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Produced by the National Air Toxics Information Clearinghouse July 1992
Progress on the Clean Air Amendments of 1990
When the Clean Air Act
Amendments (CAA) were adopted
on November 15,1990, they required
significant progress in clean air
legislation and environmental results
in a relatively short time. The ob-
jective of the Amendments is to
reduce air pollution by 56 billion
pounds (28 million tons) per year
and thereby decrease threats to
public health and the environment
from exposure to ozone, acid rain,
urban air pollution, and air toxics.
The goals of implementing the
Amendments include a 70 percent
reduction in air toxics emissions, a
10 million ton decrease in sulfur
dioxide emissions, and complete
phaseout of chlorofluorocarbons
(CFCs). Title III, which addresses
air toxics, outlines a comprehensive
plan for achieving reductions in
emissions of hazardous air pollu-
tants (HAPs).
To date, significant progress
has been made on Title III and
other titles that relate to air toxics.
Table 1 provides a list of contacts
and publication references. Under
Title V, the State operating permit
rule was promulgated June 25,
1992, and guidance for State pro-
grams on small business assistance
has been published. Several rules
covering CFCs under Title VI (in-
cludes the two HAPs carbon tetra-
chloride and methyl chloroform)
have also been proposed or finaliz-
ed. Those proposed include a ban
(continued on page 2)
In This Issue...
Promulgation of the Operating
Permits Program 3
Source Category list
Finalized 3
Gearing Up For Early
Reductions 4
Initial MACT Standard*
Underway 5
Developed ?
From the Editor
This issue of the Newsletter is devoted to updates on progress toward imple-
menting Title III - Hazardous Air Pollutants - of the 1990 Clean Air Act Amend-
ments. Because the scope of Title III is so broad, it is not feasible to adequately ad-
dress each ongoing project and activity. The Newsletter staff has covered a variety
of topics, focusing on regulations that have been promulgated recently or are to be
promulgated soon, as well as projects for which there is significant activity to
report. For more information on a specific project, readers may write the contacts
directly at the following address (unless another is given): U.S. EPA, OAQPS,
MD-13, Research Triangle Park, North Carolina 27711. Contacts may also be
reached at the telephone numbers provided within the articles. The Newsletter will
continue to cover air toxics projects related to the Amendments, so that our readers
may keep abreast of Title III progress.
The Clearinghouse and the Newsletter are currently undergoing changes to
respond to the needs of State and local agencies. The NATICH staff is reviewing
proposed changes to the contents of the NATICH data base. Users may also see dif-
ferences in the annual NATICH reports and how the NATICH data base is accessed
in the future.
Regular readers will have noticed printing changes in the current and
previous issues of the Newsletter as well as distribution delays. Changes in appear-
ance are also likely to occur. The staff hopes to have changes to the Newsletter com-
pleted by the November issue. To facilitate this, no September issue will be published.
The staff appreciates your patience and welcomes ideas and articles for the
Newsletter. Comments or suggestions for changes related to the data base are also
welcome. Please call the NATICH staff at (919) 541-0850.
Carol Jones
Editor
	1 TPRAIiY >	
AUG 28 1992 V.';.

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Progress on the CM (continued from page 1)
on nonessential products and CFC
labeling requirements. Mobil air
conditioning recycling regulations
were published in the Federal
Register on July 14, 1992, and CFC
phaseout regulations have been
finalized and were to be published
the last week of July 1992.
Under Title III, a list of the
major and area source categories
emitting one or more HAPs was
published on July 16,1992. The
schedule for regulating these
sources should be published in
November 1992 (see page 3). On
June 13,1991, guidance for the
Early Reductions Program was also
published and the final regulation
for the program should be published
this summer (see page 4). The first
maximum available control technol-
ogy (MACT) standard, which
regulates dry cleaners using per-
chloroethylene, was proposed in
November 1991 (see page 5).
In addition, several projects
are currently under development.
A list of substances to be regulated
under the Chemical Accident Pre-
vention Program is being prepared
for proposal this summer (see page
10). EPA staff is also preparing a
guidance document for determin-
ing MACT for new, modified, or
reconstructed major sources under
Section 112(g). This guidance
document will also be used for
case-by-case MACT determinations
under Section 112(j) when EPA
does not promulgate emissions
standards on schedule (see page 7).
In addition, efforts are underway to
design provisions for delegating air
toxics programs to States.
Despite EPA's efforts to imple-
ment the Amendments within the
required timetables, several statu-
tory deadlines have been missed.
This has happened primarily
because the Amendments are very
comprehensive and the implemen-
tation schedule is quite ambitious.
The Amendments require more
than 120 regulations by 1995, an
average of 24 per year, a monumen-
tal task in itself. In addition, EPA is
incorporating innovative, market-
based strategies to achieve the
goals of the CAA and support
economic growth. Techniques such
as regulatory negotiations and
pollutant trading and banking are
being employed. EPA staff is also
involving State and local agencies,
other Federal agencies, and indus-
try and environmental groups
earlier in the regulatory process.
The Agency is attempting to prom-
ulgate rules that are behind
schedule as quickly as possible and
stay on schedule for future rules. It
is hoped that with greater input and
the use of market-based strategies,
future rules will be more effective
in attaining the goals of the CAA.
Some of the details in this arti-
cle were obtained from the draft
implementation strategy for the
Clean Air Act Amendments of
1990, which is to be published this
summer. For more information,
contact Alex Wolfe at EPA Head-
quarters (ANR-443), 401 M Street,
S.W., Washington, D.C. 20460,
(202) 260-7418.
Table 1.
Contacts and Publication References
Project
Contact
FRorCFR
Notice'
Date of
Publication
Operating Permits
Kirt Cox
(919) 541-5399
57 FR 32250
July 21, 1992
CFC Phaseout Regulations
David Lee
(202) 260-1497
40 CFR Part 82
49548
September 30,
1991"
Mobil Air Conditioning
Recycling
Lena Nirk
(202) 233-9147
40 CFR Part 82
31241
July 14, 1992
Ban on Nonessential
Products
Matthew Dinkel
(202) 233-9194
40 CFR Part 82
1992
January 16,
1992
CFC Labeling
Requirements
Sue Stendevach
(202) 233-9117
40 CFR Part 82
19165
May 4,1992
Early Reductions
Dave Beck
(919) 541-5421
Rick Colyer
(919) 541-5262
56 FR 27338
June 13,1991
Source Category List
Tom Lahre
(919) 541-5668
57 FR 31576
July 16,1992
MACT Standard for Dry
Cleaners
George Smith
(919) 541-1549
56 FR 64382
December 9,
1991
' Federal Register (FR) or Code of Federal Regulations (CFR) citations.
b Citation for proposed rule; final rule not published.
Frequently Used
Acronyms
CAh. Clean Air Act Amend-
ments of 1990
GACT Generally Available
Control Technology
HAP Hazardous Air Pollutant
HON Hazardous Organic
NESHAP
MACT Modrtoom Available
Control Technology
NESHAP National Bmbaton Stan-
dard for Hacardoua Air
Pollutants

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Promulgation of the Operating Permits Program
by Kirt Cox, EPA Office of Air Quality Planning and Standards
The regulation to establish an
operating permits program that will
serve as the basis for implementing
all CAA requirements that apply to
most stationary sources was signed
June 25 and published in the July 21,
1992, Federal Register. The far-reach-
ing regulation contains criteria de-
scribing what constitutes an approv-
able State program. The require-
ments under Title V of the CAA
were described in the May 1991
NATICH Newsletter. EPA anticipates
that this program will significantly
improve air quality management by
providing more efficient implemen-
tation of the CAA Enforcement will
be improved>ecause permits aid en-
forcement and require periodic
certifications. This improved enforce-
ment is expected to result in a higher
rate of compliance. The program
also requires permit fees that will
enhance State air program resources.
This rule, along with concurrent
development of programs under
Section 112, provides a solid basis
for using Title V permits to imple-
ment air toxics control measures
including National Emission Stan-
dards for Hazardous Air Pollutants
(NESHAPs), early reductions, and
the use of Section 1120) to dele-
gate Federal air toxics regulatory
programs to States.
One of the most controversial
aspects of applying the operating
permits program to Title III was
whether a source might delay com-
pliance with a NESHAP that is
promulgated after the source
received an operating permit. The
final rule provides that implementa-
tion of new NESHAPs will not be
delayed by permitting. Another
controversial part of the final rule
provides for a minor permit modifi-
cation process by which a source
could receive an expedited review,
without public comment, of certain
increases in emissions if the
increases do not constitute a 'Title
I modification." Since Section 112(g)
modifications are one form of Title
I modifications, the decisions made
in developing the 112(g) program
will be significant to permitting as
well.
Although extensive review
delayed the rulemaking mandated
for promulgation by November 15,
1991, the CAA requires that States
submit programs to the EPA for ap-
proval no later than November 15,
1993. Details on what constitutes
an approvable State permit program
are provided in the regulation.
For more information, contact
Kirt Cox, (919) 541-5399, U.S. EPA,
OAQPS, MD-15, Research Triangle
Park, North Carolina 27711.
Source Category List Finalized
by Tom Lahre and Chuck French, EPA Office of Air Quality Planning and Standards
In the July 16,1992, Federal
Register, the EPA published a list of
categories of major and area sources
of HAPs that would be subject to
emission standards under Section
112 of Title HI of the CAA.* This Ust
will be an integral part of EPA's air
toxics program under Section 112.
EPA received about 150 com-
ments on the draft list during the
public comment period from in-
dustry, environmental groups,
academia, and Federal, State and
local agencies. Most of these com-
ments related to:
1.	the quality and inclusiveness of
the underlying data base used to
compile the draft list;
2.	the definition and disaggregation
of various categories of sources;
3.	the need for a finding of threat
of adverse effects before listing
categories of area sources; and
4. alternatives for listing the cate-
gories of steam electric genera-
tors and incinerators.
Based on these comments and
further internal Agency review, the
draft list of categories of sources
was reduced for three primary
reasons. First, EPA consolidated a
number of categories to clarify the
definitions of certain categories, as
well as to expand the opportunity
to consider emissions averaging
when setting emission standards.
For example, the Synthetic Organic
Chemical Manufacturing Industry
(SOCMD category, which was ap-
proximately 400 categories on the
draft list, was consolidated into a
single category. (Emissions averag-
ing potentially allows a facility to
"overcontrol" emissions on one or
more regulated sources while
"under controlling" emissions at
other regulated sources, as long as
an overall emissions standard is
met.) Second, EPA removed some
categories where inadequate evi-
dence exists to show that at least
one source in the category is a ma-
jor source. Finally, a number of
categories of area sources were
deferred because no finding of a
threat to human health or the
environment warranting regulation,
as required under Section 112(c) (3),
has been made. For instance, a
number of categories of small com-
bustion devices were removed from
the draft list
The source category list that
was recently published in the
Federal Register is referred to in the
CAA as the initial list. This fall, the
Agency expects to publish a draft
schedule for standards for each in-
(contikued on page 4)
3

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Source Category List (continued from page 3)
itially listed category. Standards for
40 of the initially listed categories
must be established by November
15,1992; for coke ovens by Decem-
ber 31,1992; for 25 percent of all
initially listed categories by Novem-
ber 1994; for 50 percent by Novem-
ber 1997; and for all initially listed
categories by November 1994; for
50 percent by November 1997; and
for all initially listed categories by
November 2000. Any category added
after this initial list is published must
have standards established by Nov-
ember 2000, or within 2 years after
listing, whichever is later. The draft
schedule will provide the public an
opportunity to comment prior to
publication of the final schedule,
which Section 112(e) requires by
November 15,1992.
In determining priorities for
promulgating emission standards,
Section 112(e) specifies that EPA
consider the following three criteria:
1.	the known or anticipated adverse
effects of HAPs on public health
and the environment;
2.	the quantity and location of
emissions of HAPs that a listed
category would emit; and
3. the efficiency of grouping
categories according to the
pollutants emitted, the processes
used, or technologies that could
be employed.
For more information, contact
Tom Lahre concerning the source
category list, (919) 541-5668, or
Chuck French about the regulatory
schedule, (919) 541-0647.
*See related article in the March
1991 Newsletter.
Gearing Up For Early Reductions
by David Beck, EPA Office of Air Quality Planning and Standards
As reported in the July 1991
issue of the NATICH Newsletter,;
EPA is implementing the Early
Reductions Program established
under Section 112(i)(5) of the CAA.
The program offers companies
emitting HAPs a 6-year extension
to comply with future Section 112(d)
MACT or GACT* standards that
may affect their HAP emission
sources in return for achieving early
HAPs reductions at those sources.
To qualify for the extension, com-
panies must define the participat-
ing source, select a base year (1987
or later), and achieve a 90 percent
reduction in HAPs emitted from
that source in the base year (95
percent reduction for particulate
pollutants). In defining the source,
companies will have the flexibility
to choose all or only part of a plant
site to participate in the program.
Also, each emission point does not
have to be reduced by 90 (95) per-
cent; rather, the 90 (95) percent
reduction can be achieved as an
average across all emission points
in the source. Generally, reductions
must be achieved prior to proposal
of an applicable Section 112(d)
standard; however, sources subject
to early standards (those proposed
before the end of 1993) may enter
the program by making an en-
forceable commitment to achieve
the required reductions prior to
January 1,1994. EPA proposed
regulations to implement this pro-
gram on June 13,1991 (56 FR
27338); final regulations are ex-
pected to be published this summer.
This program is appealing
because both industry and the en-
vironment can win. Industry will
find it attractive if achieving an
average 90 or 95 percent reduction
for a source involves less cost than
meeting the requirements of a Sec-
tion 112(d) standard. On the environ-
mental side, even if a 90 or 95 per-
cent early reduction is less than the
reduction ultimately required by
the Section 112(d) standard, the
fact that the reductions are made
significantly earlier than required
by future standards results in lower
overall emissions to the environ-
ment This early reduction more
than compensates for the lower
reduction percentage.
Although the regulations are
not yet final, approximately 60 com-
panies to date have made enforce-
able commitments under the Early
Reductions Program based on the
guidance in die proposed regula-
tions. Most of these enforceable
commitments are from chemical
companies that would be subject to
the forthcoming Section 112(d)
standard covering a large segment
of the Synthetic Organic Chemical
Manufacturing Industry (SOCMI).
This standard is referred to as the
Hazardous Organic NESHAP -
National Emissions Standards for
Hazardous Air Pollutants (HON;
see page 6). The commitments, if
approved and fulfilled, will reduce
HAP emissions by millions of
pounds. EPA is now evaluating the
commitments received, primarily
focusing on the technical accuracy
of the base year HAP emissions
estimate contained in each commit-
ment. Following EPA's technical
evaluation and an opportunity for
public comment, EPA will approve
or disapprove a company's enforce-
able commitment
An enabling document further
explaining details of the program
will be available from EPA after pub-
lication of final early reductions reg-
ulations. For further information on
the Early Reductions Program, con-
tact David Beck, (919)541-5421, or
Rick Colyer, (919) 541-5262.
*GACT, generally available control
technology
4

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Initial MACT Standards Underway
MACT standards must be estab-
lished for each listed source cate-
gory within 10 years of CAA enact-
ment (see page 3). These techno-
logy-based standards must reflect
the maximum degree of emissions
reductions deemed achievable by
EPA. In determining such standards,
EPA must consider not only health,
environmental, and energy impacts,
but also the cost of achieving the
emissions reductions. For area
sources, EPA has the discretion to
apply GACT or management prac-
tices instead of MACT requirements.
Dry cleaners, coke ovens,
hazardous organic chemical manu-
facturing, and chromium electro-
plating are among the first source
categories to be regulated under
Section 112. The MACT standard
for dry cleaners was proposed in
1991, and the standards for the other
three sources should be proposed
in 1992. Updates on the status of the
MACT standards for dry cleaners,
coke ovens, and chromium electro-
plating appear below, and an over-
view on the Hazardous Organic
NESHAP (HON) follows in a
separate article.
Standard for Dry Cleaners
One of the 189 toxic air pol-
lutants to be regulated under the
CAA is perchloroethylene (PCE or
Perc), the most widely used solvent
in the dry cleaning industry. The
regulation, proposed in December
1991, is the first MACT and GACT
standard to be established under
the CAA Amendments. The proposed
rule reflects EPA's efforts to mini-
mize costs to small businesses. Of
the estimated 25,200 dry cleaning
facilities in the United States, ap-
proximately 9,700 currently have
no controls and could be affected
by this rule; however, the economic
needs of small businesses are pro-
tected by "consumption cutoffs,"
which exempt all but 3,700 of the
uncontrolled plants from having to
install controls. The cutoffs of 220
gallons of PCE consumed per year
for dry-to-dry machines (that wash
and dry in the same unit) and 300
gallons of PCE consumed per year
for transfer machines (that wash
and dry in separate units) will ex-
empt many smaller dry cleaners.
The proposed rule would re-
quire operators to install a carbon
adsorber, refrigerated condenser,
or equivalent device to control vented
PCE emissions. Dry cleaners would
also have to implement pollution
prevention practices that reduce
PCE emissions. Such practices
would include operating dry clean-
ing machines and auxiliary equip-
ment properly to minimize emis-
sions, keeping records of the
amount of PCE used to determine
the amount of control required, and
performing weekly inspections to
prevent emissions from broken or
improperly functioning equipment.
The rule is expected to reduce the
total annual emissions of PCE by
13 to 26 percent.
For more information, contact
George Smith, (919) 541-1549.
Coke Oven Standard
EPA is also developing a stan-
dard for emissions from coke ovens.
The terms of this standard are cur-
rently in a regulatory negotiation
process, in which public meetings
are held in Washington, D.C., for
EPA, State and local agency repre-
sentatives, industry representatives,
environmental groups, labor unions,
and other interested parties. These
negotiations have resulted in a ten-
tative agreement on a set of stan-
dards for coke ovens. The EPA plans
to propose a regulation this fall.
Since the standard has not been
proposed to date, the statutory
promulgation date of December 31,
1992, will probably not be met.
The tentative agreement sets
standards for MACT and lowest
achievable emission rate (LAER)
for existing sources, and MACT for
new sources based on a 30-day roll-
ing average of emissions from doors,
lids, off-takes, and the oven-charg- '
ing process. In addition, work
groups will meet to establish work
practice standards and observer
certification procedures. Finally,
by March 1994, most plants will
install flares on their bypass
bleeder stacks that will prevent the
venting of raw coke oven gas in
case of a malfunction.
For further information, con-
tact Amanda Agnew, (919) 541-5268.
Chromium Electroplating
Standard
Another area to be regulated
under Title III is emissions from
chromium electroplating processes,
including hard chrome plating, dec-
orative chrome plating, and chromium
anodizing. There are approximately
5,000 operations in the United States
using one of these processes. The
strategy for the chromium electro-
plating standard is currently under
review by EPA management. After
a regulatory approach is selected
from among several options, the
preamble and regulation will be
drafted. A mqjor issue for manage-
ment is whether to use a lesser
quantity emission rate (LQER)
approach* in determining the
facilities affected by the standard.
Another issue to be resolved is the
control technology to be recom-
mended in the standard. Possibil-
ities being considered are packed-
bed scrubbers and composite mesh-
pad systems for hard chrome plat-
ing, trivalent chrome solution and
fume suppressants for decorative
chrome plating, and fume sup-
pressants for chromium anodizing.
The EPA currently plans to pro-
pose the chromium electroplating
regulation in January 1993.
For more information, contact
Lalit Banker, (919) 541-5420.
* With the lesser quantity emissions
approach, the EPA Administrator
sets the definition for a major source
at a level less than the level set by the
CAA, which is 10 tons per year for
any HAP or 25 tons per year for any
combination ofHAPs. Such action
may be warranted for extremely toxic
pollutants.
5

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Provisions of the Hazardous Organic NESHAP
by Daphne McMurrer, EPA Office of Air Quality Planning and Standards
One of the National Emission
Standards for Hazardous Air Pollu-
tants (NESHAP) being developed
under the authority of the Clean
Air Act Amendments of 1990 is
commonly known as the HON.
The HON, or Hazardous Organic
NESHAP, will regulate HAP emis-
sions from the Synthetic Organic
Chemical Manufacturing Industry
(SOCMI) source category as well
as equipment leaks from seven
non-SOCMI processes. These seven
non-SOCMI processes include the
production of styrene/butadiene
rubber, polybutadiene, chlorine,
pesticides, and pharmaceuticals,
and the use of chlorinated hydro-
carbon and butadiene. Because the
SOCMI is a large source of HAP
emissions, the HON is expected to
result in a larger reduction in emis-
sions than achieved with any other
single NESHAP. The HON is ex-
pected to reduce emissions by
more than 600,000 tons each year
after it is fully implemented.
The current version of the
HON, which is under review by the
Office of Management and Budget
(OMB), will achieve these emission
reductions by requiring the applica-
tion of MACT at all SOCMI facili-
ties that are major sources (defined
as facilities emitting more than 25
tons/year of total HAP emissions
or more than 10 tons/year emis-
sions of any single HAP). The HON
will not apply to facilities that do
not meet the major source criteria
or to research and development
facilities.
The HON has specific MACT
requirements for five kinds of emis-
sion points (shown in Table 1): pro-
cess vents, transfer operations,
storage vessels, wastewater opera-
tions, and equipment leaks. The
MACT requirements for process
vents, storage vessels, transfer
operations, and wastewater opera-
tions are performance and equip-
ment standards that can be achieved
by applying certain well-demon-
strated control techniques, referred
to as "reference control technol-
ogies." For these four kinds of
emission points, new technologies
that can be demonstrated to achieve
the same level of emission reduc-
tion as the reference technologies
can also be used for compliance
with the HON.
MACT for equipment leaks
will be a work practice standard
that was developed by regulatory
negotiation. As part of this regula-
tory negotiation process, it was
agreed that the equipment leak
standard in the HON would apply
not only to SOCMI, but also to the
(continued on page 7)
Table 1.
Summary of HON Controls
. Emission Point
Reference Control Technology
Reference Control Efficiency (%)
Process Vents
• Combustion
-	Flare
-	Incinerator
-	Boiler/Process Heater
98
Storage Vessels
•	Internal floating roof
•	External floating roof
•	Closed vent system with controls
95
Wastewater
• Controlled transport and storage and
steam stripper with controls for stripper
vents
95-98"
Transfer Operations
•	Combustion
-	Flare
-	Incinerator
-	Boiler
•	Recovery
98
Equipment Leaks
•	Enhanced leak detection and repair
•	Equipment specifications
80-88b
* The efficiency for the wastewater stripper is 95-98 percent The percent HAP reduction from wastewater varies with
the compounds and concentrations in the individual streams.
b Efficiency varies depending on the equipment in the process unit and other factors.
6

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Provisions of the HON (continued from page 6)
seven processes listed above.
These seven processes were part
of the negotiated agreement and
include sources that are similar to
SOCMI sources covered in the
agreement.
The HON also includes a pro-
vision for trading or "averaging"
emissions from different emission
points at the same facility, as long
as those emission points are sub-
ject to this rule. This emissions
averaging system has been designed
to allow a source to reduce com-
pliance costs while achieving equal
or slightly greater emissions reduc-
tions. As with other pollutant tra-
ding systems, there are questions
about the complexity and enforce-
ability of the HON's emissions
averaging system. This provision is
expected to be a focal point during
the comment period between the
HON's proposal and promulgation.
Once OMB review is com-
plete, the proposed rule will be
published in the Federal Register
and an opportunity for a public
hearing and written public com-
ments will be provided. After ad-
dressing these public comments,
the final rule will be promulgated,
and compliance will be required
within 3 years of the HON's pro-
mulgation date.
For more information, contact
Jan Meyer at (919) 541-5254 or
Daphne McMurrer at (919)
541-0248.
MACT Guidance Being Developed
by Lynn Hutchinson and Dennis Doll, EPA Office of Air Quality Planning and Standards
Under Section 112(g), a MACT
determination must be made for (1)
major sources of hazardous air pol-
lutants that construct, reconstruct,
or modify prior to the promulgation
of applicable Section 112(d) emission
standards, and (2) those that modify
after the setting of applicable Section
112(d) standards. A modification is
defined as a physical or operational
change that causes a greater than
de minimis* increase in HAP emis-
sions from a source for which off-
sets, as defined in 40 CFR Part 63,
cannot be obtained.** To support
implementation of this requirement,
EPA is developing a guidance
manual to assist owners or operators
and reviewing agencies in making
MACT determinations. When no
emission standards have been
promulgated for a source category
as required by Section 112(d), this
manual will provide guidelines for
determining MACT on a case-by-
case basis. When emissions stan-
dards have been established, the
manual will establish procedures
for owners or operators to demon-
strate, to a reviewing agency, that
the MACT requirements will be
met
This guidance will also be used
for MACT determinations under
Section 112(j), which becomes ef-
fective if EPA fails to promulgate
MACT standards in accordance
with the source category schedule
(see page 3) established pursuant
to Section 112(e). If this occurs,
major sources must submit permit
applications beginning 18 months
after the missed deadline. The per-
mitting authority must then issue a
permit that contains emission limits
determined on a case-by-case basis
to be equivalent to the standards
that should have been promulgated.
If a MACT standard is subsequently
issued, the permit must be revised
to reflect this new standard.
Based on preliminary discus-
sions, the MACT guidance manual
will address topics such as:
1.	emission sources that require
MACT determinations;
2.	control technologies that meet
the "MACT floor"***
requirement;
3.	alternatives for determining the
MACT floor;
4.	data bases providing for technol-
ogy transfer; and
5.	administrative procedures for
making a MACT determination.
Throughout the development
of this manual, EPA will strive to
develop procedures compatible
with existing State air toxics pro-
grams, while also providing for
determinations of MACT that are
consistent with the legislative
intent.
The OAQPS project leader for
Section 112(g) is Tim Smith, (919)
5414718, and the project leader for
Section 1120) is Kathy Kaufman,
(919) 541-0102. The contact for
case-by-case MACT guidance is
Lynn Hutchinson, (919) 541-5624.
*De minimis is not defined by the
CAA, but will be defined during
development of the Section 112(g)
project.
*	*For more information, see related
article in the November 1991
Newsletter.
*	* * MACT floor refers to the control
technology definitions in Section
112(d).
7

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Special Studies Continue
In addition to the rules, stan-
dards, and guidance mandated by
the CAA, Title III requires several
special studies. The topics range
from atmospheric deposition to risk
assessment, and the studies vary in
purpose. Some are exploratory, only
intended to evaluate current pro-
cedures or assess potential hazards;
others may result in rules or stan-
dards. Updates on some of the
special studies follow.
Great Waters Program
The Great Waters Program*,
mandated under Section 112(m), is
currently focusing on drafting the
1993 report to Congress, which will
describe the present state of know-
ledge on the environmental health
of and threats to the Great Waters
(see Figure 1). Teams of experts
are preparing supporting documents
that will serve as the basis for the
report. The report, as currently en-
visioned, will be short and easy to
understand, using graphics to con-
vey much of the information. The
report will address the five main
questions posed by Section 112(m):
1.	What is the pollutant loading
from the atmosphere relative to
the total loading?
2.	What are the human health and
environmental effects of those
pollutants?
3.	What are the sources of those
pollutants?
4.	Do the atmospheric loadings
contribute to violations of water
quality criteria or standards? and
5.	What Federal regulatory revi-
sions are necessary to prevent
any adverse effects?
For each of these five ques-
tions, the report will describe the
current knowledge on the topic,
what conclusions can be reached
with available information, what in-
formation is still needed, how that
information may be obtained, and
what progress is being made to col-
lect this information. The report
will be available after submittal to
Congress in November 1993.
For further information on the
Great Waters Program, contact
Melissa McCullough, (919) 541-5646.
Electric Utility Steam Generating
Units
In Section 112(n)(l)(A), Con-
gress mandated that the EPA study
the public health hazards associ-
ated with HAP emissions from elec-
tric utility steam generating units
after imposition of the CAA require-
ments. The EPA is to develop and
describe alternative control strat-
egies for HAPs that may warrant
regulation under Section 112. If the
EPA finds from the study that
regulation is warranted, it shall
then proceed with rulemaking
activities. This study is currently
scheduled to be presented in a
report to Congress by 1995.
To date, EPA has participated
in a series of meetings with industry
and governmental groups to coor-
dinate emission test programs and
exchange information regarding
utility toxics activities. The EPA
has also started to:
1.	develop Fourier transform
infrared spectroscopy field
activities,
2.	identify available methodologies
for assessing indirect human
exposures to air toxics,
3.	develop a source description data
base for the exposure models,
4.	develop a matrix of boiler type
and control technology config-
urations to use in the test pro-
gram and impact analyses,
5.	investigate the status and feasi-
bility of using available HAP
emissions data, and
6.	further define the exposure
(both direct and indirect)
models that will be used.
Another provision under Sec-
tion 112(n) includes the characteri-
zation of mercury emissions from
utility steam generating units (see
below). The EPA is gathering data
on mercury emissions as part of
the utility study.
For further information on the
utility study, contact Bill Maxwell,
(919) 541-5430.
Mercury Study
Section 112(n)(l)(B) man-
dates that a comprehensive study
of mercury emissions be prepared
for Congress by November 1994.
The study is to consider mercury
emissions from utility steam
generating units, municipal waste
combustion units, and other sources
including area sources. The study
will include an analysis of the rate
and mass of mercury emissions,
the associated health and environ-
mental effects, and the available
technologies and costs to control
the sources under study. Planning
for the study is currently underway.
For additional information on
the mercury study, contact Rick
Mattick at (919) 541-3990, or
Martha Keating at (919) 541-5340.
Hydrogen Sulfide Study
The hydrogen sulfide study
mandated under Section 112(n)(5)
will assess public health and environ-
mental hazards resulting from hy-
drogen sulfide released during the
extraction of oil and natural gas. A
report to Congress is due by No-
vember 1992, and, upon completion
of the report, EPA shall, as appro-
priate, develop and implement a
control strategy for hydrogen sulfide
emissions to protect human health
and the environment.
Presently, EPA is conducting
an initial review of State regulations
that control hydrogen sulfide, as well
as health and environmental data
including incidents that resulted in
death or injury from exposure to
hydrogen sulfide from oil and gas
wells. The EPA's Office of Solid
Waste and Emergency Response has
expressed interest in doing further
in-depth studies regarding acciden-
tal releases from oil and gas wells.
For additional information on
this study, contact Tim Simpson,
(919) 541-2469.
(continued, on page 10)
8

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figure 1.
Water Bodies Designated for Study Under Section 112(m)*
PacMaBay,
Pugrt Sound,
San
(O
Wells, ME
Casco Bay, ME
Great Bay. NH
Mass /Cape Cod Bays, MA
Waquoit Bay, MA
Buzzards Bay, MA
Narragansett Say. Rl
Long Island Sound, CT and NY
New York/
New Jersey Harbor, NY and NJ
Delaware Bay. NJ and PA and DE
Delaware Inland Bays, DE
Chesapeake Bay, M)
Chesapeake Bay, VA
Albemarle-Pamlico Sounds, NC
North Inlet- Winyah Bay, SC
ACE Basin, SC
Sapelo Island, OA
Legend
A NQAA NERRS Proposed Sites**
• NQAA NERRS Designated Sites**
¦ EPA National Estuwy Program Sites
+ Great Waters designated by name
D EPA and NQAA NERRS Proposed Sites
~ EPA and NQAA NERRS Designated Sites
* Monitoring sites will be selected from these designated waters.
This map provides a more complete listing of sites than the version
published in the January 1992 Newsletter.
**NQAA - National Oceanic and Atmospheric Administration
NERRS - National Estuarine Research Reserve System

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The Chemical Accident Prevention Program Proceeds
With the signing of the CAA
on November 15, 1990, Congress
expanded EPA's existing Chemical
Accident Prevention Program
under Section 112(r) and gave new
responsibilities within that program
to the EPA, the Occupational Safety
and Health Administration (OSHA),
and industry. This article reports
on progress in this program.
The EPA established the
Chemical Accident Prevention Pro-
gram in 1986 in response to Title
III of the Superfund Amendments
and Reauthorization Act (SARA),
which required EPA to conduct a
review of emergency systems to
monitor, detect, and prevent chemi-
cal accidents at facilities across the
nation. EPA went beyond the
specific mandates of SARA Title III
by collecting information on
chemical accidents and working to
foster communication with and
among the various groups that
have an interest in the study and
prevention of chemical emergencies.
The passage of the 1990
Amendments gave these communi-
cations an official status. The CAA
recognizes the breadth of existing
accident prevention programs and
clearly defines the responsibilities
of EPA, OSHA, and industry for
the continuation of these programs.
In general, EPA is required to
develop regulations and guidance
designed to protect the environ-
ment and public health from ac-
cidental releases, and OSHA must
similarly protect the health of
employees who work with hazard-
ous chemicals. Facilities regulated
by the CAA are required to prepare
risk management plans and to com-
ply with any accidental release pro-
gram that EPA may adopt.
EPA Developing List of
Substances to be Regulated
One of EPA's responsibilities
under Section 112(r) is to develop
and publish a list of at least 100
substances that, in the event of an
accidental release, "are known to
cause, or may reasonably be antici-
pated to cause death, injury, or
serious adverse effect to human
health or the environment." The
CAA specifically listed 16 sub-
stances to be included (Table 1).
Facilities that use any of these sub-
stances in quantities above an estab-
lished threshold will be required to
comply with the new accident pre-
vention regulations.
In developing its list of 100
substances, EPA has been assess-
ing the severity of acute adverse
health effects, the likelihood of an
accidental release, and the poten-
tial magnitude of human exposure.
The threshold quantities of the
substances are being established
by considering toxicity, reactivity,
volatility, flammability, explosivity,
and dispersibility, in addition to the
amount of the substance that is
known or anticipated to cause
serious adverse health effects. To
avoid redundancy and confusion,
EPA is also considering similar
existing lists that were developed
for accident prevention, mitigation,
and response. In addition, EPA has
been coordinating its efforts with
(continued on page 11)
Special Studies (continued from page 8)
National Academy of Sciences
Study
Section 112(o) of Title III
requires the National Academy of
Sciences (NAS) to review the
EPA's risk assessment method-
ology used to determine the
carcinogenic risk associated with
exposure to HAPs. In their review,
the NAS should consider techniques
used for estimating and describing
the carcinogenic potency of HAPs
to humans and the techniques used
for estimating exposure for the
hypothetical and actual maximally
exposed individuals as well as other
individuals. In addition, and "to the
extent practicable," the NAS may
evaluate the methodology for
assessing the risks of adverse
human health effects other than
cancer for which safe thresholds of
exposure may not exist (e.g., in-
heritable genetic mutations and
birth defects).
The NAS has held bimonthly
meetings since October 1991 and
has requested EPA to provide a
broad scope of information for
these meetings. For example, the
EPA provided information on how
the air toxics problem was defined,
how regulatory case studies were
conducted, and how the EPA did
quantitative risk assessments. The
NAS has also requested informa-
tion about the requirements of the
CAA, the status of existing risk
assessment information, and how
these elements affect EPA's risk
assessment process. More recently,
EPA provided information on emis-
sion, dispersion, and exposure
models, and the techniques used to
validate them. The NAS plans to
complete a draft of their report in
August 1992 and to submit the final
report in May 1993. The report will
be submitted to the Senate Com-
mittee on Environment and Public
Works, the House Committee on
Energy and Commerce, the Risk
Assessment and Management
Commission, and the EPA
Administrator.
Questions concerning this
study may be directed to Dennis
Pagano, (919) 541-0502.
*See related article in January 1992
Newsletter.
10

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Chemical Accident Prevention (continued from page 10)
Table 1.
Substances Required To Be Regulated
Ammonia8
Hydrogen fluoride
Anhydrous ammonia
Hydrogen sulfide
Anhydrous hydrogen chloride
Methyl chloride
Anhydrous sulfur dioxide
Methyl isocyanate
Bromine
Phosgene
Chlorine
Sulfur trioxide
Ethylene oxide
Toluene diisocyanate
Hydrogen cyanide
Vinyl chloride
a In addition to anhydrous ammonia.
OSHA, which has developed its
own list as a part of its respon-
sibilities under the CAA.
EPA will publish the proposed
list of substances after completion
of the OMB review process. Com-
ments from the public will be re-
quested at that time. The listing
regulation will describe a pro-
cedure to amend the list through
petitions to EPA. In addition, the
CAA requires EPA to review the
list at least every 5 years.
CAA Requires Risk Management
The general duty clause in the
CAA specifies that facilities that use
hazardous chemicals are responsible
for designing and maintaining a safe
plant, identifying hazards, and mini-
mizing the consequences of acciden-
tal chemical releases. Facilities using
substances to be regulated under
Section 112(r) in quantities above
threshold limits are required to
develop risk management plans.
The EPA must publish require
ments for risk management plans
as part of the CAA regulations and
issue guidance in November 1993.
Although details about the informa-
tion required in these plans will be
specified in the published rule, the
CAA describes the general require
ments. Facility risk management
plans must include a hazard assess-
ment, a prevention program, and
an emergency response program.
The guidance will address plan
development and include some
model plans. The EPA may also
develop other regulations to address
the prevention, detection, and mon-
itoring of accidental releases.
In the process of developing
these regulations, EPA has con-
ducted roundtables and focus groups
to solicit input from interested
groups. Among the risk manage
ment programs recommended by
industry representatives, trade
associations, and professional
societies and the existing programs
required by several State laws, a
number of common elements exist,
many of which OSHA has incorpo-
rated into its process safety standard
(see below). Recognizing that the
OSHA standard is in effect, EPA is
building on OSHA's work and
accommodating these recommen-
dations in preparing its regulations.
The EPA's regulations on risk
management will take effect 3 years
after the date of their publication or
3 years after the date on which a
regulated substance present at a
facility in more than threshold
amounts is first listed, whichever is
later. Proposed regulations are now
undergoing OMB review.
OSHA Issues the Process Safety
Standard
On February 24,1992, OSHA
issued a standard requiring chem-
ical process safety management in
the workplace. The standard is de
signed to prevent or minimize "the
consequences of catastrophic re
leases of toxic, reactive, flammable
or explosive chemicals" (57 FR
6403). The provisions of the stan-
dard apply not only to processes
involving chemicals at or above
threshold quantities of OSHA-listed
substances (does not include vinyl
chloride or toluene diisocyanate),
but also to many processes that
involve 10,000 pounds or more of
flammable substances.
Facilities must first collect pro-
cess safety information, then con-
duct process hazard analyses with
the help of employees. A reanalysis
and revalidation is required at least
very 5 years. Each process is to
have written operating procedures
that include safe practices for the
associated activities and that under-
go periodic review. Employers must
provide training on-the safe opera-
tion of each process and on emer-
gency procedures, and each person
is to attend a refresher every 3
years. Other requirements include
prestartup reviews, a formal main-
tenance program with written pre
cedures and specific employee train-
ing, and procedures to manage pro-
cess changes. If an event occurs
that results, or could have resulted,
in a catastrophic release, the facili-
ty must conduct a prompt incident
investigation. To plan for potential
releases, each facility is to prepare
an emergency action plan. Each
facility must conduct an audit at
least every 3 years to ensure that
compliance with the procedures
developed under the standard
continues.
The standard sets dates for
completing an increasing percen-
tage of the hazard analyses and all
must be done by May 26,1997. It
also contains compliance guidelines
and recommendations for process
safety management
For further information, con-
tact Craig Matthiessen, U.S. EPA,
Chemical and Emergency Prepared-
ness and Prevention Office (OS-120),
401 M Street, S.W., Washington,
D.C. 20460, (202) 260-9781, or Tom
Seymour, OSHA, Room N-3609, 200
Constitution Avenue, N.W., Wash-
ington, D.C. 20210, (202) 523-8061.
11

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The NATICH Newsletter 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-D1-0125, Work Assignment 1-6. The EPA Editor is Carol Jones, EPA Office of
Air Quality Planning and Standards, Research Triangle Park, North Carolina 27711, Telephone: (919) 541-5341. The Radian Project Director
is Linda Cooper, Radian Corporation, 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 Corporation, 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.
Carol Jones
Pollutant Assessment Branch
U.S. Environmental Protection Agency
MD-13
Research Triangle Park, NC 27711
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