453N90001
NATICH
NEWSLETTER
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
II /NUN?©©
State and Territorial Air Pollution Program Administrators
Association of Local Air Pollution Control Officials
Produced by the National Air Toxics Information Clearinghouse May 1990
State/Local Spotlight:
Indiana Pursues Air Toxics Regulation
One of seven States currently
without specific air toxics control
requirements, Indiana began col-
lecting information on emissions of
hazardous air pollutants in 1986.
Over the past year, the Indiana
Department of Environmental
Management (IDEM) has met with
numerous environmental, business,
and government groups to discuss
the regulation of hazardous air
pollutants. IDEM has concluded
that establishing a control program
is necessary to fulfill its statutory
mandate to protect the public
health.
Two sources of information
point to the need for a control pro-
gram: 1987 TRIS data and IDEM's
own Toxic Emission Inventory
System (TEIS). TRIS ranked In-
diana seventh in the nation in
routine air releases (56,490 tons of
air toxics in 1987). TEIS includes
survey data and information from
approximately 2,700 sources par-
ticipating in Indiana's permit pro-
gram. These data indicate that
over 92 percent of the sources may
be of concern to public health
based on a simplified screening
analysis.
Additional impetus for controls
comes from the Great Lakes Toxic
Substances Control Agreement
(May 1986).* Indiana is one of the
eight States committed to develop-
ing an inventory and pursuing
regulatory authority to require
Best Available Control Technology
(BACT) on all new and existing
sources.
*See related article in the March
1990 (p. 7) and March 1987 (p. 2)
issues of the Newsletter.
(continued on page 8)
EPA Updates Cancer Risk Information
Last May, EPA supplied Con-
gressman Henry A. Waxman, at
his request, with information on
205 facilities estimated to pose
maximum individual cancer risks
(MIR) of greater than 1 in 1,000.
The data contained in the EPA's
Air Toxics Exposure and Risk In-
formation System (ATERIS) are
also available to the public through
the NATICH Data Base of State
and Local Activities. Because the
data were outdated, EPA made a
commitment to reassess the
facilities and update emissions and
risk information. The results of the
EPA reassessment were made
public on January 10, 1990.
Reassessment Estimates Are Lower
Emission estimates decreased
for 141 of the 184 facilities (77 per-
cent) still in operation. Estimates
increased for 42 facilities (23 per-
cent) and remained unchanged for
1 facility (< 1 percent). In many
cases, the new emissions reported
were lower than those originally in
ATERIS because: (1) more current
emission factors were used, (2)
emissions were plant specific
rather than extrapolated from simi-
lar plants, as was done for some of
the original ATERIS estimates,
and (3) some plants had applied
control technology or instituted
(continued on page 2)
In This Issue
Mid-Atlantic States Form Air
Management Association 2
Clearinghouse Troubleshoots
the NATICH/TRIS Link 3
Oregon Develops Successful
Training Program 4
Ohio Studies Sewage Sludge
Incinerator Emissions 4
Health-Based Program Pro-
vides Tbxics Information 6
Clean Air Act Update -
Air Tbxics 7

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(continued from page 1)
process changes since the earlier
estimates stored in ATERIS were
made, which reduced emissions.
How the Reassessment
Was Carried Out
In order to reassess the 205
facilities, EPA sent Clean Air Act
Section 114 letters requesting up-
dated emissions data. Responses
from 184 of the 205 facilities (the
others were closed or merged)
were evaluated by EPA staff and
used in the revision of the
facilities' estimated emissions.
The updated estimates were
then used to recalculate the
estimate of MIR for each facility
using the Human Exposure Model
(HEM). The HEM is a screening-
level model that is suited to the
level of detail represented by the
emissions data. The HEM uses
simplifying assumptions regarding
source characteristics (e.g., the
maximum concentration generally
was assumed to occur at a distance
of 200 meters from the plant cen-
ter, and all emissions are assumed
to be emitted from the center of
the facility). For pulp and paper
facilities, emissions from waste-
water basins were identified as a
separate source from vent emissions
in calculation of the MIR.
(continued on page 9)
Mid-Atlantic States Form Air Management Association
The States of Delaware, Mary-
land, New Jersey, North Carolina,
Pennsylvania, and Virginia as well
as the District of Columbia, the
City of Philadelphia, and Pennsyl-
vania's Allegheny County have
formed a regional air quality con-
sortium called the Mid-Atlantic
Regional Air Management Asso-
ciation (MARAMA) (Figure 1).
The governors of the six mid-
Atlantic States made the announce-
ment at the National Governors'
Association meeting in February.
According to MARAMA's
three-page agreement signed by
the six governors, two mayors, and
a county board of commissioners
chairman, the purpose of the
agreement is "to provide a forum
and basis for cooperation among
the member agencies in addressing
common air quality management
problems and provide for consis-
tency in the remedial actions of
member agencies."
The association sees as its
mission:
•	evaluating current and emerg-
ing air quality issues, problems,
or program requirements that
would require regulatory
response or other action by
MARAMA agencies,
•	developing plans, exchanging
ideas and data to provide
mutual assistance in defining air
quality program requirements
when common problems would
benefit from a regional strategy,
and
• seeking consistency among the
member agencies through
"mutually supportable activities
and measures for the improve-
ment of air quality throughout
the region."
Among the points of
MARAMA's strategy for fulfilling
association objectives were sharing
regulations; cooperating in siting
and operating air monitoring net-
works of members' agencies;
developing plans for complying
with federal control technology
guidelines and emission reduction
targets and developing mutually
supportable strategies for achiev-
ing and maintaining current am-
bient air quality standards for
ozone, PM-10, or other pollutants
in the region where the standard is
not met; and for control of acid
rain, toxic air contaminants, or
other issues.
For more information on
MARAMA, call Robert French at
(302) 736-4791.
Figure 1
MARAMA
2

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Clearinghouse Troubleshoots The NATICH/TRIS Link
Since November 1989, NATICH
has offered an option for linking
directly to the SARA 313 data
base (the Toxics Release Inventory
System or TRIS) while logged into
NATICH (see the July 1989 issue
of the Newsletter). Records show
that use of this option has been
good, indicating that it is a valuable
tool. There has been some confu-
sion, however. This stems from a
number of TRIS idiosyncrasies.
Below are recommended solutions
to a few of the most frequently
encountered stumbling blocks.
Several of these are mentioned
in the news appearing on the
screen once you select the TRIS
option.
As with any NATICH pro-
blems, should you have problems
with the TRIS link that cannot be
solved with the solutions below,
call the Clearinghouse staff.
If you do not have the linkage
option on your main menu: For
security reasons, only governmen-
tal agencies are allowed to access
TRIS through NATICH. The
public must go through the Na-
tional Library of Medicine
(301-496-6531, ask for the TRI
representative). State and local
agencies are identified by their
agency ID, which consists of the
abbreviation of their State and two
numbers. All other users are iden-
tified by either the agency ID
"EPA1" or a blank ID. There is as
yet no way to separate the public
users from other EPA users of the
agency ID "EPA1" (though the
data base administrators are look-
ing into it). The blank agency ID's
are held by individuals with gener-
al access to the National Computer
Center's Natural Databases who
have gone into NATICH without
going through the Clearinghouse
staff. Because of these unknown
affiliations, only those EPA1 users
who are known to the data base
administrators have been given
clearance to access TRIS. Those
with blank agency ID's were not
given access. Consequently, any
federal agency users of NATICH
who have not seen option 10,
NATICH/TRIS link, on their main
NATICH menu should contact the
Clearinghouse staff so they may be
verified and authorized.
If you cannot move around or ex-
it once your are in TRIS: Moving
around in TRIS requires PF keys,
which most PC keyboards lack.
You can emulate these keys with
your keyboard, using your com-
munication software. If you use
CROSSTALK, see the steps below.
If you use another package, call
EPA User's Support (800-334-2405)
or (919) 541-7862.
To emulate a PF key using
CROSSTALK:
(1)	Either when you are at the
CROSSTALK status screen, or
when you need a PF key, hit
"ESC," which will give you a
"COMMAND" line across the bo-
ttom of your screen. Then type
"AT PGDN," which tells the soft-
ware to assign the ATtention func-
tion to the page down key. This
frees the "ESC" key for use in
TRIS. (This does not affect the
use of these keys after you exit
CROSSTALK.)
(2)	Once you have completed
step 1, and you need a PF key in
TRIS you can hit "ESC," the
number, and "ENTER." For exam-
ple, if you need PF3 - hit "ESC,"
3, "ENTER."
If you cannot get batch jobs to
print out: Make sure you have the
correct JCL (Job Control Language
- the directions for your job, e.g.,
what printer to send it to, how
many copies, what account to
charge, etc.). Solutions to common
problems with JCL settings are
outlined below.
(1)	When you get ready to
send your batch print job to the
printer, there will be a PF5 menu
option at the bottom of the screen
labeled "JCL." Select that, and a
"Batch Job Submission Param-
eters" screen will tell you what
your default settings are.
(2)	Be sure your account pa-
rameter is set with your four-letter
account code + SAROP (there
should be no space between them).
For example, if your account code
is VXYZ, then you should enter
VXYZSAROP where it asks for
your account code.
(3) Select the remote printer
for easy access. You can get the
number of one near you by going
into NATICH, selecting (9), Com-
prehensive Reports, from the main
menu and pretending to submit
one. When you get to the JCL
screen, put a "?" in the printer
space and it will give you a listing
of the printers in your State. Write
down the printer number and use
it for the TRIS batch JCL screen
also. (You should then cancel the
NATICH batch job.) Once these
TRIS JCL parameters are set, they
will become the user's default set-
tings until reset again.
If TRIS will not recognize your
CAS number: In TRIS, the user
must add leading zeros for a total
of 9 digits and take out any
hyphens "-"s from the CAS
number. For example, 62-75-9
must be entered 000062759 to be
considered a valid entry.
When searching by facility
name: TRIS can search its records
by facility name. When you select
such a search, TRIS will ask you
for:
Facility name.... >	
thru....>	
This is so the computer knows
where to begin looking and where
to stop. If you are looking for
DOW, for example, and enter
"DOW" in both spaces, the search
will begin and end when it first
finds "DOW," and it will say it
found nothing. If you put:
Facility name.... >DOW
thru.... >DOWA
it will find Dow Chemical Co., Dow
Chemical Joliet, and DOW Chemi-
cal USA and stop looking when it
hits DOWA. Similarly, if you put in
(continued on page 4)
3

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(continued from page 3)
"Allied" through "Allief," it will
find Allied Baltic Rubber, Inc.,
Allied Signal, Inc., Allied After-
market Div., etc. (See Figure 1.)
Then, if you want details on a
specific entry, you may do so by
following the directions on the
screen.
These tips should help you
through some of the rough spots
as you begin to access TRIS
through NATICH. Our records in-
dicate that the utility of the link
outweighs the inconvenience of any
initial snags. An upcoming news-
letter will address using TRIS in
more depth, giving details on con-
ducting various searches. As
always, should you have any pro-
blems with NATICH, please call
the Clearinghouse staff at (919)
541-0850 or (FTS) 629-0850.
Figure 1
Toxic Release Inventory System
Facility/Submission Query
START: ALLIED THRl): ALLIEF
YEAR: 1988
MARK
FACILITY NAME
TRIID
# SUBM
—
ALLIED - BALTIC RUBBER INC.
43804LLDBL1 FACT
l
-
ALLIED - SIGNAL INC.
45638LLDSG3330S
13
-
ALLIED - SIGNAL INC. DANVILLE WORKS
61834LLDSGN05BR
10
-
ALLIED AFTERMARKET DIV.
02916LLDFT10NEW
1
-
ALLIED AFTERMARKET DIV.
45331LLDFTM ARTZ
4
-
ALLIED AFTERMARKET DIV.
64772LLDFT1200E
3
-
ALLIED AUTOMOTIVE BENDIX HVS
28145LLDTM727BE
2
-
ALLIED AUTOMOTIVE BENDIX HVS
28216LLDTM701I8
5
-
ALLIED AUTOMOTIVE-BENDIX FMD
37311LLDSG20THS
6
-
ALLIED AUTOMOTIVE BENDIX HVS
40601LLDTMUS421
7
Oregon Develops Successful Training Program
by Marianne Fitzgerald, Oregon DEQ
Since 1985 Oregon's industry
trade associations and State en-
vironmental agency have taken a
positive approach to dealing with
the complex hazardous waste and
hazardous materials management
requirements. A series of quarterly
workshops provides an ongoing
forum for educating the regulated
community and discussing waste
management issues and programs.
The workshops began as a
homegrown informal effort to bet-
ter educate business and industry
in Oregon. Now they have become
a regularly scheduled series, cul-
minating in a two-day conference
and trade show in the fall. From
the beginning, the workshops were
designed to provide practical infor-
mation on environmental manage-
ment at an affordable price. For
just $35 for the one-day workshops
and $75 for the conference, the
price is low enough to allow several
employees from a company to at-
tend regularly.
Initial workshops focused on
hazardous waste issues, but the
agenda has expanded over time to
include the broad spectrum of
issues typically faced by a com-
pany's environmental manager.
The agenda is geared toward time-
ly topics of concern to a wide
range of businesses. The latest in-
formation on pending and final
State regulations and legislation is
featured. Community right-to-
know, hazardous waste reporting,
land bans, hazardous materials
storage and handling, underground
storage tanks, and waste minimiza-
tion are some of the topics recently
covered. Also, "boot camp" train-
ing for employees new to the field
of hazardous materials manage-
ment is offered at the conference.
The key to the success of the
workshops has been the hands-on
approach to sharing information
and discussing practical solutions
to common problems in handling
hazardous materials and hazardous
waste. For example, one session
featured the pros and cons of on-
site versus offsite solvent recy-
cling. Another session featured a
panel of speakers on Toxics
Release Inventory and community
right-to-know reporting: the State
Fire Marshall explained why the
data are needed, EPA explained
how the data are used, and an in-
dustry representative explained
how to collect the data and fill out
the forms. A session on crisis
media relations featured a local
radio news director and fire
department public relations
manager discussing tips for deal-
ing with the media in the event of
a spill or accident. A session on
waste minimization in the vehicle
maintenance industry featured
both a national expert discussing
painting and stripping techniques
and a local expert discussing the
waste management program in his
shop.
The co-sponsoring agencies,
the Oregon Council of the
American Electronic Association,
(continued on page 9)
4

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Ohio Studies Sewage Sludge Incinerator Emissions
In order to better assess the at-
mospheric releases of trace metals
and organic compounds from mu-
nicipal sewage sludge incinerators,
the Ohio EPA, Division of Air
Pollution Control, conducted a
study to review pertinent literature
and perform stack emission tests
on two Ohio sewage sludge in-
cinerators. Funded by the Ohio Air
Quality Development Authority
and completed by a contractor, the
project also developed an inventory
of all sewage sludge incinerators in
Ohio, and obtained physical and
operating data for all Ohio units.
With the resulting stack test data
and data from the literature, the
Division derived emission factors
and applied them to the rest of the
Ohio sewage sludge incinerators to
provide emission estimates for
each plant.
Sludge composition is one
potential source for many of the
compounds emitted, particularly
the metals which tend to be con-
centrated during the treatment
process. With organic compounds,
emissions are a result of volatiliza-
tion or incomplete combustion.
Thus, the study compared stack
emissions of metals, semivolatiles,
and volatiles to their content in the
sludge. Table 1 presents these
results, but excludes compounds
not found above the detection
limit.
Both incinerators were multi-
ple hearth incinerators, controlled
with scrubbers. Plant A burned
sludge generated from a mixture
of industrial, commercial, and
residential dischargers. Plant B
served a more industrialized and
commercial area. The high nickel
results at Plant A were a result of
sample contamination by a stain-
less steel sampling probe. The
high zinc emissions appear valid.
For organic emissions,
methylene chloride was highest.
Plant A emissions were generally
lower, thought to be due to the
high temperature at the top of the
(continued on page 6)
Table 1
Summary of the Stack Test Results
	PLANT A			PLANT B	
Sludge Emission	Sludge Emission
Cone.* Rate	Cone.* Rate
Compound	(ppm) (lbs/dry ton)	(ppm) (lbs/dry ton)
Metals




Arsenic
12
0.0011
24
0.0002
Beryllium
<0.2
—
<0.11
—
Cadmium
88
0.013
148
0.045
Chromium
143
0.0022
663
0.0009
Copper
708
0.0046
415
0.0041
Lead
279
0.0049
432
0.0027
Nickel
82
0.036b
177
0.0002
Selenium
<0.08
0.0007
<0.2
0.0004
Zinc
11,995
0.77
1649
0.035
Semi-Volatile Organics(




benzoic acid
217.5
0.0062
288.6
0.015
di-N-octylphthalate
30.5
0.00087
7.6
0.00039
diethylphthalate
16.2
0.00046
14.9
0.00077
bis(2-ethylhexyl)phthalate
—
—
12.9
0.00066
butylbenzylphthalate
—
—
2.3
0.00012
di-N-butylphthalate
	
—
3.0
0.00016
Volatile Organicsc




acetoned
7.0
0.00020
83.1
0.0043
benzened
1.8
0.000051
3.7
0.00019
bromodichloromethaned
5.0
0.00014
—
—
methyl ethyl ketone
—
—
2.7
0.00014
carbon disulfide6
—
—
8.0
0.00041
chloroforme
33.0
0.00094
4.7
0.00024
1,1-dichloroethane
—
—
0.8
0.000042
dibromochloromethaned
3.0
0.000085
—
—
1,2-dichloroethanede
13.1
0.00037
—
—
1,1 -dichloroethylenee
—
—
1.6
0.000082
methylene chloride
83.9
0.0024
120.0
0.0062
tetrachloroethylenee
—
—
5.0
0.00026
toluenee
4.1
0.00012
4.7
0.00024
trans-1,2-dichloroethylened
0.7
0.000019
—
—
1,1,1-trichloroethane
12.6
0.00036
38.9
0.0020
trichloroethyleneb.c
0.6
0.000017
14.1
0.00073
aDry basis.
bHigh value thought to be caused by sample contamination.
Effect may also be seen in chromium result, but to a lesser extent.
Clncludes only the compounds found above the detection limit.
dDetected in emissions but not in sludge at Plant A.
eDetected in emissions but not in sludge at Plant B.
5

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(continued from page 5)
hearth used to reduce odors. Com-
pounds detected in emissions but
not appearing in sludge were
either present in sludge below
detection limits or were formed
during the incineration process.
Next, the study compared the
metals emission results to litera-
ture values. This comparison was
based on the ratio of the emissions
to the sludge concentration (see
Table 2). In general, the percen-
tages agreed with values from
previous studies. The exceptions
are cadmium and chromium, both
of which are higher. Considering
the range of variability in reported
sludge concentrations, these dif-
ferences were not unexpected.
For organic emissions, fewer
data were available; however, the
stack test results generally fell
within the established range. No
correlation between sludge com-
position and emissions was
evident.
With the results of the
literature review and the stack
testing, Ohio EPA generated emis-
sion factors to apply to the other
25 sewage sludge incinerators (12
wastewater treatment plants)
operating in Ohio (as of October
1988). These emission factors are
listed in Table 3. The primary use
for these estimates will be inclu-
sion in Ohio EPA's assessment of
Ohio's contribution to the air tox-
ics deposition in the Great Lakes
(see related article in March 1990
Newsletter). A secondary purpose
will be to establish a frame of
Table 2
Comparison of the Metals Stack Test Results and Literature Values
Metal
	% of Metals in
Stack Test Results
Sludge Emitted	
Literature Survey
—

Plant A
Plant B
Median
Range
N
Arsenic
4.4
0.4
2.9
0.38 - 92.50
7
Beryllium
—
—
0.5
—
1
Cadmium
7.2
15.4
14.2
1 - 35.9
17
Chromium
0.8
0.07
0.33
0.07 - 7.24
11
Copper
0.3
0.5
0.37
0.13- 1.2
7
Lead
0.9
0.3
4.5
0.79-40.15
17
Nickel
22
0.07
0.28
0.07 - 1.45
15
Selenium
—
—
7.3
5.79 - 8.81
2
Zinc
3.2
1.1
0.77
0.47 - 2.28
8
reference for future permitting of
sewage sludge incinerators.
For a summary of the report
entitled "Toxic Air Emissions
from Sewage Sludge Incinerators
in Ohio," contact Paul Koval at
the Ohio EPA, Division of Air
Pollution Control, 1800 Water-
Mark Drive, Columbus, Ohio
43216. The phone number is (614)
644-2270.
Table 3
List of Emission Factors
Emission Factor®
Compound (lb/dry ton)
Metals

Arsenic
0.00075
Beryllium
<0.000002
Cadmium
0.014
Chromium
0.0030
Copper
0.0047
Lead
0.036
Nickel
0.00060
Selenium
0.0015
Zinc
0.052
Semi-Volatile Organic!
0.01060
Benzoic acid
Di-N-octylphthalate
0.00063
Diethylphthalate
0.00062
Volatile Organics

Acetone
0.002250
Benzene
0.000121
Chloroform
0.000590
Methylene chloride
0.004300
Toluene
0.000180
1,1,1-trichloroethane
0.001180
Trichloroethylene
0.000374
aMetals emission factors include
literature data; organic compound
emission factors do not.
Health-Based Program Provides Toxics Information
In 1988, responding to local
concerns over toxic air pollution,
Wayne County, Michigan's com-
missioners established a health-
based program to assist city and
county level government in both
risk assessment and risk manage-
ment. Funding for the Toxics and
Environmental Risk Management
(TERM) program and its staff of
three comes from locally assessed
fines for violations of Clean Air
Act standards. The County's
Department of Public Health gives
administrative support.
TERM has patterned itself in
part on an older program in place
since 1977 in Kentucky. The
Louisville and Jefferson County
Health Department formed a
Hazardous Material Mutual Aid
Group (HAZMAT) when represen-
tatives from local health, fire, and
the medical and disaster planning
agencies began to prepare for
possible emergency response
(continued on page 7)
6

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(continued from page 6)
requests stemming from a pro-
posed nuclear power plant.
What TERM Does
TERM serves as a clearing-
house for locally collected informa-
tion pertinent to chemical risk
management, responding to in-
dividual requests. The program
evaluates vital statistics (birth and
death data) as well as cancer in-
cidence for political subdivisions of
Wayne County. These data can be
used to guide investigations of
disease clusters reported by com-
munity groups concerned about
the impact of hazardous air
releases. TERM responds to re-
quests for information from such
groups, investigating the com-
plaints and summarizing the in-
vestigation results in a brief nar-
rative report for release to the
community.
In addition, TERM has
reviewed chemical release data
reported by local industries as re-
quired by the Superfund Amend-
ments and Reauthorization Act of
1986. With this data base, it is
possible to characterize multimedia
risks due to the storage, transport,
and release of toxic chemicals
within a densely populated in-
dustrial and urban area. Important
data on the mix of these chemicals
in the airshed are expected from
further refinements in reportable
quantity values for environmental
releases within southeastern
Michigan. TERM has already pro-
duced one detailed report on toxic
chemical releases in Wayne
County.
The TERM program also uses
centralized online data bases, such
as those provided by the National
Library of Medicine (TOXNET,
MEDLINE, etc.), for current infor-
mation on chemically mediated
health effects resulting from a
multitude of compounds.
For further information, call
Martin Atherton, Coordinator, Tox-
ics and Environmental Risk
Management Program, Wayne
County Health Department, at
(313) 326-4920.
Clean Air Act Update - Air Toxics
Previous newletter articles*
have described the basic structure
of the proposed air toxics amend-
ments to the Clean Air Act. The
purpose of this article is to chart
the bill's course toward passage
and provide a snapshot of the cur-
rent status of the air toxics amend-
ments in both the House and
Senate.
Last summer President Bush
unveiled the Administration's ver-
sion of the Clean Air Act amend-
ments. The President's proposal
had 7 Titles covering nonattain-
ment of the national ambient air
quality standards, emissions from
mobile sources, air toxics, a new
Federal air permitting system, acid
rain control, enforcement, and
other important air pollution
issues. The President's bill was
adopted in the House as H.R.
3030. The Senate did not adopt
the President's bill in total, but the
air toxics title was introduced in
the Senate as S. 1490.
Mark up of the President's bill
began in the House last fall with
the Subcommittee on Health and
Environment chaired by Henry
Waxman (D. California). The
Energy and Commerce Committee
chaired by John Dingell (D. Michi-
gan) completed mark up of the bill
on April 5, 1990.
A comprehensive bill which
was close to the President's bill in
structure but was significantly dif-
ferent in several key areas was in-
troduced in the Senate as S. 1630.
After a long negotiation session
with the Administration (in which
the EPA played a key role) the
Senate completed work on S. 1630
on April 3, 1990. The final Senate
version of the bill incorporated
amendments from the Subcommit-
tee on Environmental Protection,
the Committee on Environment and
Public Works, and the Senate floor.
As of mid-May, the next step
for Clean Air legislation is to com-
plete the amendment process in
the House. Currently the House
Committees on Public Works and
Ways and Means are seeking joint
referral of the bill to amend the
portions dealing with highways
and fees, respectively. Following
the referral process, the bill will
move to the House floor for final
debate and amendments.
After the House passes their
version of Clean Air Act legisla-
tion, a conference committee will
convene to work out the differ-
ences between the House and
Senate versions of the bill. Finally,
the bill reported out of the con-
ference committee will be submit-
ted to the President for signature.
When all of this will happen is
an open question. As of mid-May,
the House had not reported out the
version of the bill as it was amend-
ed by the Committee on Energy
and Commerce. Although it seems
unlikely, the House leadership is
trying for a floor vote on the bill
before the Memorial Day recess. If
the House does not act before the
recess, the vote will likely occur in
early June. Soon after the House
floor vote the conference commit-
tee will be convened. It is uncer-
tain how long this committee will
take with the bill. There are many
issues and competing priorities
(e.g., the budget summit) that
could delay final action. Most peo-
ple think that the conference
(continued on page 10)
7

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(continued from page 1)
IDEM currently receives some
control of air toxics through imple-
mentation of the State and federal
criteria pollutant and NESHAP
programs. However, additional con-
trols may result as IDEM develops
new ozone control plans for such
metropolitan areas as Chicago,
Louisville, Indianapolis, South
Bend, and Evansville. A new inhal-
able particulate control plan for
Lake County (bordering Lake
Michigan) should also reduce emis-
sions of certain air toxics (e.g.,
metals).
IDEM has also performed
special studies of several facilities
with air toxic emissions identified
by EPA as posing potentially signi-
ficant risk. Follow-up with indivi-
dual facilities has resulted in volun-
tary reduction by two facilities.
Also, the Air Pollution Control
Board adopted a rule in advance of
Federal NESHAP rulemaking to
reduce benzene emissions from
coke oven by-product recovery
plants in Lake and Porter counties.
A third mechanism for achieving
control of air toxics comes through
the permit renewal and new con-
struction process. IDEM routinely
performs an air quality analysis for
any new source emitting one of 36
more commonly occurring air tox-
ics (see Table 1). Where warranted,
IDEM has pursued and in some
cases obtained, controls under this
program. Air toxics are also con-
sidered in BACT determinations
under the PSD program.
Prior to presenting a proposed
control program to the Air Pollu-
tion Control Board, IDEM is seek-
ing public input to its proposal.
IDEM prepared a package that in-
cluded background information and
sent it out to interested parties in
February. The proposal comple-
ments the expected federal legisla-
tion (CAA amendments)** but con-
tains a number of additional
features:
• additional reporting require-
ments for sources above de
minimis levels to allow for con-
ducting a risk assessment.
•	provisions to allow IDEM to re-
quire controls for smaller
sources not covered by the con-
trol technology standards to be
promulgated by EPA.
•	control technology standards for
sources in advance of federal
promulgation if certain sources
or source categories pose
substantial risk and the EPA's
schedule for promulgating
regulations is not expeditious.
•	extended requirements for new
or modified sources with air
toxic emissions. Maximum
Achievable Control Technology
(MACT) would be required for
all new sources above de
minimis levels. Major new
sources of known or suspected
carcinogens would be required
to conduct a risk assessment to
determine whether MACT
results in acceptable residual
risk.
•	MACT or BACT on all new and
existing sources of the Great
Lakes seven priority pollutants
(alkylated lead compounds, ben-
zo(a)pyrene, mercury, hexachlor-
obenzene, PCBs, 2,3,7,8-TCDD
and -TCDF) above de minimis
levels.
The proposed rules will be
presented as soon as possible after
reauthorization of the Clean Air
Act in 1990. If federal legislation is
not to be enacted in 1990, IDEM
will proceed with its proposed
rules. Modification of the schedule
to establish MACT regulations
would be made according to the
availability of resources. A generic
MACT standard for new and ex-
isting sources targeting the highest
priority sources would also be
established.
The written comment period is
scheduled to close at the end of
June. IDEM is holding public
meetings during May to solicit
comments.
Table 1.
Air Toxics Controlled Through
The PSD Program
Acetaldehyde
Acrylonitrile
Benzene
Carbon Tetrachloride
Chloroform
Coke Oven Emissions
Cresols
o-Dichlorobenzene
Dioxane
Epichlorohydrin
Ethylene Dibromide
Ethylene Dichloride
Ethylene Oxide
Formaldehyde
Hexachlorocyclopentadiene
Methyl Chloroform (1,1,1-trichloroethane)
Methylene Chloride
Perchloroethylene (Tetrachloroethylene)
Phenol
Polychlorinated Biphenyls (PCBs)
Propylene Oxide
Pyridine
Styrene
Toluene
1,1,2-Trichloro-l ,2,2-trifluoroethane
(Freon 113)
1,1,2-Trichloroethane
TVichloroethylene
Vinylidene Chloride
Xylenes
Benzo(a)pyrene
Hexachlorobenzene
Lead (Alkylated) Compounds
Mercury (Alkyl)
Mercury (Vapor)
2,3,7,8-letrachlorodibenzof uran
2,3,7,8-Tetrachlorodibenzo-p-dioxin
For more information on In-
diana's proposed program, contact
Paul Dubenetzky, Chief of Air Pro-
grams, Office of Air Management,
Indiana Department of Environ-
mental Management, 105 S. Meri-
dian, Indianapolis, IN 46206,
telephone number (317) 232-8217.
* *See related article in the March
1990 issue (p. 5) and this issue (p. 7).
8

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(continued from page 2)
This level of analysis is consis-
tent with EPA's use of the data in
the prioritization of source cate-
gories and pollutants for regula-
tory development. However, the
MIR estimates are subject to
considerable uncertainty when ap-
plied to individual facilities
because of assumptions incor-
porated into the assessment pro-
cedures. The screening method-
ology used to calculate the esti-
mates has always been intended
for developing information to com-
pare source categories, and cannot
be said to provide exact estimates
of the cancer risk to the public
around specific individual facil-
ities. Simplifying assumptions are
used regarding facility physical
characteristics, the actual location
of emission sources, and the actual
location of the surrounding
population.
EPA to Follow Up on
Emission Reduction
This past summer EPA Ad-
ministrator William Reilly invited
the chief executives of nine major
corporations and the leadership of
the Chemical Manufacturers
Association to a meeting at EPA
to discuss what steps they could
take voluntarily to reduce air toxic
emissions. At that August 11
meeting, the EPA was informed of
the programs underway at the nine
firms to reduce emissions. In turn,
the EPA requested that the com-
panies submit plans for further
reductions. All the companies
agreed to do so.
The plans have now been
received and reviewed by EPA
technical staff. Meetings have been
held with the environmental staffs
of each company to better under-
stand their plans and to request
further information as appropriate.
Additional information requested
at these meetings has been sub-
mitted and has been evaluated. In
addition, EPA staff have visited
selected facilities of these nine
companies to discuss voluntary
reduction plans and review emis-
sions assessments. EPA expects to
reach agreement with the com-
panies shortly on the plans and
will track their implementation un-
til complete.
The EPA also has regulatory
development activities underway
that will apply to such facilities.
These regulations include the
hazardous organic National Emis-
sion Standards for Hazardous Air
Pollutants (NESHAP) which will
apply to chemical plants, and the
NESHAP for ethylene oxide ster-
ilizers. Proposal of both would be
facilitated by a technology-based
approach to air toxics regulation,
which is a central theme of the
President's initiative on the Clean
Air Act and other bills Congress is
considering (see related article in
March 1990 issue, p. 5).
In order to get these regula-
tions in place as soon as possible,
the EPA is working on developing
them as technology-based stan-
dards in anticipation of early pro-
posal under a revised Clean Air
Act. Also, as part of the hazardous
organic NESHAP effort, a regula-
tory negotiation to develop require-
ments for control of emissions
from equipment leaks is underway
involving EPA, the States, industry
and environmental representatives.
The EPA expects to conclude
these negotiations by early sum-
mer and to propose the hazardous
organic NESHAP regulations a
year later (see related articles in
January 1990 issue, p. 2 and this
issue p. 7).
uregon (continued from page 4)
Associated Oregon Industries, the
Oregon Department of Environ-
mental Quality and the Semicon-
ductor Safety Association, handle
all of the details for planning the
workshops. The seven-member
planning committee meets regular-
ly to set the agendas and suggest
speakers. The American Elec-
tronics Association handles the
facility arrangements, brochure
development, mailings, registra-
tion, and so forth, while the other
members make arrangements with
speakers and moderators, and pro-
vide mailing lists.
The challenge in planning the
agenda is to find speakers who are
both knowledgeable and interest-
ing. Speakers are usually drawn
from local industries, businesses,
and government agencies. Demands
on the speakers are kept to a
minimum: while written materials
are helpful, "speaker papers" are
not required and proceedings are
not published. Speakers do get
free registration and lunch, and a
few have had their travel expenses
paid.
The quarterly workshops con-
sistently attract over 200 attendees
from all types and sizes of
businesses throughout Oregon and
Southwest Washington. Consider-
ing that Oregon has only about
800 hazardous waste generators, a
large cross-section of the regulated
community is represented. The
success of the workshops led to ex-
perimentation with an expanded
format in 1988. The fall workshop
now includes two days of concur-
rent sessions and an accompanying
trade show to provide an oppor-
tunity for attendees to mingle with
their peers and meet local con-
sultants or equipment vendors. In
1989, the fall workshop drew over
400 attendees and 45 exhibitors
from throughout the Northwest.
Success sometimes has its
limitations. In an attempt to satisfy
(continued on page 10)
9

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(continued from page 9)
such a large number of attendees,
the agendas at times have been too
general to provide the detailed in-
formation needed by some par-
ticipants. Commentators have
requested more industry-specific
information, and the format may
change in the near future to in-
clude a few small breakout rooms
at three of the workshops and
more specific information at the
fall session.
The workshops benefit both
industry trade association mem-
bers and government: better
education means better waste
management, which can mean bet-
ter bottom-line performance for
businesses and a cleaner environ-
ment for all. For more information
contact Marianne Fitzgerald,
Oregon Department of Environ-
mental Quality, Pollution Preven-
tion Program, 811 S.W. Sixth,
Portland, OR 97204, (503)
229-6352.
iiicau (continued from page 7)
committee will try to report out a
bill before the Labor Day recess,
but again this is highly speculative.
There have been several recent
changes that affect the air toxics ti-
tle of the bill. The basic structure
of the two versions of the air toxics
title are essentially the same; i.e.,
technology-based regulations ap-
plicable to major sources emitting
one or more of the chemicals listed
in the bill, followed by a residual
risk phase which would analyze
the risks remaining after applica-
tion of the technology-based stan-
dards and potentially require fur-
ther regulations. The most impor-
tant changes for each of the major
provisions of the air toxics title are
listed below:
The Hazardous Air Pollutant
List: Until recently both the House
and the Senate versions of the bill
had the same list of 191 chemicals
and chemical categories. The
House Committee removed both
hydrogen sulfide and ammonia
from the list based on the pre-
sumption that these chemicals are
mainly problems from an acciden-
tal release standpoint. In addition,
the House made it more difficult to
petition the EPA to remove a
chemical category from the list
(chemical categories are classes of
chemicals such as chromium and
compounds). In order to remove a
chemical category from the list, the
petitioner must show that all
chemicals in the category for
which data are available meet the
criteria for delisting. Prior to this
amendment, single pollutants
within a chemical category could
be deleted from the list if they met
the criteria.
The Source Category List: Both
bills require EPA to develop a list
of source categories (industries)
which emit one or more of the
listed pollutants. The House added
an amendment which requires that
area source categories (small
sources) accounting for 90% of the
emissions of listed air toxics from
area sources be included on the list
of source categories subject to
regulation. In addition, the House
added a petition process for the
source category list. Based on the
Administrator's discretion or a
petition, a source category can be
withdrawn from the list if all
sources within the category do not
cause more than a 1 in 1 million
risk of cancer to the most exposed
individual and do not cause non-
cancer effects considering an am-
ple margin of safety.
Maximum Achievable Control
Technology (MACT): The House
has not changed the definition of
MACT. For new sources MACT is
defined as the control achieved in
practice by the best controlled
similar source. For existing
sources MACT is the control
achieved by the best controlled
similar sources. The Senate defined
MACT for new sources identical to
the House bill but for existing
sources MACT is defined as the
control achieved in practice by the
best controlled 10% of similar
sources or top 3 sources if there
are fewer than 30 sources within
the category. This level is predi-
cated on the availability of data on
control efficiencies of similar
sources.
Regulatory Agenda: Both the
Senate and the House versions re-
quire that EPA promulgate MACT
standards for 100% of the source
category list within 10 years. The
schedules are slightly different.
The House version requires
MACT to be promulgated for 10
source categories within 2 years
after enactment, 25% of the source
category list within 4 years, an ad-
ditional 25% within 7 years and
the final 50% within 10 years. The
Senate version requires MACT for
source categories emitting 13
priority pollutants within 2 years,
25% of the list within 4 years, an
additional 25% within 6 years and
the final 50% within 10 years.
Voluntary Reductions: There
are provisions in both bills to pro-
vide incentives for industries to
achieve early reductions of air tox-
ics emissions. The House version
allows a 5 year extension of the
compliance data for MACT stan-
dards for facilities which achieve
an overall annual 90% reduction
(95% reduction for particulates) of
listed toxics. Reductions must be
based on emissions for a baseline
year no earlier than 1987. The
Senate would allow facilities to be
exempt from the MACT require-
ments for a 90%/95% overall
(continued on page 11)
10

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(continued from page 10)
annual reduction from a baseline
year not before 1985. The reduc-
tions achieved pursuant to Federal
regulation cannot be counted
toward the 90%/95%, but reduc-
tions achieved under State and
local laws can be credited.
Negligible Risk: The House
has a provision which would allow
sources which can demonstrate
negligible risk to be exempted
from both MACT and residual risk
requirements. An amendment of-
fered in the Committee mark up
further defined negligible risk as 1
in 1 million risk of cancer for the
most exposed individual in the
population and an ample margin of
safety for non-cancer effects.
These demonstrations would be
based on EPA guidance. The
Senate does not have a negligible
risk provision. There is a mini-
mum emission rate provision
within the Senate bill which would
operate similarly to negligible risk.
Under this provision a risk-based
minimum emissions rate would be
established with each MACT stan-
dard. If a facility could demon-
strate that they do not emit more
than the minimum emission rate
they would be exempt from the
regulatory requirements.
Residual Risk: Although the
MACT standards will probably
have the most effect on air toxics,
the issue of residual risk has
generated more dicussion and con-
troversy than any other issue deal-
ing with air toxics. Both the Senate
and the House versions have a
residual risk provision that would
require evaluation of the risks re-
maining after the application of the
MACT standards. The contro-
versial issue is the decision rules
which will be applied in determin-
ing how much residual risk is ac-
ceptable. The original Administra-
tion position was to evaluate resi-
dual risk on a case by case basis
taking into account all available in-
formation including costs of fur-
ther control.
The Senate and the House ver-
sions both require a study of how
residual risk should be analyzed.
On the House side, this would be
an eight-year study conducted by
EPA in consultation with the
Surgeon General. If the Congress
does not act legislatively on the
recommendations in the study to
amend the process for analysis of
residual risk, then eight years after
the promulgation of MACT stan-
dards, residual risk must be evalu-
ated under the current law (i.e., the
ample margin of safety criteria
under the current section 112).
The risk assessment study re-
quired under the Senate bill would
be conducted by the National
Academy of Sciences (NAS). The
NAS study would be reported to
Congress and a special Risk
Assessment Risk Management
Commission within two years. The
Commission is required to report
to Congress on recommendations
for further legislation on residual
risk within 3.5 years after enact-
ment. If Congress does not act
legislatively within five years after
enactment, then bright line risk
criteria take effect. The Senate
bright lines are 1 in 10,000 and 1
in 1 million risk of cancer for the
most exposed individual and an
ample margin of safety for non-
cancer effects. All sources must
meet the 1 in 10,000 risk criterion.
Sources that meet the 1 in 10,000
risk level, but cannot achieve the 1
in 1 million risk level must demon-
strate that they have applied all
available control technology when-
ever their permit is renewed. In
addition, these sources can be re-
quired to conduct research and
development into further control
methods. Finally, the Senate bill
includes a provision which would
allow facilities to conduct a site-
specific risk assessment to
demonstrate compliance with the
established risk levels. A site-
specific risk assessment would be
a risk analysis that could incor-
porate all of the unique parameters
regarding the facility. Some of
these parameters may include the
location and mobility of the ex-
posed population, the local meteor-
ology, the location of facility fence-
line, local terrain features, etc.
These risk analyses would be
based on EPA guidance.
The above discussion touches
on only a few of the issues which
are addressed in the air toxics title.
Many of these provisions are likely
to be changed in the upcoming
House floor debate and the con-
ference committee. Succeeding ar-
ticles on this topic will provide up-
dates on the passage of the Clean
Air Act. In the interim, if you have
any questions about air toxics issues
in the Clean Air Act amendments,
call Tim Mohin at (919)541-5349
or (FTS) 629-5349.
*See related articles in the
September 1989 and March 1990
NATICH Newsletters.
Helpful Numbers

Air Risk Information Support Center (Air RISC Hotline)....
(919) 541-0888
(FTS) 629-0888
Control Technology Center (Hotline):	
(919) 541-0800
(FTS) 629-0800
NATICH Clearinghouse Staff:	
(919) 541-0850
(FTS) 629-0850
SARA Title III	
1-800-535-0202
11
t

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The NA TI CI I Ncwsk't ter is published six times a year by the National Air Toxics Information Clearinghouse.
The Newsletter is prepared by Radian Corporation under EPA Contract Number 68-D8-0065, Work Assign-
ment 21. The EPA Project Officer is Scott Voorhees, EPA Office of Air Quality Planning and Standards,
Research Triangle Park, North Carolina 27711, Telephone: (919)541-5348. The Radian Project Director is
Caroline Brickley, P. O. Box 13000, Research Triangle Park, North Carolina 27709, (919)541-9100.
The Newsletter is distributed free of charge. To report address changes, write Meredith Haley, Radian Cor-
poration, P. O. Box 13000, Research Triangle Park, North Carolina 27709.
The views expressed in the NATICH Newsletter do not necessarily reflect the views and policies of the
Environmental Protection Agency. Mention of trade names or commercial products does not constitute any
endorsement or recommendation for use by EPA.
Printed on recycled paper.
Scott Voorhees
Pollutant Assessment Branch
U.S. Environmental Protection Agency
MD-13
Research Triangle Park, NC 27711
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