453N90002
NATICH
NEWSLETTER
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
0 ^L£\[pİ(Q)
State and Territorial Air Pollution Program Administrators
Association of Local Air Pollution Control Officials
Produced by the National Air Toxics Information Clearinghouse July 1990
Clearinghouse Has New Staff
After almost 2 years of serving
as project officer for this news-
letter, Scott Voorhees will leave the
Clearinghouse staff temporarily to
accept a Fulbright Research Grant.
The grant will enable him to
evaluate the air pollution control
program at the Japan Environment
Agency (JEA). The 9-month detail
begins in September.
Replacing Scott as Newsletter
Project Officer is Martha Keating.
Other Newsletter staffers, Nancy
Riley and Melissa McCullough,
will continue their duties as
Newsletter mailing coordinator and
NATICH data base coordinator.
All three respond to questions on
the NATICH data base and the
Clearinghouse in general. They
can be reached at (919) 541-0850
or (FTS) 629-0850.
New NATICH publications in
preparation for late summer print-
ing and mailing include the
"Bibliography of Selected Reports
and Federal Register Notices
Related to Air Toxics Volume 3:
Citations - 1989" and "Ongoing
Research and Regulatory Develop-
ment Projects." The Bibliography
includes an update to the index for
this Newsletter as Appendix A.
Clean Air Act Update: House
Version Passes
Status of Amendments: As of
June, both the House and the
Senate have passed different ver-
sions of the Clean Air Act Amend-
ments. A conference committee
will be appointed in the weeks to
come that will meet to negotiate
the differences between the two
versions. Once a compromise has
been reached, the bill will be sent
to the President to sign into law. It
is most likely that the conference
committee will begin meeting in
late June or early July and report
out a bill by the end of the summer.
The May Newsletter article
concerning the Clean Air Act was
published just prior to the passage
of Clean Air Act amendments by
the House of Representatives*
Although the air toxics portion of
the bill (Title III) remained largely
intact, there were some important
changes worth noting.
Definition of MACT: As men-
tioned in the May issue, both the
House and Senate versions of the
Clean Air Act Amendments
specified an initial phase of
technology-based standards (max-
imum achievable control technol-
ogy or MACT) for source cate-
gories emitting air toxics, to be
followed by a source-specific risk
analysis and possible further
regulation. The basic structure of
the bill was not changed by the
House. An amendment was ac-
cepted, however, which modified
the definition of MACT for ex-
isting sources. In the Administra-
tion's bill, MACT was defined for
existing sources as the control
*See May issue, p. 7
(continued on page 8)
In This Issue
Santa Barbara Writes
New EtO Rule 2
Using TRIS Through
NATICH: A Primer 3
SCAQMD Controls
Landfill Gas Emissions 5
STAPPA/ALAPCO
Comment on Proposed
MWC Regulation 7
California Publishes
Tbxics Directory 8
Hospital Waste
Combustion Study Has
Corrected T&ble 8
OAQPS Publishes Sludge
Incinerator Report 9

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Santa Barbara Writes New EtO Rule
by Robert Sears, Air Toxics Coordinator Santa Barbara County, CA
The Santa Barbara County Air
Pollution Control District (SBAPCD)
at one time had several large
sources of ethylene oxide (EtO)
emissions within its jurisdiction.
EtO is a recognized carcinogen,
mutagen, and reproductive toxi-
cant. Recently, SBAPCD reviewed
the possible need of controlling the
emissions and quantified the
health risks associated with them.
The following article outlines the
steps in that review leading to
development of the District's new
rule to reduce EtO emissions.
Health Risk Management
Levels Developed
The SBAPCD researched the
available literature and correspond-
ed with State and federal health
experts to identify the levels of
EtO exposure which are associated
with adverse health effects. Dose-
response information was obtained
for acute reproductive harm and
chronic carcinogenic risk. At the
time of the review, dose-response
information was not available for
determining thresholds (if any) at
which mutagenic or cytogenetic
damage may be initiated due to
EtO exposure.
The SBAPCD selected a one-
hour average EtO concentration of
0.3 ppm (540 ug/m3) as the level
necessary to protect the general
public from adverse reproductive
harm. This level was developed
from an inhalation study that iden-
tified a no observed adverse effect
level (NOAEL) of 33 ppm for
adverse reproductive effects in
pregnant rats. The SBAPCD
health risk management level of
0.3 ppm was obtained from this
NOAEL by applying an uncertain-
ty factor of 10 to convert from
animal to human exposure and
another uncertainty factor of 10 to
account for sensitive individuals in
the human population. The resul-
tant value of 0.33 ppm was then
rounded to 0.3 ppm.
For carcinogenic risk, the
SBAPCD approach is to control
carcinogenic emissions such that
the maximum individual excess
lifetime cancer risk caused by
these emissions does not exceed
one per million at any point at the
boundary or outside the affected
source property boundary.
Exposure Assessment Conducted
In April 1989, the SBAPCD
requested emission quantity and
nature of release information from
all of the known EtO sources in
the County. The emission release
characteristics were necessary for
input to the air quality impact
modeling to be performed as part
of the exposure assessment.
The survey results indicated
that there were 11 sources of EtO
emissions within the District, in-
cluding one spice fumigator, three
medical device manufacturers and
seven hospitals. The spice fumi-
gator was identified as the largest
source of EtO emissions at approx-
imately 13,000 pounds per year.
The emissions from the medical
device manufacturers included 80
pounds per year from an inter-
ocular lens manufacturing facility,
and 1,166 and 1,000 pounds per
year respectively from two medical
implant manufacturing facilities.
Emissions of EtO from hospitals in
the District ranged from 4.5 to 556
pounds per year.
The SBAPCD performed in-
halation exposure assessments of
the three largest EtO sources with-
in the County (the spice fumigator
and the two medical implant
manufacturers). Ambient air im-
pacts were quantified using the
EPA ISCST air quality dispersion
model (with Schulman-Scire
downwash applied) on an IBM AT
compatible personal computer. A
complete year of meteorological
data collected at nearby airports
was used in the analyses. Emission
rates from sterilizer and aeration
room venting (peak hourly and an-
nual averages), building dimen-
sions, and other release character-
istics from each source were
modeled to quantify acute and
chronic exposures. Approximately
1,200 receptors were modeled for
each source, with locations of the
receptors ranging from the facility
boundary to 30 kilometers from
the source.
The exposure assessment
results were reviewed to verify
compliance with the SBAPCD
acute reproductive harm and car-
cinogenic health risk management
levels. Impacts from the other
sources not modeled in the ex-
posure assessment were estimated
by scaling impacts from the three
sources that were modeled.
Peak one-hour emission rates
were modeled to quantify acute ex-
posure. One-hour emission rates of
28.6 pounds per hour for the spice
fumigator and 6.3 and 20.65
pounds per hour respectively for
the medical implant manufacturers
were modeled. Peak one-hour con-
centrations from the spice fumi-
gator exceeded 20,000 ug/m3, and
were 10,000 and 21,000 ug/m3
respectively from the two medical
implant manufacturers. These
modeled concentrations greatly ex-
ceed the 540 ug/m3 health risk
management level determined by
the SBAPCD as necessary to pro-
tect the public from potential
reproductive harm.
Annual-average modeled con-
centrations were multiplied by the
inhalation unit risk value for EtO
of 1.0 x 10-4 (ug/m3)-1 to obtain an
estimate of maximum individual
excess lifetime cancer risks. Using
this approach, the maximum in-
dividual excess lifetime cancer risk
from the spice fumigator was ap-
proximately 3 x 10-3. For both the
medical implant manufacturers,
the risk was 2 x 10-4.
The results of both the acute
and chronic exposure assessments
were displayed graphically as
isopleths of concentration or risk
superimposed on land-use maps.
2

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(continued)
This approach displays areas
where unacceptable risk or am-
bient air concentrations are
predicted to occur. When coupled
with demographic data, estimates
of the exposed population were
also obtained. The isopleths were
generated using the Surfer
Graphics software package on a
PC.
Control Rule Drafted
Based on the results of the ex-
posure assessments, a control rule
was developed to reduce both
chronic and acute risks to accept-
able levels. This rule, SBAPCD
Rule 336, was adopted on Decem-
ber 12, 1989. Requirements of the
EtO control rule are summarized
below.
The evacuation of sterilant gas
for all sources from the steriliza-
tion chamber must be designed to
ensure that EtO is not released in
wastewater streams. This will
allow for control of EtO emissions
that would otherwise be released
to the atmosphere from subse-
quent volatilization from the
wastewater.
Sterilization chamber emis-
sions are required to be vented to
an emission control device with a
control efficiency of 99.9% or
greater, by weight. All other emis-
sion sources, including but not
limited to aeration, ventilation air,
and fume hoods, are required to be
vented to a control device with a
control efficiency of 99% or
greater, by weight. If a single con-
trol device is employed for all EtO
emission sources, then the single
device must demonstrate a control
efficiency of 99.8% or greater, by
weight.
Sources that emit EtO in
amounts of 250 pounds per year or
more must comply with all control
requirements within 1 year of rule
adoption. Smaller sources (be-
tween 4 and 250 pounds of EtO
per year) must comply with all
control requirements within 2
years of rule adoption. Sources
emitting less than 4 pounds of EtO
per year are exempt from the con-
trol requirements, except for the
provision that EtO cannot be
released to the wastewater stream.
The exemption level of 4 pounds
per year is based on the approx-
imation that 4 pounds per year of
EtO correlates to a one per million
maximum individual excess
lifetime cancer risk. All sources
are required to have permits and
are subject to quarterly reporting
requirements.
In addition to the above control
requirements, the EtO rule pro-
hibits any source from emitting
more than 0.5 pound per hour or
1.5 pounds per day of EtO. This
particular provision became effec-
tive upon the date of rule adoption
(i.e., no compliance period was
granted). These emission caps
were chosen to immediately reduce
the potential for reproductive harm
and carcinogenic risk to the lowest
level possible. However, while
hospital sterilization units, which
are mostly small emitters, are not
affected by this emission cap, the
larger EtO sources in the District
have been required to curtail emis-
sions immediately.
Proposition 65 Lawsuits Initiated
California Proposition 65 (The
Safe Drinking Water and Toxic En-
forcement Act of 1986) lists EtO as
a pollutant which is known to the
State to cause both cancer and
reproductive harm. This regulation
requires sources which expose in-
dividuals to cancer risks or repro-
ductive harm above specified
significance levels to issue ap-
propriate public warnings.
After reviewing the SBAPCD
EtO exposure assessments, the
State Attorney General's Office
filed lawsuits against the spice
fumigator and the two medical im-
plant manufacturers, alleging
failure to provide warnings of
significant risk to the exposed
public. This action points out the
need for sources to perform risk
assessments to determine com-
pliance with right-to-know laws.
Also, this action suggests that as
more risk assessments are per-
formed by air pollution control
districts throughout California, ad-
ditional Proposition 65 issues may
be raised.
For additional information,
contact Robert Sears, Santa Bar-
bara County APCD, 26 Castilian
Drive, Building B-23, Goleta, CA
93117, or call him at (805) 961-8800.
Using TRIS Through NATICH: A Primer
Since November 1989, the
Clearinghouse has offered an op-
tion for governmental users to ac-
cess the SARA 313 data base from
NATICH. This article will provide
step-by-step instructions to access
some of the more useful reports. A
detailed TRIS user's manual is be-
ing developed by the Office of Toxic
Substances and should be available
sometime mid- to late summer.
Call Carolyn Thornton at (202)
475-8620 for a copy.
Upon entry to TRIS, several
screens of news and instructions
appear. These are followed by the
first menu that presents three op-
tions: (1) BATCH REPORTS; (2)
ONLINE QUERIES; and (3) EXIT
TRIS. Choosing BATCH REPORTS
initiates a search for the desired
parameters and allows the user to
sort the resulting data which can
then be sent to a remote printer
near the user* ONLINE QUERIES
is more interactive and provides
immediate viewing of the data. To
3

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TRIS (continued)
see the reports and queries that
these two offer, see Figure 1. The
third option is EXIT TRIS. For
users without PF keys, EXIT
TRIS is your last opportunity to
get out of TRIS without turning
off your computer.
When using TRIS, it is helpful
to know some rules regarding the
PF keys. For example, the bottom
of the screen lists the PF keys and
their functions. PF1 is for HELP.
PF2 takes you to the MAIN menu.
PF3, labeled PREV, will take you
to the previous screen (very useful
when you need to run a number of
the same searches). Job control
language or JCL is PF5 and in-
structs the computer where to
send your report and who to
charge. (See the May Newsletter
for more on JCL.) Depending on
what search you are in, the func-
tion of the other PF keys may
change. For example, when you
are in batch reports, PF6 is labeled
QUERY and will take you to the
online query menu. In online
queries, PF6 is labeled RPTS and
will take you to the batch reports
menu. As shown in Figure 1, PF
keys 9 through 12 have different
functions under the Facility Sub-
mission Display. The important
thing to remember is to read your
screen and consult Figure 1.
Some valuable information for
State and local agencies and
regional offices are facility iden-
tification, facility releases to all
media, totals over a geographic
area, and comparison of a facility's
releases over the years for which
the data are available. The instruc-
tions below offer three pathways to
these data. The FACILITY
NAME SEARCH option not only
provides the name and address of
a particular facility, but also the
TRI facility ID and DCN (docu-
ment control number) for each sub-
mittal (documentation for one
chemical from one facility). These
identifiers can be used throughout
Figure 1
3 POTW/Oftsite
Location
Report
4. Facility
Profile
Report
6. Chemical/
Geographical/
SIC Code
Report	
7. Form "R"
Facsimile
Request
i	
BATCH REPORTS
TRIS DATABASE OPTIONS
O



1. Chemical


(CAS# or Chet
Report
I Opt: location
Vs^.
2. Geographic

Location
	1
Report

— 1. Facility Info
Year
' Facility ID, DUNS#,>
EPA ID#, DCN, or
Facility Name
\Opt: CAS# or Chert
5. Regional TRIS

Submissions

Report

2. Releases/Transfers
By Facility, Including
Total Chem By
Location
Year
'Control Totals Only?^
Any Combination:
CAS# or Chem,
Location, or SIC,
Year
'Facility ID, DUNS#,"
EPA ID#, DCN or
Facility Name
sOpt: CAS# or Chem/
3. Releases/Transfers
Activities/Uses
By Facility	
Facility Info, ID #s
Releases/T ransfers
POTW/Offsite Info
Activities/Uses

List of Facility

Submissions: iD#s,

Name, Addr, Contacts,

Chem Info, Location
Cy^NameN.
Waste Minim Info
[ Selection V-
Releases/T ransfers
\ScreenJ
Activities/Uses

Listing of: Facilities,
ID#s, Contacts,
CAS#s, Chemicals
Total Releases/Media/
Location
/SortN
\Ordej/
Facility ID#s, DCNs
Releases, Total
Releases by Medium
For Location
Facsimile of Form
Submitted by Facility

ONLINE QUERIES
Facility Name(s). AdcJr
DCN, CAS#, SIC
Facility II)#
[ Selection)
^Screen;
7 Year-to-year
Release/Transfer
Comparison
Comparison ol
Releases for
All Chems
All Years
4

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TRIS (continued)
TRIS to access information on a
given facility.
(1)	Go to ONLINE QUERIES.
(2)	Select: 1. FACILITY NAME
SEARCH.
(3)	Select the reporting year and
facility name (the search may
be narrowed by selecting a
specific geographic area).
(4)	The number of submittals
found appears on the screen;
press enter to view.
The CHEMICAL/GEOGRA-
PHICAL/SIC CODE REPORT is a
program that identifies facilities
emitting the specified chemical,
focused if desired within an SIC
Code, for a particular geographic
area. The report will also give the
amount of the chemical released to
each medium by facility and the
total for all facilities. Alternatively,
the totals only may be requested.
(1)	Go to BATCH REPORTS.
(2)	Select: 6. CHEMICAL/
GEOGRAPHICAL/SIC CODE
REPORTS.
(3)	Specify yes or no in CONTROL
TOTALS ONLY and the
desired combination of CAS
number, Region/State/City/
County/Zip Code, and SIC Code.
(4)	Select the desired sort order
and press enter to submit the
report.
The YEAR-TOYEAR
RELEASE TRANSFER COM-
PARISON option provides the
changes in releases at a facility
over time, currently 1987 and
1988.
(1) Select ONLINE QUERIES.
(2)	Select: 7. YEAR-TOYEAR
RELEASE TRANSFER
COMPARISON.
(3)	Select the TRI facility ID or
facility name and whether to
include delisted chemicals. The
search can be narrowed by in-
dicating a CAS number. (In
selecting a facility name, a
FACILITY NAME selection
screen appears that lists facility
names, TRI facility IDs, and
the number of submittals for
each. The user must specify
the ones of interest with an
"X" and hit the PF9 key to
submit the names.)
For any questions about these
instructions, or other ways to view
TRIS data, contact the Clearing-
house staff.
"See related article in the May 1990
Newsletter, p. 3
SCAQMD Controls Landfill Gas Emissions
The following overview was
adapted from a longer paper pre-
sented by Robert R. Pease, Mohsen
Nazemi, Rodney W. Millican, and
Stacey M. K. Ebiner of the South
Coast Air Quality Management
District at a meeting of the Air and
Waste Management Association in
June 1989 and updated by the
Newsletter staff in April 1990.
In 1984 the South Coast Air
Quality Management District
(SCAQMD) tested 20 municipal
landfills looking for the presence
of contaminants such as vinyl
chloride or benzene that had been
identified at hazardous waste
sites*. SCAQMD found both com-
pounds in 85 percent of the land-
fills tested. It is probable that this
is a nationwide occurrence.
The agency adopted Rule
1150.1, Control of Gaseous Emis-
sions from Active Landfills, in
1985.** Rule 1150.1 was adopted
as a result of a task force report
CARB produced in 1982 and work
the agency did in 1984 related to
reactive organic gas (ROG) emis-
sions and public nuisance odors
from landfills. At present, 35 land-
fills have submitted compliance
plans and 101 have requested ex-
emption from the rule. Of those,
85 requests were exempted, 8 were
denied, and decisions on the rest
are pending.
A broader inventory of landfill
gas compositions within and above
active and inactive landfills in the
State is currently being compiled
by the California Air Resources
Board through implementation of
State Health and Safety Code Sec-
tion 41805.5 by the local air
districts. The majority of the data
(84 test reports were completed)
for the State is expected to come
from landfills under SCAQMD
jurisdiction. CARB is compiling
the data to include in a report for
the State legislature this year.
Several Collection/Control
Systems Are Applicable
The heating value and the
amount of the landfill gas general-
ly dictate the type of control
system to be used. A survey of the
heating values of landfill gas
around the country showed that
more than half of the landfills pro-
duce gas with heating values of
less than 501 Btu/SCF, and only a
small portion of the landfills pro-
duce gas with high heat content.***
Depending on such variables as
how much landfill gas is available
and at what flow rate, and what
use is to be made of the gas, land-
fill operators decide whether to
collect the gas for incineration or
power generation.
Vertical wells and horizontal
trench wells are the preferred
technology for collecting the gas at
present. The interior wells are
spaced a nominal 100 to 300 feet
apart. Design spacing is much
5

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Landfills (continued)
closer between wells on the
perimeter of the landfill. Ideal
spacing minimizes the number of
wells yet provides necessary
negative pressure below cover at
maximum distance from the well
heads. Relatively high negative
pressures are pulled on the boun-
dary control wells or trenches.
If the collection system is pro-
perly designed and installed, it will
not only prevent odor and protect
the public from the release of toxic
pollutants, it will also ensure that
more gas is available for energy
recovery purposes.
Flares were first used to in-
cinerate the gas for migration con-
trol purposes and odor control. As
more and more landfill gas flares
were installed, improvements in
design and construction followed.
Multiple orifice-type burners were
used to spread the flame pattern,
resulting in increased flame con-
tact, higher destruction efficien-
cies, with lower NOx and carbon
monoxide emissions.
Landfill gas has been used to
fuel a multitude of power genera-
tion and thermal production equip-
ment. Similar to sewage digester
gas, landfill gas can be used to
generate salable energy, drive
mechanical equipment such as
pumps and blowers, or produce
steam. Various attempts were
made to treat raw landfill gas in
order to upgrade the quality and
Btu content. The treatment pro-
cess also removed the impurities
which are inherent in the gas.
However, at this time, there are no
gas treating facilities in operation
in this area.
To date, the majority of landfill
gas powers energy production
equipment such as engines and
boilers. Reciprocating piston-type
internal combustion engines firing
on landfill gas are used to drive
electric generators throughout
SCAQMD's jurisdiction. NOx
emissions from these engines are
lower than comparable natural gas-
fired engines due to lower Btu
content of the gas and the diluting
effect of the fuel-bound CO2.
The most recent power gener-
ation technology to use landfill gas
is the steam generator using the
Rankine Cycle. The gas is burned
in a boiler to produce superheated
steam. The steam is used to drive
a steam turbine-generator for
power production. The benefits of
the Rankine Cycle power produc-
tion from the combustion of land-
fill gas is the exceptional heat rate
of 10,000 Btu/KW. This is the
lowest rate and highest efficiency
of all of the LFG-fired power
generation systems to date. In ad-
dition, the Rankine Cycle has been
demonstrated to be one of the
lowest emitters of NOx and ROG
of any LFG-fired equipment. The
boiler is designed for low emission
rates by the following techniques:
•	Low NOx burner (low O2)
•	Flue Gas Recirculation (FGR)
•	Oxygen trim system
•	Low furnace heat flux
•	Low combustion air preheat
Toxic emissions from LFG-
fired boilers appear to be con-
trolled to acceptable levels, based
on source testing. High combus-
tion temperatures and a more than
adequate retention time in the fur-
nace provide a destruction effi-
ciency in excess of 99 percent for
total organics.
Landfills Conduct Risk
Assessments
Each landfill project must per-
form a risk assessment in order to
establish the extent of the public
health impacts of the project on
the exposed population. This is a
requirement of SCAQMD's ex-
isting Rule 212 and a proposed
rule (1401). Further, under
Assembly Bill 2588,**** a health
risk assessment may be required
from some landfills. In most in-
stances, a screening procedure
Table 1
Risks for Landfill Gas-Fired Projects

Gas Rate
Risk

Project
(cfm)
do-Ğr
Remarks
Boiler
24,000
0.10
2 boilers
Boiler
10,000
0.25
has booster fan
Boiler
7,000
0.01
1 boiler
Flare
7,500
0.023
5 flares
Flare
15,000
0.096
7 flares
Flare
3,750
0.919
2 flares
Flare
4,167
0.240
1 flare
Internal Combustion Engine
1,300
28
3 engines, no control
Internal Combustion Engine
950
0.326
1 engine, no contol
Internal Combustion Engine
400
0.045
1 engine, clean burn
Direct comparisons cannot be made because each value is specific to a landfill.
In general, however, boilers result in hwer risks than internal combustion
engines.
*Risk here is defined as: excess probability of cancer incidence to the maximum
exposed individual based on a 70-year lifespan.
6

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Landfills (continued)
which uses inhalation pathway
analysis, rather than a multi-
pathway analysis, is required to
determine potential exposure to
carcinogenic air contaminants. If
this risk is determined to exceed
one in one million (10"6), a detailed
modeling analysis will be required.
Currently, the District is in the
process of adopting a rule that will
clearly define toxic emissions
limits based on risk analysis (pro-
posed Rule 1401, scheduled for
adoption in June 1990). Table 1
estimates risks for landfill gas-
fired projects from various land-
fills throughout SCAQMD's
jurisdiction.
For further information regard-
ing the South Coast Air Quality
Management District's landfill gas
control and compliance program,
call Mohsen Nazemi, SCAQMD
engineering division, (818)
572-6145.	
*Note: California is the only State
now requiring landfill controls.
Although some 20 States have land-
fill regulations, most cover odor
only.
*	*See related Newsletter articles in
issues for July 1984, pp. 1-2 and
July 1987, p. 3.
*	* *Governmental Advisory Associa-
tion, Inc., "Methane Recovery From
Landfill Yearbook Directory and
Guide," 1986 - 1987.
*	* * * See article on CARB's "Hot
Spots" Regulation in the March
1990 issue of the Newsletter (p. 2).
STAPPA/ALAPCO Comment on Proposed MWC Regulation
After the proposed municipal
waste combustion regulations ap-
peared in the Federal Register in
December 1990 (54 FR 52209 and
52251), comments from STAPPA/
ALAPCO were among some 270
sets of comments EPA received by
the closing day of the comment
period, March 1, 1990. The pro-
posed regulations would provide
emission guidelines for existing
municipal waste combustors and
performance standards for new
combustors. STAPPA/ALAPCO
commented on these issues:
•	materials separation and
recycling
•	emission limits for organics,
metals, and acid gases
•	compliance /performance
•	monitoring
•	operator training and
certification
Following are highlights of the
comments, excerpted from
STAPPA/ALAPCO text.
With respect to the proposed
requirement that municipal waste
combustors separate and recycle
25 percent of materials prior to
combustion, the two associations
recommended that mandatory
recycling be "part of an overall
regulatory strategy for municipal
solid waste disposal (i.e., not just
the air program) and should be ap-
plied to other programs such as
landfills."
Concerning emission limits, for
organics STAPPA/ALAPCO
believe that dioxin/furan emissions
may not adequately represent all
organics as a surrogate. The
associations recommended that
additional surrogates, such as
methylene chloride, be chosen and
that standards be set for them. In
addition, STAPPA/ALAPCO also
suggested that "all products of
combustion should be subjected to
a residence time and temperature
limitation to ensure that organic
substances are properly com-
busted... and that EPA establish
standards to accomplish this."
STAPPA/ALAPCO also com-
mented on the proposed use of
particulates as a surrogate for
metals, stating that "particulates
are not representative of mercury
and recommending] that the
Agency develop a separate stan-
dard for these emissions." The
associations added their recom-
mendation that both new and ex-
isting sources, regardless of size,
be subject to the same standard.
STAPPA/ALAPCO further sug-
gested that the proposed standard
of 0.015 gr/dscf be changed to
0.010 gr/dscf and be required for
all municipal waste combustors,
not just for regional existing
sources. Further, the associations
stated their belief that "it is impor-
tant to require testing for condensi-
ble particulates [for all sources] as
part of a particulate standard."
Finally, the association advocated
lowering the proposed opacity level
from 10 percent to 5 percent.
The associations urged EPA to
select more stringent standards
than those proposed for acid gases
as well.
With respect to the compliance/
performance provisions of the pro-
posed regulation, STAPPA/ALAPCO
stated that "EPA's proposal could
be strengthened by shortening the
compliance periods for acid gases
from 24 to 4 hours and for carbon
monoxide and particulates from 4
hours to 1 hour (excluding startup
and shutdown periods)." Finally,
the associations suggested that
EPA "delete the proposed provi-
sion that would allow a source to
forego compliance testing for two
consecutive years if tests in the
three previous years demonstrated
compliance."
7

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California Publishes Toxics Directory
The California Department of
Health Services has published a
1990 Toxics Directory. The direc-
tory is designed to help people in
the health professions, environ-
mental work, the media, govern-
ment, and industry to find informa-
tion on toxic substances and their
health effects.
The directory describes more
than 80 governmental, educational,
and public interest organizations
on the national, State, and local
levels that can answer questions
about all types of toxic problems.
Numerous California government
offices that deal with toxics are
listed, as well as laboratories that
analyze hazardous materials and
contaminants.
The directory consists of cita-
tions of books, scientific journal
articles, and on-line computer data
bases. References include text-
books and handbooks, guides on
clean-up and management of tox-
ics, on-line environmental data
bases, and books and articles on
toxic substances by exposure
categories such as air and water,
substances of common concern
such as asbestos and dioxin, and
risk assessment and risk com-
munication.
Copies of the toxics directory
may be ordered at $5.50 each from
the State Publications Section, P.O.
Box 1015, North Highlands, CA
95660. Request Publication No.
7540-958-1300-3, and make checks
payable to State of California.
Note: Government agencies in
California may obtain a free copy
of the directory. To do so, or to ob-
tain a list of other publications on
toxics, write or call the Hazard
Identification and Risk Assess-
ment Branch (HIRAB), 2151
Berkeley Way, Berkeley, CA
94704, (415) 540-3063. Do not
send paid orders to HIRAB.
Hospital Waste Combustion Study
Has Corrected Table
The January 1989 issue of the
Newsletter (p. 14) described the
availability of The Hospital Waste
Combustion Study - Data Gather-
ing Phase, Final Report (EPA-450/
3-88-017) released in December
1988. The report contains the
results of a study of air emissions
from hospital waste combustion.
The hydrogen chloride emission
factor used in Table 3-3 of the
report is incorrect and has been
corrected. To obtain a copy of the
corrected table, contact Brenda
Riddle, Pollutant Assessment
Branch, (919) 541-5341.
Copies of the report are avail-
able through the Library Services
Office (MD-35), U.S. Environmen-
tal Protection Agency, Research
Triangle Park, North Carolina
27711, or from National Informa-
tion Services, 5285 Port Royal
Road, Springfield, Virginia 22161.
(continued from page 1)
achieved in practice by the best
performing similar sources. The
definition of MACT for existing
sources could be less stringent
than that for new sources because
an industry average of the best
performing sources could be used
as the benchmark. The debate in
both the House and the Senate
focused on the MACT definition
for existing sources.
The new definition in the
House bill establishes MACT for
existing sources at the level at
least as stringent as the average
emission limitation achieved in
practice by the best performing 15
percent of similar sources, ex-
cluding any sources which have
achieved, within the past 12
months, a level equivalent to the
lowest achievable emission rate as
defined by Part D, Section 171
(Plan Requirements for Nonattain-
ment Areas). This definition ap-
plies only to source categories of
30 or more sources. For source
categories of fewer than 30
sources, MACT is defined as the
control achieved in practice by the
best performing 5 sources.
The existing source definition
of MACT in the Senate bill is the
control achieved in practice by the
best controlled 10 percent of
similar sources. If there are fewer
than 30 sources within the source
category, MACT is defined as the
control achieved in practice by the
best performing 3 sources.
An important note about the
definitions of MACT in the House
and Senate bills is that there is
language to restrict the informa-
tion used to define MACT to the
data available to the Administrator.
The implication is that EPA will
not be required to conduct a
survey of each source in every
source category before MACT can
be established. The EPA still has
the discretion to establish levels
which are more stringent than the
MACT definition if it is determined
8

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(continued)
that MACT is not represented by
the sources in a particular source
category. This provision is impor-
tant because it opens the door to
technology transfer from other
similar, but better performing
source categories.
The MACT definition for new
sources was not changed by the
House or Senate bills. As original-
ly defined in the Administration's
bill, MACT for new sources re-
quires a level of control at least as
stringent as the control achieved in
practice by the best performing
similar source.
Accidental Release Prevention:
The original Administration ver-
sion of the Clean Air Act amend-
ments did not contain an acciden-
tal release program other than a
chemical accident investigation
board. The accidental release por-
tion of the bill in the House has
been modified several times since
the bill was first introduced. The
latest round of amendments by the
House makes the accidental
release provisions as passed very
similar to the requirements in the
Senate bill.
The House provision now re-
quires EPA, in consultation with
the Secretaries of Transportation
and Labor, to promulgate reason-
able regulations and appropriate
guidance for the prevention and
detection of accidental releases in-
to the ambient air. These regula-
tions, due 3 years after enactment,
would apply to all facilities with at
least one of a list of 100 chemicals
stored on site in excess of a thresh-
old quantity. The list of chemicals
and threshold quantities will be
developed as part of the regula-
tions. The House bill also includes
several chemicals which must be
included on such a list: chlorine,
anhydrous ammonia, methyl chlor-
ide, ethylene oxide, vinyl chloride,
methyl isocyanate, hydrogen
cyanide, tetrachloroethylene, am-
monia, hydrogen sulfide, phosgene,
bromine, anhydrous hydrogen
chloride, hydrogen fluoride, an-
hydrous sulfur dioxide, and sulfur
trioxide.
In addition to the accident
prevention regulations, an Acciden-
tal Release Investigation Board
would be established by the House
bill. Unlike the original Admini-
stration position, this board would
be an independent agency ap-
pointed by the President to investi-
gate any accidental release of a
listed chemical which causes
fatalities or serious injuries. The
board must report to Congress
every 2 years on further measures
which are needed to prevent ac-
cidental releases.
The Newsletter will continue to
follow the progress of the Clean
Air Act Amendments of 1990
through enactment. In the mean-
time, if you have questions about
air toxics issues in the Clean Air
Act amendments, call Tim Mohin
at (919) 541-5349 or (FTS)
629-5349.
OAQPS Publishes
Sludge Incinerator Report
The EPA's Office of Air Quality
Planning and Standards (OAQPS)
has published a report that pro-
vides information on estimating
emissions of toxic substances from
sewage sludge incinerators. This
report is entitled "Locating and
Estimating Air Emissions from
Sewage Sludge Incinerators"
(EPA-450/2-90-009). This emission
document is a part of the report
series of "Locating and Estimating
Air Emissions from (or of) (Sources
Category or Substance)." The pur-
pose of the sewage sludge inciner-
ator report is to assist air pollution
control agencies and others who
are interested in locating potential
sewage sludge incinerators and in
making preliminary estimates of
the emissions resulting from these
sources. This document contains
available information on the types
of sewage sludge incinerators and
their air pollution control equip-
ment. Emission factors are
presented for each major type of
sewage sludge incinerators for the
following compounds: metals in-
cluding arsenic, beryllium, cad-
mium, chromium, and nickel; and
organics including chlorinated
dibenzo-p-dioxins, dibenzofurans,
benzene, chlorobenzenes, and
phenol. Overviews of procedures
for source sampling and analysis of
air toxic emissions from these
sources are also provided.
Single copies of this report are
available by writing the EPA li-
brary at MD-35, Research Triangle
Park, NC 27711 or by calling (919)
541-2777 or (FTS) 629-2777. The
process to make the reports
available through the National
Technical Information Service
(NTIS) for a fee has been initiated.
No NTIS order number has yet
been assigned to the report. For
further information on the report,
contact Bill Kuykendal, EPA,
OAQPS, Noncriteria Pollutant Pro-
grams Branch (NPPB), MD-15,
Research Triangle Park, NC
27711.
9

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The NATICIINewsletter 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 2-5. The EPA Project Officer is Martha Keating, 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. 0. 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.
Martha Keating
Pollutant Assessment Branch
U.S. Environmental Protection Agency
MD-13
Research Triangle Park, NC 27711
FIRST CLASS MAIL
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E.P.A.
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