen chloride
506-77-4
10,000
c
Cyclohexylamine [Cyclohexanamine]
108-91-8
15,000
b
Diborane
19287-45-7
2,500
b
Dimethyldichlorosilane [Silane,
dichlorodimethyl-]
in
CO
r*
i
m
r*
5,000
b
1,1-Dimethylhydrazine [Hydrazine,
1,1-dimethyl-]
57-14-7
15,000
b
Epichlorohydrin [Oxirane,
(chloromethyl)-]
106-89-8
20,000
b
Ethylenediamine [1,2-Ethanediamine]
107-15-3
20,000
b
-------
Chemical Name*
CAS No
Threshold
Quantity
llha)
Basis
for
b
Ethyleneimine [Aziridine]
151-56-4
10,000
Ethylene oxide [Oxirane]
75-21-8
10,000
a, b
Fluorine
7782-41-4
1,000
b
Formaldehyde (solution)
50c00-0
15,000
b
Furan
110-00-9
5,000
b
Hydrazine
302-01-2
15,000
b
Hydrochloric acid (cone 30% or greater)
7647-01-0
15,000
d
Hydrocyanic acid
74-90-8
2,500
a, b
Hydrogen chloride (anhydrous)
[Hydrochloric acid]
7647-01-0
5,000
a
Hydrogen fluoride/Hydrofluoric acid
(cone 50% or greater) {Hydrofluoric
acid]
7664-39-3
1,000
a, b
Hydrogen selenide
7783-07-5
500
b
Hydrogen sulfide
7783-06-4
10,000
a, b
Iron, pentacarbonyl- [Iron carbonyl
-------
Chemical Name
CAS No
Threshold Basis
Quantity for
fibs) Listing
Peracetic acid [Ethaneperoxoic acid]
Perchloromethylmercaptan
[Methanesulfenyl chloride, trichloro-]
Phosgene [Carbonic dichloride]
Phosphine
[Phosphory1
Phosphorus oxychloride
chloride]
Phosphorus trichloride
trichloride]
[Phosphorous
Piperidine
Propionitrile
[Propanenitrile]
[Carbonochloridic
Propyl chloroformate
acid, propylester]
Propyleneimine [Aziridine, 2-methyl-]
Propylene oxide [Oxirane, methyl-]
Sulfur dioxide (anhydrous)
Sulfur tetrafluoride [Sulfur fluoride
(SF4), (T-4)-]
Sulfur trioxide
Tetramethyllead
tetramethyl-]
Tetranitromethane
tetranitro-]
[Plumbane,
[Methane,
Titanium tetrachloride [Titanium
chloride (TiC14) (T-4)-]
Toluene 2,4-diisocyanate [Benzene,
2,4-diisocyanato-l-methyl-]'
Toluene 2,6-diisocyanate [Benzene,
1,3-diisocyanato-2-methyl-]1
Toluene diisocyanate (unspecified
isomer) IBenzene,
1,3-diisocyanatomethyl-]1
Trimethylchlorosilane
chlorotrimethyl-]
Vinyl acetate monomer
ethenyl ester]
[Silane,
[Acetic acid
79-21-0
594-42-3
75-44-5
7803-51-2
10025-87-3
110-89-4
107-12-0
109-61-5
75-55-8
75-56-9
7446-09-5
7783-60-0
7446-11-9
75-74-1
509-14-8
7550-45-0
584-84-9
91-08-7
26471-62-5
75-77-4
108-05-4
10,000
10,000
500
5,000
5,000
7719-12-2 15,000
15,000
10,000
15,000
10,000
10,000
5,000
2,500
10,000
10,000
10,000
2,500
10,000
10,000
10,000
10,000
15,000
b
b
a,
b
b
b
b
b
b
b
a,
b
a,
b
lThe mixture exemption in §68.115(b)(1) does not apply to the substance.
Basis for Listing:
*Handated for listing by Congress.
"On EHS list, vapor pressure 10 mmHg or greater.
"Toxic gas.
"Toxicity of hydrogen chloride, potential to release hydrogen chloride, and
history of accidents.
Toxicity of sulfur trioxide and sulfuric acid, potential to release sulfur
trioxide, and history of accidents.
-------
TABLE 2 TO §68.130 - LIST OF REGULATED TOXIC SUBSTANCES AND THRESHOLD
QUANTITIES FOR ACCIDENTAL RELEASE PREVENTION
[CAS NUMBER ORDER - 77 SUBSTANCES]
Ma.
50-00-0
57-14-7
60-34-4
67-66-3
74-87-3
74-90-8
74-93-1
75-15-0
75-21-8
75-44-5
75-55-8
75-56-9
75-74-1
75-77-4
75-78-5
75-79-6
78-82-0
79-21-0
79-22-1
91-08-7
106-89-8
107-02-8
107-11-9
107-12-0
107-13-1
107-15-3
107-18-6
107-30-2
rhemiral Name
Formaldehyde (solution)
1,1-Dimethylhydrazine [Hydrazine,
1,1-dimethyl-J
Methyl hydrazine [Hydrazine, methyl-]
Chloroform [Methane, trichloro-]
Methyl chloride [Methane, chloro-]
Hydrocyanic acid
Methyl mercaptan [Methanethiol]
Carbon disulfide
Ethylene oxide [Oxirane]
Phosgene [Carbonic dichloride]
Propyleneimine [Aziridine, 2-methyl-]
Propylene oxide [Oxirane, methyl-]
Tetramethyllead [Plumbane,
tetramethyl-]
Trimethylchlorosilane [Silane,
chlorotrimethyl-]
Dimethyldichlorosilane [Silane,
dichlorodimethyl-]
Methyltrichlorosilane [Silane,
trichloromethyl-J
Isobutyronitrile
2-methyl-]
Peracetic acid
[Propanenitrile,
[Ethaneperoxoic acid]
[Carbonochloridic
.Methyl chloroformate
acid, methylester]
Toluene 2,6-diisocyanate [Benzene,
1,3-diisocyanato-2-methyl-]1
Epichlorohydrin [Oxirane,
(chloromethyl)-]
Acrolein [2-Propenal]
Allylamine [2-Propen-l-amine]
Propionitrile [Propanenitrile]
Acrylonitrile [2-Propenenitrile]
Ethylenediamine [1,2-Ethanediamine]
Allyl alcohol [2-Propen-l-ol]
Chloromethyl methyl ether [Methane,
chloromethoxy-]
Threshold
Quantity
llhaj
15,000
15,000
15,000
20,000
10,000
2,500
10,000
20,000
10,000
500
10,000
10,000
10,000
10,000
5,000
5,000
20,000
10,000
5,000
10,000
20,000
5,000
10,000
10,000
20,000
2(T, 000
15,000
5,000
Basis
for
Listing
b
b
b
b
a
a,
b
b
a,
a,
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
b
-------
CAS MO.
108-05-4
108-23-6
108-91-8
109-61-5
110-00-9
110-89-4
123-73-9
126-98-7
151-56-4
302-01-2
353-42-4
506-77-4
509-14-8
542-88-1
556-64-9
584-84-9
594-42-3
624-83-9
814-68-6
4170-30-3
7446-09-5
7446-11-9
7550-45-0
7637-07-2
7647-01-0
7647-01-0
Chemical Name
Vinyl acetate monomer [Acetic acid
ethenyl ester]
Isopropyl chloroformate
[Carbonochloridic acid, 1-methylethyl
ester]
Cyclohexylamine [Cyclohexanamine]
Propyl chloroformate [Carbonochloridic
acid, propylester]
Fur an
Piperidine
Crotonaldehyde, (E) [2-Butenal, (E)-]
Methacryloni trile [2-Propeneni trile,
2-methyl-]
Ethyleneimine [Aziridine]
Hydrazine
Boron trifluoride compound with methyl
ether (1:1) [Boron,
tri£luoro[oxybis[metane]]-, T-4-
Cyanogen chloride
Tetranitromethane [Methane,
tetranitro-]
Chloromethyl ether [Methane,
oxybis[chloro-]
Methyl thiocyanate [Thiocyanic acid,
methyl ester]
Toluene 2,4-diisocyanate [Benzene,
2,4-diisocyanato-l-methyl-]1
Perchloromethylmercaptan
[Methanesulfenyl chloride, trichloro-]
Methyl isocyanate [Methane,
isocyanato-]
Acrylyl chloride [2-Propenoyl
chloride]
Crotonaldehyde [2-Butenal]
Sulfur dioxide (anhydrous)
Sulfur trioxide
Titanium tetrachloride [Titanium
chloride (TiC14) (T-4)-]
Boron trifluoride [Borane, trifluoro-]
Hydrochloric acid (cone 30% or greater)
Hydrogen chloride (anhydrous)
[Hydrochloric acid]
Threshold Basis
Quantity for
(IbS) List-itm
15,000 b
15,000 b
15,000 b
15,000 b
5,000 b
15,000 b
20,000 b
10,000 b
10,000 b
15,000 b
15,000 b
10,000 c
10,000 b
1,000 b
20,000 b
10,000 a
10,000 b
10,000 a, b
5,000 b
20,000 b
5,000 a, b
10,000 a, b
2,500 b
5,000 b
15,000 d
5,000 a
-------
CAS NO.
7664-39-3
7664-41-7
7664-41-7
7697-37-2
7719-12-2
7726-95-6
7782-41-4
7782-50-5
7783-06-4
7783-07-5
7783-60-0
7784-34-1
7784-42-1
7803-51-2
8014-95-7
10025-87-3
10049-04-4
10102-43-9
10294-34-5
13463-39-3
13463-40-6
19287-45-7
26471-62-5
Chemical Name
Hydrogen fluoride/Hydrofluoric acid
(cone 50% or greater) [Hydrofluoric
acid]
Ammonia (anhydrous)
Ammonia (cone 20% or greater)
Nitric acid (cone 80% or greater)
Phosphorus trichloride [Phosphorous
trichloride]
Bromine
Fluorine
Chlorine
Hydrogen sulfide
Hydrogen selenide
Sulfur tetrafluoride [Sulfur fluoride
(SF4), (T-4)-]
Arsenous trichloride
Arsine
Phosphine
Oleum (Fuming Sulfuric acid) [Sulfuric
acid, mixture with sulfur trioxide]1
Phosphorus oxychloride
chloride]
Chlorine dioxide
(C102)]
[Phosphory1
[Chlorine oxide
Nitric oxide [Nitrogen oxide (NO)]
Boron trichloride [Borane, trichloro-]
Nickel carbonyl
Iron, pentacarbonyl- [Iron carbonyl
(Fe(CO)5), (TB-5-11)-]
Diborane
Toluene diisocyanate (unspecified
isomer) [Benzene,
1,3-diisocyanatomethyl-]1
Threshold
Quantity
iibsj :
1,000
10,000
20,000
15,000
15,000
10,000
1,000
2,500
10,000
500
2,500
15,000
1,000
5,000
10,000
5,000
1,000
10,000
5,000
1,000
2,500
2,500
10,000
Basis
for
Listing
a, b
a, b
a, b
b
b
a, b
b
a, b
a, b
b
b
b
b
b
e
b
b
b
b
b
a
lThe mixture exemption in 568.115(b)(1) does not apply to the substance.
Basis for Listing:
"Mandated for listing by Congress.
*On EHS list, vapor pressure 10 mmHg or greater.
*70x10 gas.
"Toxicity of hydrogen chloride, potential to release hydrogen chloride, and
history of accidents.
Toxicity of sulfur trioxide and sulfuric acid, potential to release sulfur
trioxide, and history of accidents.
-------
TABLE 3 TO §68.130 - LIST OF REGULATED FLAMMABLE SUBSTANCES AND
QUANTITIES FOR ACCIDENTAL RELEASE PREVENTION
[ALPHABETICAL ORDER - 63 SUBSTANCES]
THRESHOLD
Chemical Name
CAS Ho.
Acetaldehyde
Acetylene [Ethyne]
75-07-0
74-86-2
Threshold
Quantity
flbs 1
10,000
10,000
Basis
for
Listing
g
f
Bromotrifluorethylene [Ethene,
bromotrifluoro-]
598-73-2
10,000
f
1,3-Butadiene
106-99-0
10,000
f
Butane
106-97-8
10,000
f
1-Butene
106-98-9
10,000
f
2-Butene
107-01-7
10,000
f
Butene
25167-67-3
10,000
f
2-Butene-cis
590-18-1
10,000
f
2-Butene-trans [2-Butene, (E)]
624-64-6
10,000
f
Carbon oxysulfide [Carbon oxide
sulfide (COS)]
463-58-1
10,000
f
Chlorine monoxide [Chlorine oxide]
7791-21-1
10,000
f
2-Chloropropylene [1-Propene,
2-chloro-]
557-98-2
10,000
g
1-Chloropropylene [1-Propene,
1-chloro-]
590-21-6
10,000
g
Cyanogen [Ethanedinitrile]
460-19-5
10.000
f
Cyclopropane
75-19-4
10,000
f
Dichlorosilane [Silane, dichloro-]
4109-96-0
10,000
f
Difluoroethane [Ethane, 1,1-difluoro-)
75-37-6
10,000
f
Dimethylamine [Methanamine, N-methyl-]
124-40-3
10,000
f
2.2-Dimethylpropane [Propane,
2,2-dimethyl-]
463-82-1
10,000
f
Ethane
74-84-0
10,000
f
Ethyl acetylene [1-Butyne]
107-00-6
10,000
f
Ethylamine [Ethanamine]
75-04-7
10,000
f
Ethyl chloride [Ethane, chloro-]
75-00-3
10,000
f
Ethylene [Ethene]
74-85-1
10,000
f
Ethyl ether [Ethane, 1,1¦-oxybis-]
60-29-7
10,000
g
Ethyl mercaptan [Ethanethiol]
75-08-1
10,000
g
Ethyl nitrite [Nitrous acid, ethyl
ester]
109-95-5
10,000
f
Hydrogen
1333-74-0
10,000
f
-------
Threshold
Quantity
Basis
for
Isobutane [Propane, 2-methyl]
75-28-5
\ f
10,000
f
Isopentane {Butane, 2-methyl-]
78-78-4
10,000
g
Isoprene [1,3-Butadiene, 2-methyl-]
78-79-5
10,000
9
Isopropylamine [2-Propanamine]
75-31-0
10,000
9
Isopropyl chloride [Propane,
2-chloro-]
75-29-6
10,000
9
Methane
74-82-8
10,000
f
Methylamine [Me th&namine]
74-69-5
10,000
f
3-Methyl-l-butene
563-45-1
10,000
f
2-Methy1-1-butene
563-46-2
10,000
9
Methyl ether [Methane, oxybis-]
115-10-6
10,000
f
Methyl formate [Formic acid, methyl
ester]
107-31-3
10,000
9
2-Me thylpropene [1-Propene, 2-methyl-J
115-11-7
10,000
f
1,3-Pentadiene
504-60-9
10,000
f
Pentane
109-66-0
10,000
g
1-Pentene
109-67-1
10,000
9
2-Pentene, (E)-
646-04-8
10,000
9
2-Pentene, (Z)-
627-20-3
10,000
9
Propadiene [1,2-Propadiene]
463-49-0
10,000
f
Propane
74-98-6
10,000
f
Propylene [1-Propene]
115-07-1
10,000
f
Propyne [1-Propyne]
74-99-7
10,000
f
Silane
7803-62-5
10,000
f
Tetrafluoroethylene [Ethene,
tetrafluoro-]
116-14-3
10,000
f
Tetramethylsilane [Silane,
tetramethyl-]
75-76-3
10,000
g
Trichlorosilane [Silane, trichloro-]
10025-78-2
10,000
9
Trifluorochloroethylene [Ethene,
chlorotrifluoro-]
79-38-9
10,000
f
Trimethylamine [Methanamine,
M,N-dimethyl-J
75-50-3
10,000
f
Vinyl acetylene [l-Buten-3-yne]
689-97-4
10,000
f
Vinyl chloride [Ethene, chloro-]
75-01-4
10,000
a.
Vinyl ethyl ether [Ethene, ethoxy-]
109-92-2
10,000
9
Vinyl £luoride [Ethene, fluoro-]
75-02-5
10,000
f
-------
Threshold Basis
Quantity for
Chemical Name cas mo. aba) Listing
Vinylidene chloride [Ethene, 75-35-4 10,000 g
1,1-dichloro-]
Vinylidene fluoride [Ethene, 75-38-7 10,000 f
1,1-difluoro-]
Vinyl methyl ether [Ethene, methoxy-] 107-25-5 10,000 f
Basis for Listing:
^Mandated for listing by Congress.
'Flammable gas.
"Volatile flammable liquid.
-------
TABLE 4 TO §68.130 - LIST OF REGULATED FLAMMABLE SUBSTANCES AND THRESHOLD
QUANTITIES FOR ACCIDENTAL RELEASE PREVENTION
[CAS NUMBER ORDER - 63 SUBSTANCES]
Threshold
Quantity
Basis
for
60-29-7
Ethyl ether [Ethane,
1,1'-oxybis-]
60-29-7
10,000
g
74-82-8
Methane
74-82-8
10,000
f
74-84-0
Ethane
74-84-0
10,000
f
74-85-1
Ethylene [Ethene]
74-85-1
10,000
f
74-86-2
Acetylene [Ethyne]
74-86-2
10,000
f
74-89-5
Methylamine [Methanamine]
74-89-5
10,000
f
74-98-6
Propane
74-98-6
10,000
f
74-99-7
Propyne [1-Propyne]
74-99-7
10,000
f
75-00-3
Ethyl chloride [Ethane,
chloro-]
75-00-3
10,000
f
75-01-4
Vinyl chloride [Ethene,
chloro-]
75-01-4
10,000
a,
75-02-5
Vinyl fluoride [Ethene,
fluoro-]
75-02-5
10,000
f
75-04-7
Ethylamine [Ethanamine]
75-04-7
10,000
f
75-07-0
Acetaldehyde
75-07-0
10,000
g
75-08-1
Ethyl mercaptan
[Ethanethiol]
75-08-1
10,000
g
75-19-4
Cyclopropane
75-19-4
10,000
f
75-28-5
Isobutane [Propane,
2-methyl]
75-28-5
10,000
f
75-29-6
Isopropyl chloride
[Propane, 2-chloro-]
75-29-6
10,000
g
75-31-0
Isopropylamine
[2-Propanamine]
75-31-0
10,000
g
75-35-4
Vinylidene chloride
[Ethene, 1,1-dichloro-]
75-35-4
10,000
g
75-37-6
Di £luoroethane [Ethane,
1,1-difluoro-]
75-37-6
10,000
f
75-38-7
Vinylidene fluoride
[Ethene, 1,1-di fluoro-]
75-38-7
10,000
f
75-50-3
Trimethylamine
[Methanamine, N,N-dimethyl-]
75-50-3
10,000
f
75-76-3
Tetramethylsilane [Silane,
tetramethyl-]
75-76-3
10,000
g
78-78-4
Isopentane [Butane,
2-methyl-]
78-78-4
10,000
g
78-79-5
Isoprene [1,3-Butadiene,
2-methyl-]
78-79-5
10,000
g
-------
Threshold
Quantity
Basis
for
mm i
79-38-9
Tr i fluorochloroethylene
[Ethene, chlorotrifluoro-]
79-38-9
10,000
f
106-97-8
Butane
106-97-8
10,000
f
106-98-9
1-Butene
106-98-9
10,000
f
106-99-0
1,3-Butadiene
106-99-0
10,000
f
107-00-6
Ethyl acetylene [1-Butyne]
107-00-6
10,000
f
107-01-7
2-Butene
107-01-7
10,000
f
107-25-5
Vinyl methyl ether [Ethene,
methoxy-]
107-25-5
10,000
f
107-31-3
Methyl formate [Formic
acid, methyl ester]
107-31-3
10,000
S
109-66-0
Pentane
109-66-0
10,000
g
109-67-1
1-Pentene
109-67-1
10,000
9
109-92-2
Vinyl ethyl ether [Ethene,
ethoxy-]
109-92-2
10,000
a
109-95-5
Ethyl nitrite [Nitrous
acid, ethyl ester]
109-95-5
10,000
f
115-07-1
Propylene [1-Propene]
115-07-1
10,000
f
115-10-6
Methyl ether [Methane,
oxybis-]
115-10-6
10,000
f
115-11-7
2-Methylpropene [1-Propene,
2-methyl-]
115-11-7
10,000
f
116-14-3
Tetrafluoroethylene
[Ethene, tetrafluoro-]
116-14-3
10,000
f
124-40-3
Dimethylamine [Methanamine,
N-methyl-]
124-40-3
10,000
f
460-19-5
Cyanogen [Ethanedinitrile]
460-19-5
10,000
f
463-49-0
Propadiene [1,2-Propadiene]
463-49-0
10,000
f
463-58-1
Carbon oxysulfide [Carbon
oxide sulfide (COS)j
463-58-1
10,000
f
463-82-1
2,2-Dimethylpropane
[Propane, 2,2-dimethyl-]
463-82-1
10,000
f
504-60-9
1,3-Pentadiene
504-60-9
10,000
f
557-98-2
2-Chloropropylene
[1-Propene, 2-chloro-]
557-98-2
10.000
g
563-45-1
3-Methy1-1-butene
563-45-1
10,000
f
563-46-2
2-Methyl-1-butene
563-46-2
10,000
g
590-18-1
2-Butene-cis
590-18-1
10,000
f
590-21-6
1-Chloropropylene
590-21-6
10,000
g
[1-Propene, 1-chloro-]
-------
CAS MO.
598-73-2
624-64-6
627-20-3
646-04-8
689-97-4
1333-74-0
4109-96-0
7791-21-1
7803-62-5
10025-78-2
Chemical Name
Bromotrifluorethylene
[Ethene, bromotrifluoro-]
2-Butene-trans
(E) ]
2-Pentene, (Z)
2-Pentene, (E) -
Vinyl acetylene
[l-Buten-3-yne]
Hydrogen
Dichlorosilane
dichloro-]
[2-Butene,
Chlorine monoxide
oxide]
Silane
Trichlorosilane [Silane,
trichloro-]
25167-67-3 Butene
Basis for Listing:
Mandated for listing by Congress.
'Flammable gas.
"Volatile flammable liquid.
e*s Mo.
[Silane,
[Chlorine
Threshold Basis
Quantity for
(lbs)
598-73-2 10,000
624-64-6 10,000
627-20-3 10,000
646-04-8 10,000
689-97-4 10,000
1333-74-0 10,000
4109-96-0 10,000
7791-21-1 10,000
7803-62-5 10,000
10025-78-2 10,000
25167-67-3 10,000
Listing
f
9
g
f
f
f
f
g
-------
APPENDIX B
INFORMATION RESOURCES
-------
INFORMATION RESOURCES
ON-LINE RESOURCES
For Access to Information and Professionals Concerning Pollution Prevention and
Environmental Compliance:
Envlrotense
Enviro$ense is a free, public, integrated environmental information system. It is designed to:
Assist users in finding and implementing common sense solutions, such as
pollution prevention, to environmental problems.
Facilitate the sharing of technology, procedures, and experience across federal
agencies, other governmental organizations, manufacturers, suppliers, researchers,
and others.
Encourage the development and demonstration of pollution prevention
technologies suitable for export.
Help federal agencies attain compliance with the Right-to-Know provisions of
Executive Order 12856, which requires Federal compliance with Right-to-Know
law and pollution prevention requirements.
EnviroSense is accessible by modem and via the World Wide Web on the Internet:
Via Modem: The telephone number is (703) 908-2092. Use a personal computer with a modem
and communications software set to the following: (Data bits=8, parity=N, and stop bits=l);
Emulation - ANSI or VT-100.
Via the Internet: The address is http://wastenot.inel.gov/envirosense/ You need to have access
to the Internet and World Wide Web navigational software such as Mosaic.
For Information and Documents on the Clean Air Act:
Technology Transfer Network (TTN) Bulletin Board System
The TTN is operated by the EPA's Office of Air Quality Planning & Standards (OAQPS), the
system can be accessed with a computer by calling (919) 541-1447 for 9600 & 19200 bps
modems or (919) 541-5742 for 1200 & 2400 bps modems (Data bits=8, parity=N, and stop
bitsal). Help Line: (919)541-5384.
-------
KEY DOCUMENTS
General Pollution Prevention
United States Environmental Protection Agency, Office of Pollution Prevention and Toxics.
"Pollution Prevention 1991, Progress on Reducing Industrial Pollutants." Publication No.
EPA 21P-3003, Washington D.C., October 1991.
United States Environmental Protection Agency, Office of Pollution Prevention and Toxics.
"Pollution Prevention Directory." Publication No. EPA 742-B-94-005, Washington D.C.,
September 1994.
United States Environmental Protection Agency, Office of Pollution Prevention and Toxics.
"Abstracts of Pollution Prevention Case Study Sources." Publication No. EPA 742-B-94-
001, Washington D.C., January 1994.
United States Environmental Protection Agency, Office of Pollution Prevention and Toxics.
"Summary of Pollution Prevention Case Studies with Economic Data (by SIC Codes)."
Publication No. EPA 742-S-94-001, Washington D.C., January 1994.
Federal Facility Pollution Prevention
United States Environmental Protection Agency, Office of Federal Facilities Enforcement.
"Pollution Prevention in the Federal Government: Guide for Developing Pollution
Prevention Strategies for Executive Order 12856 and Beyond." Publication No. EPA
300-B-94-007, Washington, D.C., April 1994.
United States Environmental Protection Agency, Office of Research and Development. "Federal
Facility Pollution Prevention: Tools for Compliance." Publication No. EPA 600-R-94-
154, Cincinnati, OH, September 1994.
United States Environmental Protection Agency, Office of Enforcement and Compliance
Assurance. "Guidance for Implementing Executive Order 12856: Federal Compliance
with Right-to-Know Laws and Pollution Prevention Requirements." Publication No. EPA
300-B-95-005, Washington, D.C., April 1995.
United States Environmental Protection Agency, Office of Enforcement and Compliance
Assurance. "Catalogue of Federal Agency Environmental Compliance/Management
Documents." Publication No. EPA 300-B-94-011, Washington, D.C., June 1994.
F«rlHtv Planning
United States Environmental Protection Agency, Office of Research and Development. "Facility
Pollution Prevention Guide." Publication No. EPA/600/R-92/088 Washington, D.C., May
1992.
-------
True Cost Accounting
United States Environmental Protection Agency, Office of Policy, Planning and Evaluation and
Office of Solid Waste. "Pollution Prevention Benefits Manual, Volume I, Phase II."
Washington D.C., October 1989 (available from Pollution Prevention Clearinghouse).
United States Environmental Protection Agency, Office of Pollution Prevention and Toxics.
'Total Cost Assessment: Accelerated Industrial Pollution Prevention through Innovative
Project Financial Analysis." Washington D.C., May 1992 (available from Pollution
Prevention Clearinghouse).
United States Environmental Protection Agency, Office of Research and Development "A
Primer for Financial Analysis of Pollution Prevention Projects." Publication No.
EPA/600/R-93/059, Washington, D.C., April 1993.
United States Environmental Protection Agency, Office of Pollution Prevention and Toxics.
"P2/Finance User's Manual, Pollution Prevention Financial Analysis and Cost Evaluation
System for Lotus 1-2-3 For DOS, Version 3.4a." Publication No. EPA/742-B-94-003,
Washington, D.C., January 1994.
United States Environmental Protection Agency, Office of Pollution Prevention and Toxics.
"Stakeholder's Action Agenda: A Report of the Workshop on Accounting and Capital
Budgeting for Environmental Costs, December 5-7,1993." Publication No. EPA/742-R-
94-003, Washington, D.C., May 1994.
United States Environmental Protection Agency, Office of Pollution Prevention and Toxics.
"Workgroup Proceedings: Accounting and Capital Budgeting for Environmental Costs
Workshop, December 5-7, 1993." Publication No. EPA/742-R-94-002, Washington,
D.C., May 1994.
United States Environmental Protection Agency, Office of Pollution Prevention and Toxics.
"Design For The Environment, Directory of EPA's Environmental Network for
Managerial Accounting and Capital Budgeting." Publication No. EPA/742-B-94-004,
Washington, D.C., May 1994.
I Afe Cvcle Analysis
United States Environmental Protection Agency, Office of Research and Development. "Life-
Cycle Assessment: Inventory Guidelines and Principles." Publication No. EPA/60Q/R-
92/245 Washington, D.C., February 1993.
United States Environmental Protection Agency, Office of Pollution Prevention and Toxics. "The
Use of Life Cycle Assessment in Environmental Labeling." Publication No. EPA/742-R-
93-003, Washington, D.C., September 1993.
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