HAZARDOUS AIR POLLUTANTS This page intentionally left blank HAZARDOUS AIR POLLUTANTS Assessment, Liabilities, and Regulatory Compliance by Jeffrey W. Bradstreet NOYES PUBLICATIONS Park Ridge, New Jersey, USA. copyrisht 8 1995 by Jefftey W. Bradstreet No copy of this book may be reproduced or utilized in any form 01 by any means, electronic or mechanical, including photocopying. recording or by any informa- tion storage and retrieval system, without permission in writing from the Publisher. Uirary of Congress Catalog Card Number: 95-31385 ISBN 0-8155-1386-0 Printed in the United States Published in the United States of America by Noyes Publications Mill Road, Park Ridge, New Jersey 07656 10 9 8 7 6 5 4 3 2 1 Library of Congress Cataloging-in-Publication Data Bradstreet, Jeffrey W. Hazardous air pollutants : assessment, liabilities, and regulatory compliance /by Jeffrey W.B radstreet. p. an. Includes bibliographid references and index. ISBN 0-8155-1386-0 1. Air--Pollution. 2. Fadory and trade waste--E!nvironmental aspects--United States. 3. Liability for air pollution damages- -United States. 4. United States. Clean Air Act Amendments of 1990. I. Title. TD883.2.B62 1995 363.73'92--d~20 95-31385 m ACKNOWLEDGMENTS My special appreciation to my wife Susan for her love, encouragement and partnership in completing this book. My thanks to Gary Wroblewski for his assistance and contributions on Chapter 7 and to Laurie Graziano for her typing of most of this book. This book is dedicated to the memory of Morris B. fit4 DSc., apioneer in the field of hazardous air pollutants. V ABOUT THE AUTHOR Dr. Jeffrey Bradstreet has over 23 years of experience in the evaluation and reduction of environmental risks associated with industrial facilities, and is recognized nationally for his expertise in environmental engineering. He has directed the environmental assessment and development of compliance programs for a variety of industrial facility emissions. His areas of specialized expertise include air pollution control technology, environmental permitting, hazardous waste management, hazardous air pollutant management, health risk assessment, environmental compliance programs, and expert testimony. He is a member of the Chi Epsilon National Civil Engineering Honor Society; the American Society of Civil Engineers; and the Air and Waste Management Association (and serves on the AWMA Solvents, Odors, and Gases Committee). vi PREFACE During the past ten years, state and federal regulations affecting hazardous air pollutants have produced an escalating dilemma for industrial facilities. While struggling to remain competitive and in compliance with environmental regulations, industry faces increasing requirements and potential liabilities due to emissions of hazardous air pollutants. Many states began establishing regulations governing the emissions of hazardous air pollutants after the 1984 accidental release of methyl isocyanate in Bophal, India. After thirteen years of extended debate, the U.S. Congress passed significant amendments to the Clean Air Act in 1990. These various regulations require industrial facilities to evaluate, control, monitor, permit and assess risk for a variety of listed chemicals considered hazardous air pollutants. Title I11 of the 1990 Clean Air Act Amendments provides for the permitting and control of sources emitting as little as ten tons per year of one of 189 federally listed hazardous air pollutants. In addition, sources emitting lesser quantities of 100 of these 189 hazardous air pollutants have to develop risk management plans to prevent accidental releases. This requirement is very similar to the Occupational Safety and Health Administration regulation for protecting workers from accidental releases. Approximately ten other federal regulations also deal with emissions of hazardous pollutants. In addition, state regulations address up to 460 hazardous air pollutants. Deadlines for establishing compliance with the federal requirements, are currently being implemented for some industry categories and are scheduled to be completed by 2003. vii viii Preface To effectively respond to this myriad of hazardous air pollutant regulations and maintain a viable business, owners and operators of industrial facilities need to understand: the pollutants that are regulated as hazardous, applicable state and federal requirements, sources of hazardous air pollutants, the quantification of hazardous air pollutant emissions, potential risks and liabilities, and the best means to establish a compliance program. This book provides a review of the regulatory requirements affecting sources of hazardous air pollutants, the available methods for inventorying and measuring emissions, a review of methods for evaluating potential risks and liabilities due to hazardous air pollutant emissions, and approaches available to reduce emissions and establish a hazardous air pollutant compliance program. LIST OF FIGURES Figure 3-1 Potential Benefit of Early Reduction . . . . . . . . . 42 Figure 3-2 Table I11 Flow Chart . . . . . . . . . . . . . . . . . . . 55 Figure 5-1 Overview of Wisconsin Chapter NR445 . . . . . . . 96 Figure 6-1 Estimate of Relative Contribution of Various Sources to Estimated Annual Cancer Cases . . . . . . . . . . . . . . . . . . . 9 9 Figure 9-1 The Four Evaluations of Risk Assessment . . . . . 222 Figure 9-2 Types of Downwash . . . . . . . . . . . . . . . . . . 226 Figure 9-3 Typical Atmospheric Stability Conditions . . . . . 229 Figure 9-4 Typical Gauss ian Plume . . . . . . . . . . . . . . . . 231 Figure 9-5 Selection and Application of Air Quality Models and Data Bases . . . . . . . . . . . 234 Figure 9-6a Typical Frequency Distribution . . . . . . . . . . . 246 Figure 9-6b Typical Cumulative Distribution . . . . . . . . . . . 246 Figure 9-7 Translating Exposure To Dose . . . . . . . . . . . . 248 Figure 9-8a Typical Dose Response Curve ............ 250 Figure 9-8b Typical Extrapolation of Dose Response Curve ..................... 250 Figure 10-1 Bag-in-a-Drum Sampling Technique . . . . . . . . 263 Figure 10-2 Triangle Olfactometer System . . . . . . . . . . . . 264 ix