Hazardous Air Pollutants: Assessment, Liabilities and Regulatory Compliance

409 Pages·1997·13.73 MB·English

by  Jeffrey W. Bradstreet

HAZARDOUS AIR POLLUTANTS
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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