NATIONAL AIR TOXICS INFORMATION
CLEARINGHOUSE NEWSLETTER
£ f"PA Office of Air Quality Planning and Standards	January 1989
Research Triangle Park, North Carolina 27711
State and Territorial Air Pollution Program Administrators
Association of Local Air Pollution Control Officials
IN THIS ISSUE
CLEARINGHOUSE TO UPDATE DATA COLLECTION SURVEY	1
CLEARINGHOUSE STAFF DUTIES HIGHLIGHTED	2
STATE/LOCAL AGENCY SPOTLIGHT AIR TOXICS MONITORING MOVES AHEAD IN
MASSACHUSETTS	2
EPA ENCOURAGES CO-CONTROL OF AIR TOXICS EMISSIONS	3
NESCAUM ADOPTS BACT GUIDELINE	6
POINT SOURCE TOXIC EMISSION INVENTORY COMPLETED	7
AIR RISC SERVES AIR TOXICS AGENCIES	9
NEW DATA BASE MANAGEMENT SYSTEM INTRODUCED	9
MARYLAND ADOPTS COMPREHENSIVE REGULATIONS FOR NEW AND EXISTING
SOURCES OF TOXIC AIR POLLUTANTS	10
OTS CONCLUDES TWO SARA TITLE III SECTION 313 QUALITY ASSURANCE
PILOT SURVEYS	12
EPA, STAPPA/ALAPCO CONTINUE URBAN AIR TOXICS WORKSHOP REGISTRATION	13
AMBIENT AIR TOXICS REPORT AVAILABLE	13
OAQPS PUBLISHES AIR TOXICS EMISSION FACTOR COMPILATION	14
OAOPS PUBLISHES URBAN AIR TOXICS REPORT	14
FINAL HOSPITAL WASTE COMBUSTION STUDY REPORT RELEASED	14
CLEARINGHOUSE TO UPDATE
DATA COLLECTION SURVEY
Data Collection Survey Format Modified
On February 17, the 1989 version of the NATICH
data collection survey will be mailed. A new format will
be featured for the entry of agency profile information.
Unlike previous years' questionnaires which asked for
a yes or no response on the agency profile segment, the
new version will include options to characterize the "cur-
rent" program, any planned "future" program, as well
as a choice for "no" program. It is anticipated that the
new format will be incorporated into the data base
superseding the existing information. This revision to the
profile is designed to provide a more complete picture
of a given agency's program. The data base will be
modified to accept the new survey information and agen-
cy representatives should be aware that older agency
profiles may be lost if they are not updated to the new
format. Thus it will be important for each agency to prq
vide input on the 1989 survey. Data should be submit-
ted within two months of receipt of the survey. Although
the Clearinghouse will accept data at any time, July 1,
1989, is the final date to receive data that will be incor-
porated into the annual Clearinghouse data base report.
Data Base Development Continues
As reported in the previous issue of the Newsletter,
a feasibility study is currently in progress to assess the
possibility of linking the SARA Title III Toxic Release In-
ventory System to the NATICH data base. Should the link
appear reasonable, current plans are to complete the
project during the second half of this year.
Several additional development projects are being
initiated this year. An index of Newsletter articles and
subjects will be incorporated into the Bibliography and
Ongoing Research Files section of the data base. Also,

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data retrieval based on a pollutant name or CAS number
across all NATICH files in combination with an offline
batch or print option will be made available during the
coming months. Additionally, in response to comments
received on the procedure used to access information
on permit and source test data, the current access code
method of retrieval will be modified. The existing option
allows NATICH users to input an access code to view a
permit or source test on the initial complex search
criteria screen. It is anticipated that the user will no
longer be required to write down the access code but in-
stead will be able to highlight the desired option on the
screen. The code option will, however, be retained to
allow NATICH users to continue to use the access codes
printed in Volume II of the NATICH Data Base Report on
State, Local and EPA Air Toxics Activities (July 1987).
Data Base Maintenance Continues
EPA continues to perform tasks associated with
maintaining the data base. These tasks include debug-
ging the programs, adding features to ease data entry,
and correcting deletion and repair problems with the
data.
Contact Given for Changes to Newsletter
Mailing List
Newsletter readers wishing to report mailing ad-
dress changes may do so by writing Meredith Haley,
Radian Corporation, P.O. Box 13000, Research Triangle
Park, North Carolina 27709.
Diskette Sample of NATICH Available
Requests continue for copies of the diskette pro-
gram illustrating some of the types of data and retrieval
options in the NATICH data base. As announced in the
July 1988 Newsletter, this program allows a potential
user to understand the NATICH data base through a per-
sonal computer run sample of NATICH capabilities. To
obtain a copy of this program, please send one unfor-
matted double-sided, double-density, 5.25-inch floppy
diskette to Nancy Riley, U.S. EPA, MD-13, Research
Triangle Park, North Carolina 27711.
CLEARINGHOUSE STAFF D
Clearinghouse staff are available to talk with
Newsletter readers or NATICH data base users and to
answer their questions.
Tim Mohin handles the NATICH data base, in-
cluding its maintenance, development and data collec-
tion. Data base users should call him with general ques-
tions regarding the Clearinghouse as well as questions
on accessing and using the data base. He should also
receive data submitted in response to the 1989 survey.
UTIES HIGHLIGHTED
The person in charge of the Newsletter is Scott
Voorhees. Call him with article and feature ideas.
Call Nancy Riley for Clearinghouse documents and
special reports.
Any member of the Clearinghouse team can re-
spond to questions regarding Clearinghouse programs
and functions. Staff may be reached at (919) 541-0850
or (FTS) 629-0850. The mailing address is: EPA Office
of Air Quality Planning and Standards, MD-13, Research
Triangle Park, North Carolina 27711.
STATE/LOCAL AGENCY SPC
MONITORING MOVES AHE
by Sarah J. Simon, Deputy Director for Technical
Massachusetts Department of Environmental Qu
The Division of Air Quality Control (DAQC) of the
Massachusetts Department of Environmental Quality
Engineering (DEQE) is investing in monitoring resources
to assist in developing its air toxics program and to pro-
tect public health and welfare. Three distinct monitoring
areas are being investigated by DAQC:
1. Efforts to measure short-term plume emissions
during accidents and other emergencies. These
do not require as high a level of data quality
and information certainty as the traditional air
programs.
>TLIGHTi AIR TOXICS
IAD IN MASSACHUSETTS
Support, Division of Air Quality Control,
ality Engineering
2.	Special studies to perform source investiga-
tions, especially near hazardous waste sites
and industrial areas. New, sophisticated, low-
level detectors, sampling techniques and
analysis methods make it possible to determine
trace air toxics levels.
3.	Routine monitoring at a network of sites to
measure low ambient concentrations of specific
contaminants with toxic effects. These will aid in
developing realistic programs to control toxic air
pollution and address the public's health
questions.
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Mobile Monitoring Available
The DAQC has begun to use some of the new,
highly sensitive, field-based monitoring technologies.
Two special studies were conducted in 1985 and 1986
using a mobile Trace Atmospheric Gas Analyzer
(TAGA"', Sciex, Inc.) unit, a mass spectrophotometer that
can continuously measure specific air contaminant con-
centrations. This is the first truly mobile analytic instru-
ment with real-time monitoring capabilities. An emergen-
cy mobile van converted from a recreational vehicle by
DAQC's Surveillance Branch has also found use in
screening work during emergency response activities.
Results of the special studies using the mobile
TAGA" told the Massachusetts public more precisely
what the air toxics were at various areas of concern, such
as dump sites and industrial sources. These studies,
however, were largely inconclusive. At a Superfund site
in Billerica and a landfill in Worcester, the TAGA" found
that the level of many air toxics near the sites was
equivalent to levels off site. Some contaminants iden-
tified by TAGA" could not be found again later with sta-
tionary sampling and analysis methods of equivalent
sensitivity.
In 1987 and 1988, the Massachusetts Legislature
appropriated nearly .5 million dollars to build a new
mobile air monitoring laboratory to support both
emergency response and special studies. In designing
and outfitting the lab, DAQC has drawn on the ex-
perience gained from previous monitoring projects. The
basic design enables effective emergency response
work as well as special studies monitoring. Examples of
special features of the mobile unit include:
Emergency Response
For the vehicle:
-	minimal size and height
-	heavy duty mechanicals
-	communications capability
For field use:
-	hand-held screening
analyzers
-	personal protection
equipment
Special Studies
-	controlled environment for the
analyzers
¦	special electrical system
-	analyzer shielding from stray
signals
¦	gas sample collectors/
GC columns
¦	particle samplers and support
Emergency Response (cont)
Equipment for the van:
- safety support features
(external shower, external
gas cylinder storage)
Special Studies (contj
-	GC Photo Ionization Detector
-	Phase Contrast Microscope
Division staff are able to bring the new mobile air
monitoring lab to sites easily, where it can serve as a field
air monitoring operations center and support emergency
and longer term surveys. Along with the mobile lab, the
Division has purchased a new gas chromatography/
mass spectrometry system located in Massachusetts'
environmental laboratory, the Lawrence Experiment Sta-
tion. This will provide more sensitive concentration quan-
tification and positive organics identification in support
of the special air monitoring studies.
Special Studies Address Methodology and
Emission Mechanisms
The Special Studies efforts are addressing four
areas of concern in toxics monitoring. First, the develop-
ment of monitoring methods is critically important, in part
to lower detection limits into the range of concentrations
that match developing health guidelines, such as DE-
QE's Allowable Ambient Limits. Second, through atten-
tion to quality control, quality assurance, and time
averaging, air toxics monitoring data are forming the
basis of a consistent air quality data base that can be in-
terpreted for representativeness and trends. Third, new
field monitoring techniques are helping the Division to
understand emission sources and mechanisms for tox-
ic pollutant releases, such as soil gas emissions and
acute incidents, which can now be monitored more easi-
ly in the field. Finally, resources and staff expertise are
being developed and are available for program use when
questions arise.
Because air toxics trends and the extent of human
exposures are not well known, air toxics monitoring is
an integral part of understanding and resolving air tox-
ics problems. Better air monitoring and analysis tech-
niques will help assure a clean, safe environment.
For more information on air toxics monitoring in
Massachusetts, call Sarah Simon, Division of Air Quality
Control at (617) 292-5630 or Donald Steele, Chief of the
Air Quality Surveillance Branch at (508) 851-4784.
EPA ENCOURAGES CO-CONTROL
OF AIR TOXICS EMISSIONS*
Co-control is the control of criteria pollutant emis-
sions that achieves air quality goals for both air toxics
and criteria pollutants. As a tool for State and local air
toxics agencies, co-control offers potential benefits in
terms of meeting multiple environmental goals, poten-
tially lowering overall emission control costs, and en-
hancing regulatory effectiveness and administrative effi-
ciency. Using existing legal authorities and regulatory
mechanisms in this fashion is an integral part of the U.S.
Environmental Protection Agency's (EPA's) National Air
Toxics Strategy (see previous Newsletter articles in
August and December 1985, September and November
1987). Under the Strategy announced in 1985, EPA's Ad-
ministrator stressed the importance of using all available
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legal authorities to address the air toxics problem. One
of the principal existing authorities envisioned for use
under the Strategy, in addition to Section 112 of the Clean
Air Act (Act), is EPA's State Implementation Plan (SIP)
approval authority contained in Section 110.
Although the primary goal of SIPs must necessari-
ly be attaining and maintaining national ambient air
quality standards (NAAQS) for criteria air pollutants, an
important secondary goal can be enhancing the control
of toxic air pollutants through SIP control measures.
Reductions in criteria pollutants through SIP activities,
in addition to Federal regulatory efforts focused on
criteria pollutant control, have been shown to produce
substantial reductions in specific air toxics which exist
predominantly as a form of either particulate matter (PM)
or volatile organic compounds (VOC).
Significant cost saving opportunities appear possi-
ble for State and local agencies by promoting better
coordination in the development of SIPs and the air tox-
ics control programs that many State and local agencies
are now developing given that many of the same point
and area sources are likely to be affected under both
types of programs. Consequently, EPA encourages the
development of SIPs which incorporate measures that
also achieve air toxics benefits. While EPA does not
mandate these co-control efforts, the Agency is foster-
ing consideration of them within the Clean Air Act Sec-
tion 105 grant dollars available to support the develop-
ment of SIPs and State and local air toxics programs.
The air toxics problem overlaps with PM and VOC
problems in two ways. First, many nonattainment areas
with respect to particulate matter nominally 10
micrometers or less (PM10) and virtually all ozone nonat-
tainment areas to be addressed in upcoming SIP revi-
sions involve large urban areas that are believed to have
air toxics problems. In addition, the vast majority of tox-
ic substances belong to the general categories of PM
and VOCs.
Table 1 illustrates a few of the type of sources that
emit VOCs and PM and that have been associated with
high maximum individual cancer risks at the fenceline.
Table 1 is based on EPA's screening experience within
the national emissions standards for hazardous air
pollutants (NESHAP) development process. The screen-
ing program includes 1,880 point sources. Of these, 40
percent were found, with varying degrees of certainty,
to cause a hot spot in the vicinity of the plant (i.e., at least
1 in 10,000 lifetime cancer risk to the maximum exposed
individual at the fenceline). Systematic and comprehen-
sive evaluation of other point sources, including
thousands of sources of VOC and PM, is expected to
reveal many more high risk point sources (HRPS).
The major contributors to annual cancer incidence
tend to be small point and area sources and road
vehicles, the latter source category figuring importantly
in urban areas. Particulate pollutants that appear to con-
tribute substantially to aggregate annual incidence
include hexavalent chromium (Cm6), polycyclic organic
matter (POM), arsenic and asbestos. The VOCs that con-
tribute significantly to annual incidence include for-
maldehyde, 1,3-butadiene and benzene. In summary, it
appears from these studies that the pollutants respon-
sible for estimates of most of the annual cancer in-
cidence associated with air toxics consist of a mixture
of trace metals, VOCs, and POM.
TABLE 1.
VOC AND PM SOURCE CATEGORIES ASSOCIATED WITH
MAXIMUM INDIVIDUAL RISKS GREATER THAN 10-*
Source Category
Chlorine production
Ethylene oxide production
Vinyhdene monomer produclion
Styrene-butadiene rosin
Glass manufacturing
Cooling towers
Ferrochromium production
Pollutant
Carbon tetrachloride
Ethylene oxide
Vinyhdene chloride
Butadiene and styrene
Arsenic
Chromium
Chromium
National Control Programs for
PM and VOC Have Co-Control Benefits
Studies have shown that existing national PM and
VOC control programs have already been effective in
reducing toxics emissions. These existing programs in-
clude the Federal motor vehicle control program
(FMVCP), SIPs that include new source review (NSR)
and presumptive requirements to meet nationally de-
fined reasonably available control technology (RACT),
and the application of control by new or modified sources
to meet applicable and source performance standards
(NSPS). In addition, some toxic compounds are being
controlled by sources for economic reasons or to meet
occupational work place standards unrelated to air pollu-
tion control programs.
Upcoming PM^ and ozone SIP actions described
in the next section are believed to afford State and local
air pollution control agencies additional opportunities to
control air toxics.
Current SIP Opportunities Outlined
Major SIP changes are under development in
response to a revision in the PM NAAQS and the pass-
ing of the attainment date for the ozone NAAQS. Addi-
tional controls designed to reduce criteria pollutants can
be justified, in part, by their simultaneous payoff to air
toxics. Moreover, these SIP control efforts, properly
designed, can do much more to reduce the air toxics
concerns associated with increased cancer incidence
and risks to the maximum exposed individual.
In 1987, as part of the Act's requirement that EPA
periodically review and, if appropriate, revise the
NAAQS, EPA revised the primary and secondary
NAAQS for total suspended particulates (TSP) to apply to
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PM10. In the case of PM10, agencies were to submit a
plan by August 1988. All areas within a State are
classified as either Group I, II, or III, based on the prob-
ability of attainment of the new PM10 standards.
In May 1988, EPA issued "SIP calls" for 66 areas
that failed to meet the December 31, 1987, Act deadline
for attainment of the ozone NAAQS. Revised ozone SIPs
will be developed in two phases. The first phase will
focus on upgrading emission inventories and correcting
loopholes and deficiencies in existing SIPs. The second
phase, and its timing, will be contingent on EPA's final
post-1987 Policy (or Clean Air Act amendments).
Regardless of the ultimate schedule for revising existing
ozone SIPs, it is clear that many State and local agen-
cies will need to consider additional VOC control
measures in coming months.
Both the ozone and PM10 SIP actions offer several
opportunities for enhancing State and local air toxics
programs. First, State and local agencies are encour-
aged to develop an air toxics component for their ozone
and PM10 SIPs. In this way, integration of air toxics and
SIP goals can be explicitly addressed within the context
of the SIPs themselves. One anticipated benefit of this
integrated approach will be the enhanced acceptability
of SIP control measures that can be credited with both
criteria pollutant and air toxics reductions. In addition,
SIP control measures which may be somewhat marginal
from a purely VOC perspective may be regarded more
highly if they are demonstrated as having significant
health risk reduction benefits.
State and local agencies can also use the data col-
lection activities of SIP development and data submit-
ted under the requirements of the Superfund Amend-
ments Reauthorization Act (SARA) as opportunities for
discovering useful air toxics information which can be
used to enhance the control of air toxics. Finally, the NSR
activities of SIPs [including the prevention of significant
deterioration (PSD) and nonattainment NSR permit re-
quirements] should incorporate the consideration of air
toxics. In fact, much of co-control consideration here is
mandatory. A recent remand by EPA's Administrator of
a best available control technology (BACT) determina-
tion for a PSD application sets a precedent and require-
ment for the consideration of unregulated noncriteria
pollutants as well as pollutants explicitly regulated under
the Act in settling BACT (see related article in this issue).
Potential Co-Control Measures Discussed
Control strategies that offer significant air toxics
benefits and, at the same time, satisfy PM10 or ozone
plans should be given higher priority than those that do
not enhance air toxics control. Also, there may be
measures that are marginal from an ozone or PM-io
perspective, but which can be on the basis of the payoff
of additional toxics control.
One example of a PM control measure that also
reduces air toxics is the use of an electrostatic
precipitator at a cement manufacturing facility. Not on-
ly are overall PM emissions reduced, but also emissions
from the associated toxic metals such as beryllium, cad-
mium, chromium, lead, mercury, and nickel. It is impor-
tant to note that the ranges of achievable emissions
reduction generally associated with the PM and VOC
control strategies do not necessarily provide the same
level of air toxics reduction. If additional control options
are to be considered, it is key that the physical and
chemical properties of the toxics species, and how these
properties affect the degree of control afforded by con-
ventional emissions devices, be understood so that co-
control can be optimized.
Permits or SIPs may also be optimized for co-control
of air toxics by incorporating any additional control re-
quirements into revised SIPs or permit conditions, by
specifying PM or VOC emission rates that would act as
a surrogate means to impose a needed control, or by set-
ting directly a toxics-specific limitation (given adequate
State and local authority to do so).
Increased SIP Enforcement Provides
Air Toxics Benefits
Unrelated to the opportunities afforded by SIP revi-
sions is the indirect control of air toxics through inten-
sified enforcement activities of existing SIP re-
quirements. Aggressive audit and enforcement of VOC
and PM sources which also emit toxic pollutants can be
a cost-effective means of minimizing emissions of air tox-
ics from new and existing sources. An intensified en-
forcement effort aimed at sources of air toxics could in-
clude: (1) compliance audits of selected high priority
sources (e.g., those emitting significant amounts of high
priority pollutants, sources with a history of poor com-
pliance; etc.), (2) increased number of enforcement
source inspections, (3) stepped-up enforcement actions
against noncomplying sources which emit air toxics (4)
evaluation of facilities most likely to experience process
upsets or control equipment malfunctions, (5) strength-
ened source monitoring requirements, (6) enhanced use
of opacity monitoring as an enforcement tool, and (7) ex-
panded coverage of ambiguous VOC regulations to
sources not previously judged to be covered by those
regulations.
Co-Control Feasible Outside
Normal SIP Requirements
Consideration could also be given to identifying and
adopting control measures for sources or pollutants not
covered under SIPs. Numerous small sources which are
potential emitters of toxics are often exempt from State
and local permit requirements (e.g., degreasers or
miscellaneous metal or plastic coating operations). Also,
sources not currently required to apply RACT could be
controlled to RACT levels if they are sources of air tox-
ics (such as spray painting bridges with chromate
paints). Third, consideration should be given to the con-
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trol of VOCs which could be exempt, under current
regulations, because of negligible reactivity (such as
small furniture refinishing businesses using methylene
chloride as a paint stripper). Finally, some sources
and/or source-related operations are exempted within
SIPs (such as peaking power units and malfunctions),
and these exemptions should be reexamined in light of
their toxics implications. Control of each of these sources
may not have been justifiable previously on the basis of
criteria pollutants control, but may be worthy of consi-
deration under a co-control program to address air
toxics.
In summary, the impact of existing Federal pro-
grams that result in concurrent air toxics reduction
clearly demonstrates the benefits of co-control air tox-
ics management. EPA therefore promotes the adoption
of a pro-active philosophy of co-control through a
number of policies. This is exemplified by EPA's en-
couraging State and local agencies to take credit for the
reduction of air toxics in justifying PM and VOC controls
proposed under SIP development EPA also views the
SIPs as opportunities providing valuable insight on im-
proving future co-control implementation techniques.
*The information in this article was drawn from a paper,
"Co-Control of Air Toxics," prepared by Michael Trutna
and Martha Keating (EPA/OAQPS/NPPB).
NESCAUM ADOPTS BACT G
In October 1988, the Board of Directors of the North-
east States for Coordinated Air Use Management
(NESCAUM) adopted a best available control technology
(BACT) guideline. The new BACT guideline is intended
to promote consistency among NESCAUM's eight
member States in determining BACT and in helping per-
mit applicants select the appropriate level of analysis to
support a proposed control technology. The new policy
does not change regulations in any State or any existing
requirements for a BACT analysis.
NESCAUM States will use a top-down BACT
analysis, defining this as "beginning a BACT determina-
tion by identifying the most stringent control available for
a similar or identical source or source category. The
BACT analysis begins with that "top" case, and makes
allowances for environmental, energy, and economic
considerations. NESCAUM's guideline makes it the per-
mit applicant's responsibility to identify the most
stringent control possible and then to present and de-
fend the selected control approach.
NESCAUM Strives for Consistent Approach
The NESCAUM Directors felt that the level of
analysis or documentation to support a BACT determina-
tion should be consistent from area to area. However,
since the BACT analysis is a case-by-case process, the
guideline notes that consistency does not necessarily
mean that a new facility in one area will have an emis-
sion limit identical to that of the same type of facility in
another area. Using a consistent approach to determine
BACT should ensure that the impacts of alternative emis-
sion control systems are measured by the same set of
parameters.
Top-Down Approach Starts with LAER
In carrying out a top-down BACT analysis the appli-
cant must first identify the most stringent control possi-
ble and then quantify emissions. This level of control is
usually referred to as the lowest achievable emission
iUIDELINE
rate (LAER). The starting assumption for the top-down
approach is that the most stringent control possible is
BACT. The burden of proof for applying a less stringent
control rests in the applicant's case-specific evaluation
of the control alternatives.
When identifying the top case and alternative con-
trol technologies, the NESCAUM guideline states that
the following types of controls should be considered:
1.	existing control technology that has been pro-
ven in practice for the source category;
2.	technically feasible alternatives that have been
demonstrated on other source categories;
3.	innovative control technology that has never
been applied to any source on a full scale, con-
tinuously operating basis;
4.	use of production processes, fuels, and
coatings that are inherently lower polluting; and
5.	specific design or operational parameters.
NESCAUM also listed the following sources of in-
formation that must be consulted by the applicant
preparing a BACT analysis:
1.	the EPA's BACT/LAER Clearinghouse;
2.	EPA, State, and local air quality permits issued
for the particular industry;
3.	Federal, State, and local permitting engineers
concerning projects under review;
4.	control equipment vendors;
5.	trade associations,
6.	agencies or companies outside the United
States;
7.	inspection and performance test reports; and
8.	technical papers and journals.
Control Alternatives Evaluated
A list of control alternatives prepared by an appli-
cant should show respective control efficiencies, ex-
pected emissions, economic costs, environmental
benefits, energy costs, and other costs.
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The effectiveness of control alternatives is the
decisive factor affecting BACT selection, although en-
vironmental, energy, and economic impacts are impor-
tant parts of the selection process. Examining these im-
pacts more closely is also necessary when the permit
applicant proposes using a control technology that is not
the most effective on the list of alternatives. The burden
of proof, however, is on the permit applicant to justify why
a source cannot meet the best technology available.
Environmental impacts of each control alternative
to consider include air quality, water quality, solid waste
disposal, noise, steam plumes from cooling towers, the
potential for accidental release, and reliability. An in-
significant air quality impact cannot provide a basis for
accepting a less stringent control technology. Air quality
extends to potential air pollutants that are not currently
regulated under the Clean Air Act, but that may have a
significant environmental impact. The focus of the
analysis should be to develop an inventory and evaluate
the impact on those pollutants of each control alternative.
In analyzing energy impacts, the applicant should
estimate energy consumption and identify the type and
amount of scarce fuels in the region that would be re-
quired. In evaluating the economic impacts of various
BACT control options, primary consideration should be
given to the cost effectiveness of an option and not to
the economic situation of the source applicant. The
NESCAUM guideline gives details on how the economic
analysis should be completed.
For a copy of the NESCAUM BACT guideline, call
the NESCAUM office at (617) 367-8540.
POINT SOURCE TOXIC EMI
INVENTORY COMPLETED
by Andy Lindstrom, Air Pollution Control Analy
The Regional Air Pollution Control Agency (RAPCA)
of Dayton, Ohio, has completed a major point source tox-
ic emission inventory. Based on the Ohio EPA's 1986 list
of 39 toxic chemicals* this inventory was conducted on
all facilities within the six-county RAPCA jurisdiction that
emitted more than five tons of volatile organic compound
(VOC) emissions in 1985. The RAPCA personnel used
these data to conduct modeling and risk assessment ex-
ercises for some of these sources. The agency's objec-
tives in carrying out this inventory were first to identify
those industrial point sources with which significant risk
levels might be associated (that is, those that emit high
levels of toxic compounds) and then to mitigate any
sources that RAPCA determined would present unac-
ceptable health risks to the community.
Background Described
The U.S. EPA's "Six Month Study," which included
a national risk assessment for approximately 45 com-
pounds emitted from point and area sources, concludes
that toxic air pollution in the U.S. may be responsible for
between 1,300-1,700 cancer cases per year. The study
also concludes that an additive lifetime risk from 1 x 10-3
to 1 x 10*4 is not uncommon in urban areas of this coun-
try. Risks of this magnitude were shown to be associated
with both point and area source emissions.
While both point and area sources are of concern
in the Dayton area, this project's primary objective was
to quantify toxic compounds emitted by large industrial
point sources. This subset of all toxic emissions was
chosen because the methods for inventory are well
established and the emissions calculations could be per-
formed fairly quickly. The RAPCA also believed that this
SSION
st. Regional Air Pollution Control Agency
type of inventory would be the best way to identify any
major point sources of toxic emissions that might be of
immediate concern in the Dayton area.
In contacting the selected facilities, RAPCA asked
each to supply material safety data sheets (MSDS) and
usage rates for all the materials they used, made, or pro-
cessed in 1986. The RAPCA personnel then calculated
the emissions for most of these facilities using standard
mass balance procedures. In some cases facilities were
allowed to estimate their own emissions. These
estimates were accepted only after RAPCA reviewed the
calculation methods used by the facilities.
Once the emissions calculations for a facility were
completed, the information was entered into a dBase
data base. The RAPCA has also custom developed ac-
companying software to access information contained
in the toxic emission inventory. (See the June 1987 issue
of the Newsletter.) The data base is thorough, expand-
able, and IBM compatible, and is available upon request.
Results Outlined
Fifty-three facilities within the RAPCA jurisdiction
were found to emit compounds on the 1986 Ohio EPA
toxics list. At least 12 of the 39 compounds on the toxics
list were determined to be emitted in significant quan-
tities (^0.01 ton/year).
It is interesting to note that only a few compounds
account for the bulk of the emissions. Xylene and
toluene accounted for over 70 percent (by weight) of all
the toxics emitted in 1986 (see Table 2). Chloroform from
one facility and methylene chloride from 14 facilities ac-
counted for 12.5 percent and 11.8 percent, respectively,
of the remaining emissions.
7

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Most of the emissions calculated in this inventory
emanated from a small number of major facilities in the
Miami Valley. Approximately 84 percent of all emissions
(by weight) came from eight facilities.
Modeling for the major sources of these emissions
was difficult to conduct because stack parameter data
were frequently not available. Modeling for only one of
the major emission sources of chloroform was per-
formed because of the potential risk associated with the
chemical emitted and the availability of stack data. This
source emitted 218 tons of chloroform in 1985. The Point
Plume (PTPLU) model estimated a peak ambient
chloroform concentration that had a maximum cancer
risk of 3.56 x 10E-2. While this risk seems very high, it
should be noted that PTPLU generates the highest one-
hour potential concentration to be found around a par-
ticular site. More sophisticated models such as the In-
dustrial Source Complex (ISC) and EPA's Human Ex-
posure Model (HEM) have been used to assess this
hazard and have found that the actual risk associated
with this source was closer to 4.4 x 10E-4. Other major
sources were not modeled because the emissions are
fugitive emissions with no identifiable stack; thus, the
PTPLU could not be used. One example is a truck
assembly plant that used a total of 271 tons of xylene dur-
ing its 1985 production year. The vast majority (205 tons)
of this compound was used for miscellaneous cleanup
throughout the plant, so no one particular stack or even
period of time can be isolated for modeling. Most of the
remaining xylene (66 tons) was used as a paint solvent
on 10 paint lines located throughout the plant.
TABLE 1.
TOXIC COMPOUNDS INCLUDED
IN THE RAPCA INVENTORY
Acetaldehyde
Acetonitrile
"Acrylonitrile
Ammonia
"Arsenic and compounds
"Benzene
Benzo(a)pyrene
"Beryllium and compounds
Bromine
*1,3-Butadiene
"Cadmium and compounds
Carbon disulfide
"Carbon tetrachloride
Chlorine
Chlorabenzene
"Chloroform
"Chromium, hexavalent
compounds
Cyanide and compounds
"Dioxin
Ethylbenzene		
"These chemicals also appear on Ohio's new list of toxic compounds.
Ethylene
Ethylene dibromide
"Ethylene dichloride
"Ethylene oxide
Fluorine
"Formaldehyde
Hydrogen cyanide
Maleic anhydride
Methyl chloride
Methyl methacrylate
"Methylene chloride
Perchloroethylene
"Phosgene
"Styrene
Titanium tetrachloride
Toluene
"2,4-Toluene diisocyanate
"Vinyl chloride
Xylene
TABLE 2.
SUMMARY OF POINT SOURCE
TOXIC EMISSIONS FOR 1986
Compound
Number of
Facilities
TYP
Emitted
Percentage
of Total
Xylene
34
818.0
46.7
Toluene
32
410.5
23.5
Chloroform
1
218.8
12.5
Methylene chloride
14
207.2
11.8
Tetrachloroethylene
7
76.1
4.3
Styrene
5
15.2
09
Formaldehyde
7
2.8
0.2
Methyl methacrylate
1
0.7
<0.1
1,3-toluene diisocyanate
1
0.2
<0.1
Benzene
3
0.2
<01
Ethylbenzene
3
0.1
<0.1
Ammonia
1
0.1
<0.1
TOTAL

1749.9

A second assembly plant included in the inventory
emitted approximately 105 tons of methylene chloride,
used as a miscellaneous cleanup solvent. The
methylene chloride was lost during general use
throughout the entire plant and was considered to be
another source of fugitive emissions, despite the plant
recycling program.
RAPCA Concludes Point Sources
Not a High Contributor
The RAPCA concludes from this inventory that a
few major point sources contribute most of the toxic VOC
emissions in its jurisdiction. Because of this, these
facilities warrant further investigation. The highest priori-
ty may be the high methylene chloride emitter men-
tioned above.
For further information on the RAPCA inventory or
to request copies of the inventory software, call Andy
Lindstrom, RAPCA, at (513) 225-4898.
'These compounds are listed in Table 1. Of these 39,18
are included in the prioritized air toxics substances list
for Ohio announced shortly after RAPCA's inventory was
completed. The list was developed independent of the
inventory. Compilers of the list looked at Ohio's specific
types of industry (SIC codes) and their relative sizes,
then estimated the potential emission rates. Using these
projected emission rates and the health effects data, they
determined the probable risk associated with each com-
pound. Shortly after this inventory was completed, the
Ohio EPA announced the State's new list of 29 toxic
compounds.
8

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AIR RISC SERVES AIR TOXI
As more people learn about the Air Risk Informa-
tion Support Center (Air RISC), calls to the hotline in-
crease* Designed to assist State and local air pollution
control agencies and U.S. Environmental Protection
Agency Regional Offices, Air RISC advises callers on
technical matters pertaining to health, exposure, and risk
assessment for toxic air pollutants. Hotline calls include
requests for information on the potential effects of
specific chemicals or industrial process emissions,
assistance in accessing EPA health data bases, and
technical review of assessment documentation.
Two recent calls illustrate Air RISC services. The
first came from North Carolina's Division of Environmen-
tal Management (NCDEM), Air Quality Section. The
NCDEM suspected an unknown substance had been
dumped in a remote canal in a coastal wildlife refuge.
An initial investigation by NCDEM revealed a strong
smell of hydrogen sulfide at the roadside; the smell
seemed to disappear at water level. No other odor was
distinguishable. NCDEM requested toxicity information
on hydrogen sulfide from Air RISC.
Air RISC staff discussed the availability of safety
and health information on hydrogen sulfide. They
responded by sending the caller EPA's recent Health
Assessment Document on Hydrogen Sulfide. Further,
they cautioned that hydrogen sulfide at concentrations
above 150 ppm anesthetizes the sense of smell, thereby
giving no warning of its presence, even at lethal concen-
trations. Staff also pointed out that care should be taken
with any activities at the site since stirring the sediments
could release greater concentrations of the gas.
A second call presented Air RISC with a more com-
plex situation. Region III had been receiving numerous
public complaints about a steel mill in western Penn-
sylvania. This mill had increased production and had ex-
perienced five upsets in its coking operation with the
subsequent discharge of coke oven by-product gas.
Citizens complained of the odors and described health
effects symptoms, such as coughing and asthmatic
CS AGENCIES
response, that they thought were related to the mill's
emissions. Others also questioned the carcinogenic
potential of these emissions. The Regional Office initially
requested a list of the chemicals that might be emitted
from such a plant. They also asked for information on any
associated chronic health effects for the possible con-
centrations of these pollutants found at the coking facili-
ty. Further, Region III sought assistance from Air RISC
in preparing a response to health concerns about the mill
voiced by a citizens' group.
To respond, Air RISC staff familiarized themselves
with the case through contacts with the Region. Using
information from the Region III air toxics coordinator and
in-house expertise on coke oven emissions and related
health effects, Air RISC staff developed lists of chemicals
that might be released and their possible emission
levels.
Once data collection was complete, calculations
were performed to determine the maximum individual
cancer risks of exposure to the mixture of coke oven by-
products, with benzo(a)pyrene as one component. [Ben-
zo(a)pyrene had been specifically mentioned by the
citizens' group as an area of concern.] Combining their
findings, Air RISC staff prepared documentation to be
used by the Department of Justice. The primary conclu-
sion was that risk associated with the steel mill coke oven
emissions was due to the mixture of coke oven by-
products, not to any single component.
To further serve the needs of State, local, and
regional air pollution professionals, the Air RISC is plan-
ning a series of national workshops on risk assessment
and communication. Further details will be available in
the next Newsletter. For further information on the two
calls to Air RISC, contact Melissa McCullough at (919)
541-5646 or (FTS) 629-5646.
*See related article in the November 1988 issue of the
Newsletter. The Air RISC hotline is (919) 541-0888.
NEW DATA BASE MANAGE
SYSTEM INTRODUCED
EPA's Storage and Retrieval of Aerometric Data
(SAROAD) has been replaced, with National Emissions
Data System (NEDS) and Compliance Data System
(CDS) soon to follow. The new acronym is AIRS, or
Aerometric Information Retrieval System. AIRS is
described as a top-of-the-line data base management
system providing for the storage and retrieval of air
monitoring, emissions, and air compliance data.
Two AIRS features present advantages over the
previously used systems. First, AIRS can be updated
MEIMT
weekly, whereas SAROAD was updated monthly. With
SAROAD's long turnaround time data were not available
to State and local agencies in timely fashion. Second,
AIRS is an interactive system. State and local agencies
can input data and then retrieve information later. It takes
at most four days for the AIRS staff to update the AIRS
data base.
What the AIRS System Contains
AIRS consists of three subsystems: (1) Air Quality
9

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Subsystem (AQS), (2) AIRS Facility Subsystem (AFS),
and (3) Geographic and Common Subsystem
(GEOCOM). The AQS and GEOCOM subsystems
became operational on EPA's IBM 3090 in July 1987.
AQS is currently accessed by 30 States, with an ad-
ditional 15 States to be trained in this fiscal year. This
subsystem contains air quality data dating from 1957.
AFS is currently under development with a sched-
uled implementation date of August 1989. It will contain
all of the facilities information such as plant information,
emissions estimates, compliance information, and much
more.
The GEOCOM data base contains all the
geographic codes (that is, State codes, county codes,
etc.) and the common codes, used by both AQS and
AFS, such as parameter codes, description codes, and
others.
Who Uses the System and Why
Besides State and local agency users who can ac-
cess the data base directly, industry can also access
AIRS for doing research or conducting trends analysis
by contacting regional offices. Information on AQS may
be obtained directly from AQS contacts given below.
Since AFS is not yet operational, the emissions, com-
pliance, and related data are available through regional
contacts for NEDS and CDS also listed. The system's
data are available to the private sector through the
Freedom of Information Act.
For further information on AIRS, call Gary Wilder at
541-5447 or (FTS) 629-5447.
CONTACTS
Region
AQS
IV
VI
VII
VIII
IX
Wendy Armington
(FTS) 860-4384
(617) 860 4384
Ed Fmfer
(FTS) 264-2517
(212) 264-2517
Mike Giuranna
(FTS) 597-8336
(215) 597-8336
Damita David
(FTS) 257-2864
(404) 347-2864
Larry Lehrman
(FTS) 886-6231
(312) 886-6231
Ruth Tatom
(FTS) 255-2289
(214) 655-2289
Jeff Wandtke
(FTS) 757-3884
(913) 236-3884
Marlin Helming
(FTS) 776-5103
(303) 236-5103
Jim Forrest
(FTS) 454-8222
(415) 974-8222
Bill Puckett
(FTS) 399-1702
(206) 442-1702
NEDS
Bob Judge
(FTS) 835-3248
(617) 565 3248
Matthew McCarthy
(FTS) 264-2517
(212) 264-2517
Ted Erdman
(FTS) 597-3977
(215) 597-3977
Al Yeast
(FTS) 257-2864
(404) 347-2864
Barry Bolka
(FTS) 886-6227
(312) 886-6227
Ruth Tatom
(FTS) 255-2289
(214) 655-2289
Jeff Wandtke
(FTS) 757-3884
(913) 236-3884
Marlin Helming
(FTS) 776-5103
(303) 236-5103
Kathleen Moore
(FTS) 454-0567
(415) 974-0567
Bill Puckett
(FTS) 399-1702
(206) 442-1702
CDS
Tom Elter
(FTS) 835-3259
(617) 565-3259
Gloria Vaughn
(FTS) 264-0885
(212) 264-0885
Jackie Pine
(FTS) 597-6552
(215) 597-6552
Liz Wilde
(FTS) 257-2904
(404) 347-2904
Dusanka Knutson
(FTS) 353-6730
(312) 353-6730
Mary Marusak
(FTS) 255-7223
(214) 655-7723
Earlyne Hill
(FTS) 757-2896
(913) 236-2896
Brenda Combs
(FTS) 564-7684
(303) 293-7684
Marian Lundholm
(FTS) 454-8065
(415) 974-8065
Betty Swan
(FTS) 399-2724
(206) 442-2724
MARYLAND ADOPTS COMPREHENSIVE
REGULATIONS FOR NEW AND EXISTING
SOURCES OF TOXIC AIR POLLUTANTS
by George Aburn, Head, Toxics Review Section, Maryland Air Management Administration
This article summarizes the major provisions of
Maryland's new regulations and outlines the steps the
Air Management Administration (AMA) of the Maryland
Department of the Environment took to reach promulga-
tion. The regulations were proposed on May 6,1988, and
became effective on September 27. All new sources
must comply with the regulations before they can be
issued an air quality permit. Existing sources must be
in compliance by 1990 or 1992, depending on the Toxic
Air Pollutants (TAPs) they discharge. Sources of car-
cinogens or highly toxic noncarcinogens are subject to
the earlier compliance deadline.
The AMA has estimated that the regulations will
cover over 150 new sources each year and about 800
existing sources at 400 facilities in four years. An in-
teresting aspect of the regulations is that the regulated
sources are responsible for estimating emissions, pre-
dicting off-site concentrations and providing a top-down
T-BACT (Best Available Control Technology for Toxics)
demonstration.
The Beginning of the Regulation
Development Process Described
The AMA began studying the air toxics issue in
mid-1983. At the time, AMA's efforts were concentrated
on two primary tasks: investigating programs developed
by other States and identifying major policy choices AMA
would have to make to develop the program. EPA
assisted in this effort by funding a contractor to prepare
a report identifying major policy choices. In preparing
that preliminary design, AMA also carefully reviewed the
work already done by other States. The programs in New
York and Michigan were especially useful as models.
When AMA settled on a preliminary design concept,
10

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they began the lengthy process of soliciting advice from
outside interest groups. In late 1984, a short concept
paper explaining the proposal was distributed widely.
AMA requested a meeting with major industries and en-
vironmental and community groups to discuss the paper.
They also met with the Chamber of Commerce, several
advisory councils, the Governor's Office, the State's
Department of Economic and Community Development,
State legislators, EPA, and public health educators from
the Johns Hopkins University and the University of
Maryland.
Through this process AMA was able to identify
some issues and better formulate their proposal.
Another important result was that the Chamber of Com-
merce asked AMA to set up an informal working group
as a forum for Chamber participation as AMA developed
the regulations. The Chamber was especially interested
in early involvement before the final proposal was
developed.
The AMA agreed to form a working group represent-
ing a broad spectrum of interests in addition to the
Chamber. After preparing a preliminary draft regulation,
AMA convened a working group consisting of represen-
tatives from the Chamber, environmental groups, the
State legislature, local government, EPA, and outside ex-
perts. EPA assisted by funding both a contractor (to
prepare drafts of some supporting documentation) and
a consultant (to chair the working group).
The AMA met with the working group eight times
during the summer and early fall of 1985 and revised the
draft regulations based on their comments. In November
and December, public meetings were held throughout
the State. The AMA found that the meetings with the
working group were much more productive than the
public meetings in getting informed comments on the
draft regulations and identifying important issues.
However, the public meetings reached a much broader
audience.
It is interesting to note that although AMA formed
the working group at the request of the Chamber, the
Chamber's representatives in the working group made
it clear that they would be speaking as individuals, not
for the whole Chamber. Further, they acknowledged that
the Chamber might never fully support any version of an
air toxics control program because some Chamber
members would always oppose it.
The AMA concluded that the working group process
was a very useful means to identify and work out
reasonable solutions to issues, but that its role in
developing a workable compromise between conflicting
points of view was somewhat limited.
Based on the working group recommendations,
AMA prepared a revised draft of the regulations. This
draft was presented to three advisory groups: the Air
Quality Advisory Council, the Governor's Council on Tox-
ic Substances, and the Controlled Hazardous
Substances Council. All three councils recommended
that AMA proceed with the regulations. Throughout this
period AMA continued to work with interested parties on
certain parts of the regulations. The Maryland Chamber
of Commerce and the Maryland Chemical Industry
Council (a group of large chemical companies) con-
tinued to express concern over certain sections of the
regulations.
On May 6, 1988, AMA proposed the regulations in
the Maryland Register. Three hearings were held, and
there was a 30-day comment period. The hearings were
sparsely attended, and few written comments opposing
the regulations were received. The regulations were ap-
proved on July 29, 1988, and became effective
September 27. The AMA feels that the formal promulga-
tion process went smoothly because of its considerable
efforts to resolve problems prior to promulgation.
Toxic Air Pollutants and Sources
Covered by Regulations Discussed
Toxic air pollutants (TAPs) include a large number
of carcinogens and noncarcinogens for which no na-
tional or State ambient air quality standards have been
established. The regulations refer to carcinogens as
"Class I TAPs" and to other toxics as "Class II TAPs."
The number of substances regulated as toxic air
pollutants is larger for new than for existing sources. For
existing sources, the regulations contain a specific list
of pollutants. For new sources, there is a somewhat
longer list of Class I TAPs (carcinogens) and an open-
ended definition of Class II TAPs that is based on the
definition of "health hazard" in the State's Right-to-Know
laws.
The sources governed by the regulations are iden-
tified in the sections concerning applicability. In general,
the regulations apply to any source required to get an
air quality permit. Certain small sources are exempt, and
there are specific exemptions for fuel-burning equip-
ment, char-broilers, and gasoline stations.
Regulations' General Requirements Outlined
The regulations have three major requirements:
1.	Quantify emissions of toxic air pollutants.
2.	Use the best available control technology for
toxics (T-BACT).
3.	Do not unreasonably endanger human health.
Under the first of these requirements new sources
must quantify any TAP discharged. For existing sources,
the requirement is limited to specifically listed TAPs. Ex-
isting sources must submit emissions information by
January 1,1989, for Class I and highly toxic Class II TAPs,
and by January 1, 1991, for other Class II TAPs.
The T-BACT requirement applies to new sources.
It allows the Department to consider both the toxicity of
substances discharged and the costs of controlling emis-
sions on a case-by-case basis.
The third requirement is also called the "ambient
impact" requirement, because in order to demonstrate
11

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compliance, a source must show that it will not increase
concentrations of TAPs in the ambient air by more than
certain levels. Existing sources must comply with the
ambient impact requirement by July 1, 1990, for Class
I and highly toxic Class II TAPs, and by January 1,1992,
for other Class II TAPs.
The Ambient Impact Requirement
Includes Several Options
The ambient impact requirement is the most com-
plex part of the regulations, because there are several
options a source may use to demonstrate that its emis-
sions do not unreasonably endanger human health. The
primary option is to demonstrate that the source will not
increase ambient concentrations by more than ap-
plicable "Screening Levels." The second option is a
"Second Tier Analysis." There is also a third option for
Class I sources, involving a "Special Permit."
Screening levels are established for both car-
cinogens and for other toxic effects. Screening levels for
carcinogenic effects are called "Risk-Based Screening
Levels" since they are developed using risk assessment.
The risk-based screening level represents a maximum
increase in individual lifetime cancer risk of 1 in 100,000.
Screening levels for other toxic effects may be
based on Threshold Limit Values (TLVs). The TLV-based
screening levels are equal to the TLV divided by 100 and
are either 1- or 8-hour average concentrations. If no TLV
is available, the regulations contain procedures for
developing screening levels based on toxicity data
establishing thresholds for various health effects
(threshold-based screening levels). Since these screen-
ing levels are developed using methods that may not be
appropriate for every substance, the regulations also
provide that the Department may adopt special screen-
ing levels to more adequately reflect toxic effects other
than cancer.
Screening levels are intended to be conservative so
that public health will be protected even though only one
source is evaluated at a time. However, a mechanism is
provided in the "Second Tier Analysis" to consider
multiple sources of a TAP and to develop a less conser-
vative, though still protective, Acceptable Ambient Level
(AAL) to replace a screening level for noncarcinogenic
effects.
The Second Tier option also provides for the
development of "Insignificant Risk Concentrations" in
cases where new data indicate that a risk-based screen-
ing level should be revised. This option will involve a
reanalysis of the dose response data for a carcinogen.
Finally, the Special Permit option for Class I TAPs
involves a reassessment of the exposure to a carcinogen
and the acceptable risk level. Screening level analysis
assumes that a person will be continuously exposed for
70 years to the highest TAP concentration predicted to
occur off the source's property. Since this assumption
is very conservative, the Special Permit option provides
for the opportunity to use more realistic exposure
assumptions. In addition, if necessary, the Special Per-
mit provides the opportunity to accept risks that are
higher than 1 in 100,000.
Urban Air Toxics Study Underway
The AMA is also involved in an urban air toxics
study of the Baltimore area. This study, which is part of
an EPA-sponsored Integrated Environmental Manage-
ment Program (IEMP) project, reviews all sources of air
toxics including cars and other area sources. The study
will help the Department establish priorities among
sources, source categories, and pollutants by ranking
sources and pollutants in terms of risk. The study will
also demonstrate a risk management approach where
control options are ranked in terms of risk reduced per
dollars spent and combined into the most cost-effective
strategies to reduce risk. The study should be complete
in 1989.
For more information on Maryland's regulations, call
the Air Toxics Control Division at (301) 631-3230.
OTS CONCLUDES TWO SARA TITLE III SECTION 313
QUALITY ASSURANCE PILOT SURVEYS
Anticipating wide variety in the data submitted in the
first year Form R reports, the Office of Toxic Substances
(OTS) has implemented a multi-task quality assurance
effort to determine data quality. Form R reports are those
required for the Toxic Chemical Release Inventory col-
lected under the authority of Section 313 of SARA Title
III. The reports were due July 1, 1988. The Agency ex-
pected data quality to vary because of lack of monitor-
ing data and the influence of such factors as facility size
or the "chemical sophistication" of the facility, staff, or
consultant resources preparing the reports.
The concept of visiting randomly selected facilities
is a pilot effort by EPA designed to gather information on
the applicability of this approach to data quality
assurance. In addition to indicating improvements that
can be made in future data quality efforts, the site visits
provided feedback that can be used to improve the
reporting instructions, guidance, or the reporting form.
Two pilot data quality efforts have just been com-
pleted. One used telephone contacts to clarify "ques-
tionable" data; the other used site visits to review all
aspects of a facility's reporting.
12

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Questionable Data Surveyed by Telephone Calls
The OTS called 60 facilities to clarify data that it
found questionable based on a number of automated
data checking algorithms. Algorithms were prepared on:
air releases for volatile compounds (for "users"* of
chemicals and for all others); fugitive air emissions of
volatile compounds; water releases of dyes; water
releases of a number of chemicals in 10 industrial
categories; total releases for chemicals "used" at a
facility (with and without treatment); wastewater treat-
ment efficiency; airborne waste treatment efficiency; and
potential double counting of releases and offsite
transfers.
After these algorithms were programmed and ap-
plied to the data, OTS automatically selected forms that
had a questionable response (such as low water
releases of a textile dye). Depending on the resources
available, OTS randomly selected 5 to 10 forms for calls
to clarify each of the 9 to 10 categories (listed above) of
questionable data. Calls concentrated on the specific
questionable data point.
Site Visits Reviewed Data in Detail
In the second major activity, OTS visited 25 random-
ly selected sites to review in detail all calculations,
assumptions, and determinations made for all forms
submitted by the facility. Facilities selected were
stratified to cover facilities across the reporting SIC
codes although the number of visits was not intended
to provide a statistical measure of the validity of release
estimates. Site visits required developing a survey instru-
ment and an Information Collection Request.
In early 1989, OTS plans to call up to 1,000 facilities
for questionable data and visit up to 200 sites for detailed
audits. For further information on this project, call Larry
Longanecker, EPA/Office of Toxic Substances, at (202)
382-7971.
•Facilities indicated whether they manufacture, process
or use the chemicals reported.
EPA, STAPPA/ALAPCO COf
URBAN AIR TOXICS WORK
Registration space is still available for workshops
due to take place in Anaheim (February 15-17, 1989),
Denver (March 8-10, 1989) and Baltimore (April 19-21,
1989). These are two-and-a-half day workshops to
disseminate information and promote discussion on ur-
ban air toxics, including evidence assembled to date and
air quality planning and management activities by State
and local agencies. The workshops are being co-hosted
by State and local agencies which have recently com-
pleted major urban air toxics studies. State and local ex-
periences in assessing and mitigating urban air toxics
as well as the latest EPA information will be presented
and discussed.
tITINUE
SHOP REGISTRATION
Registration is $40 and is reserved for government
agency personnel. Names of interested nongovernment
personnel will be placed on a waiting list for registration.
E. H. Pechan & Associates is handling workshop infor-
mation under contract to EPA. For more information or
registration forms, write to Annette Najjar, E. H. Pechan
and Associates, 5537 Hempstead Way, Springfield, VA
22151, or call the conference hot line at (703) 941-4490.
The EPA Project Manager is Bill Lamason, Noncriteria
Pollutant Programs Branch, MD-15, U.S. EPA, Research
Triangle Park, North Carolina 27711, (919) 541-5374.
AMBIENT AIR TOXICS REP
The second and final report "The EPA Interim Data
Base for Air Toxic Volatile Organic Chemicals" is now
available on the interim data base for ambient air toxic
measurements. The data base consists of air toxics data
contributed on a voluntary basis from local, State, and
Federal agencies. The California Air Resources Board's
data from its State network is featured in the report. The
Interim Data Base was created initially because EPA's
previous air data handling system (SAROAD) could not
store toxics data. The National Aerometric Information
Retrieval System (AIRS) subsystem now has the
capability to store and process ambient air toxics data
ORT AVAILABLE
(see article on AIRS elsewhere in this issue). According-
ly, future reports on air toxics data will be based on the
information on AIRS.
This report contains summary statistics for 75 tox-
ic air pollutants representing a total of 148 monitoring
sites. The report provides annual summary statistics
such as the mean and maximum concentrations and,
when available, the quarterly summary statistics as well.
The report is available to anyone interested by calling
Bob Faoro at (919) 541-5459 or (FTS) 629-5459, or by
writing him at: U.S. EPA, MD-14, Research Triangle Park,
North Carolina 27711.
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OAQPS PUBLISHES AIR TO
EMISSION FACTOR COMPII
The EPA's Office of Air Quality Planning and Stan-
dards (OAQPS) has recently published two reports en-
titled "Toxic Air Pollutant Emission Factors - A Compila-
tion for Selected Air Toxic Compounds and Sources"
and "Toxic Air Pollutant Emission Factors - Information
Storage and Retrieval System User's Manual." The
respective report numbers are EPA-450/2-88-006a and
EPA-450/2-88-006b. The first report presents emission
factors for selected air toxic compounds and sources,
and associates the emission factors to levels of source
activity. The emission factors in the report were compiled
from a review of the literature for more than 200 air tox-
ics compounds. This report updates and expands a
previous report entitled "Preliminary Compilation of Air
Pollutant Emission Factors for Selected Air Toxic Com-
XICS
.AT ION
pounds," EPA 450/4-86-010a. A software system contain-
ing the compilation was developed to allow for easy ac-
cess and updating of the system. The second report ex-
plains the use of the system.
Single copies of these reports are available by
writing the EPA library at MD-35, Research Triangle Park,
North Carolina 27711 or by calling (919) 541-2777 or (FTS)
629-2777. These reports will also be available for a fee
through the National Technical Information Services
(NTIS) by calling (703) 487-4650. No NTIS numbers have
been assigned yet. The system and data base are
available to agency users upon request by writing Anne
Pope at MD-15, Research Triangle Park, North Carolina
27711 or by calling (919) 541-5373 or (FTS) 629-5373.
OAQPS PUBLISHES URBAN
The Air Quality Management Division (AQMD)/Non-
criteria Pollutant Programs Branch (NPPB) has recent-
ly published a report on urban air toxics that was original-
ly prepared by the South Coast Air Quality Management
District (SCAQMD). The report was published by
SCAQMD in June 1987 and is entitled "Multiple Air Tox-
ics Exposure Study; Working Paper No. 3." Its EPA report
number is EPA-450/4-88-013. The report gives an ac-
count of how the emission and ambient data collection
and analyses were conducted for their urban air toxics
assessment effort known as the Multiple Air Toxics Ex-
AIR TOXICS REPORT
posure Study (MATES). The report has been published
by EPA to make it more widely available as an example
of how State and local agencies may conduct urban air
toxics analyses. Copies are being distributed to many
State and local agency officials but State and local agen-
cies may obtain additional copies by writing to U.S. EPA,
Pollutant Characterization Section, MD-15, Research
Triangle Park, North Carolina 27711. The report is being
entered into the National Technical Information Service
(NTIS). The NTIS number and price are not yet available.
FIMAL HOSPITAL WASTE C
STUDY REPORT RELEASED
The Hospital Waste Combustion Study - Data
Gathering Phase, Final Report (EPA-450/3-88-017) was
released in December 1988. This report contains the
results of a study of air emissions from hospital waste
combustion. These results will allow the EPA to assess
the need for and feasibility of regulating multipollutant
emissions from hospital waste combustion.
Information was gathered from State and local en-
vironmental agencies, equipment vendors, the open
technical literature, the American Hospital Association,
and visits to three incineration facilities. Information was
sought concerning feed characteristics, combustor
designs and operating characteristics, emissions of air
pollutants, applied and potential control technology,
numbers and locations of hospital waste combustors,
and applicable regulations.
OMBUSTION
The report provides a description of the industry and
characterization of hospital waste, information about the
processes and equipment used for hospital waste com-
bustion, data concerning air pollutants emitted from
hospital waste incinerators and their formation in the
combustion process, a discussion of air pollution con-
trol techniques and possible control efficiencies, a sum-
mary of regulations affecting hospital waste combustion
and model plants for EPA's use in assessing regulatory
strategies.
Copies of this report are available through the
Library Services Office (MD-35), U.S. Environmental Pro-
tection Agency, Research Triangle Park, North Carolina
27711, or from National Information Services, 5285 Port
Royal Road, Springfield, Virginia 22161.
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CTC AND All? RISC HOTLINES
ARE READY TO ASSIST STATE AND
LOCAL AGENCIES
For answers to control technology questions, State
and local air agencies can call EPA's Control Technology
Center (CTC) Hotline at (919) 541-0800.
Help with questions on health effects, exposure, or
risk assessment associated with air toxics is available
from EPA's Risk Information Support Center (Air RISC)
Hotline at (919) 541-0888.
NEED HELP?
If your agency needs help in finding information on
a specific air toxics question, you can announce that
need in the National Air Toxics Information Clear-
inghouse Newsletter. Your colleagues from other State
or local agencies who have such information will be able
to contact you with assistance. In addition, the Clearing-
house staff would like to receive your ideas for future
Newsletter articles. To list an information need in the next
issue or to submit an article or a suggestion for a future
Newsletter article, please call Susan Buchanan, Radian
Corporation, (919) 541-9100.
The National Air Toxics Information Clearinghouse Newsletter is published six times a year by the National
Air Toxics Information Clearinghouse to assist State and local agencies making decisions on noncriteria pollu-
tant emissions. The first issue appeared in December 1983. The Clearinghouse is being implemented by the
U.S. Environmental Protection Agency, Emission Standards Division, Pollutant Assessment Branch as part of
a joint effort with the State and Local Air Pollution Control Officials (ALAPCO). The National Air Toxics Informa-
tion Clearinghouse Newsletter is prepared by Radian Corporation under EPA Contract Number 68-08-0065,
Work Assignment 1. The EPA Project Officer is Scott Voorhees, EPA Office of Air Quality Planning and Stan-
dards, Research Triangle Park, North Carolina 27711, Telephone: (919)541-5348. The Radian Project Director
is Susan Buchanan, P.O. Box 13000, Research Triangle Park, North Carolina 27709, (919)541-9100.
The Newsletter is prepared primarily for State and local air pollution control agencies and is distributed
free of charge. Those wishing to report address changes may do so by writing Meredith Haley, Radian Cor-
poration, P.O. Box 13000, Research Triangle Park, North Carolina 27709. Please contact the Project Officer either
with any comments you might have pertaining to this newsletter or with suggestions for future newsletters. Ar-
ticles in the newsletter are written by Radian Corporation or EPA staff unless otherwise indicated.
The views expressed in the National Air Toxics Information Clearinghouse 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.
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Scott Voorhees
Pollutant Assessment Branch
U.S. Environmental Protection Aqency
MD-13
Research Triangle Park, NC 27711
FIRST CLASS MAIL
U.S. Postage Paid
E.P.A.
Permit No. G-35

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