Document 06Mopvb7Le6eBKxQY3yNEg49m

California Air Rasourcas Board PROPOSED UPDATE TO THE LIST OF SUBSTANCES FOR THE TOXIC AIR CONTAMINANT PROGRAM State of California Air Resources Board Stationary Source Division February 1991 SL 063393 PROPOSED UPDATE TO THE LIST OF SUBSTANCES FOR THE TOXIC AIR CONTAMINANT PROGRAM State of California Air Resources Board Stationary Source Division February 1991 SL 063394 PROPOSED UPDATE TO THE LIST OF SUBSTANCES FOR THE TOXIC AIR CONTAMINANT PROGRAM PreDared-.bv: State of California Air Resources Board Stationary Source Division Principal Author: Richard Corey Contributing Staff: Jay Emerson Greg Harris Kitty Howard Roger Korenberg Linda Martz Reviewed bv: Janette Brooks, Manager, Special Projects Section Joan Denton, Manager, Substance Evaluation Section Genevieve Shiroma, Chief, Toxic Air Contaminant Identification Branch Donald 0. Ames, Assistant Chief, Stationary Source Division Peter D. Venturing Chief, Stationary Source Division February 1991 Si- PROPOSED UPDATE TO THE LIST OF SUBSTANCES FOR THE TOXIC AIR CONTAMINANT PROGRAM To be presented at the meeting of the California Air Resources Board: on March 15, 1991 at Lincoln Plaza Auditorium, First Floor 400 P Street Sacramento, California California Air Resources Board 1102 Q Street P.0. Box 2815 Sacramento, CA 95812 This report has been prepared by the staff of the Air Resources Board and approved for publication. Approval does not signify that the contents necessarily reflect the views and policies of the Air Resources Board. SL 63396 TABLE OF CONTENTS Contents EAflfi Acknowledgments......................................................................................................... 111 Overview and Recommendation.................................................................................. 1 I. Changes in Substance Status........................................................................ 9 A. Inorganic Arsenic...................................................................................... 9 B. Trichloroethylene...................................................................................... 9 C. Vinyl Chloride............................................................................................. 10 D. Chloroform..................................................................................................... 10 E. Styrene........................................................................................................... 11 F. Coke-Oven Emissions.................................................................................. 12 G. Inorganic Lead............................................................................................. 12 II. Proposed Changes to Definitions and List Framework.......................... 13 A. Category Definitions................................................................................ 13 B. Changes to List Framework...................................................................... 14 C. Emissions Data Used to Categorize New Substances..................... 16 D. Effect of Revised Category Definitions................ 16 E. Summary of Proposed Changes to the List........................................ 17 F. Listing of Substances and Substance Categories.......................... 17 III. Future Direction............................................................................................. 22 A. The List of Substances.......................................................................... 22 B. Prioritization of Substances............................................................... 22 References...................................................................................................................... 24 TABLES 1 - Proposed Toxic Air Contaminant Identification List......................... 2 - Summary of Substancesin Proposed Subcategory IIIA.......................... 3 - Summary of Substances in Proposed Subcategory 11 IB.......................... 4 - Proposed Toxic Air Contaminant Identification List......................... 6 18 18 19 SL 063397 appendices Appendix A - February 1990 Toxic Air Contaminant Identification List Appendix B - Request for Information on the Toxic Air Contaminant Program List Appendix C - Comments Received from Public with Staff Responses Appendix D - Styrene Health Effects Evaluation Request Appendix E - Inorganic Lead Health Effects Evaluation Request -u- SL 063398 ACKNQWLED6MEHI5 The authors wish to thank the many air pollution control districts that provided preliminary toxics emissions data collected under the Air Toxics "Hot Spots" Information and Assessment Act of 1987. In addition, the authors wish to thank the following management and staff of the Air Resources Board and Department of Health Services who reviewed and commented on this report: Barbara Cook Joe De Vita Peggy Jenkins Jim Lyons Beth Schwehr Carolyn Suer Todd Wong George Alexeeff Department of Health Services -i i i- SL 063399 OVERVIEW AND RECOHHENDATIflM OVERVIEW Each year the Toxic Air Contaminant Identification List of substances is reviewed and presented to the Air Resources Board ("the Board") as an informational item. This report presents proposed changes to the February 1990 list of substances (Appendix A) used in the Toxic Air Contaminant Program. The revised list is entitled "The Toxic Air Contaminant Identification List, February 1991." 1. What is the purpose of the list of suhstances? The purpose of the list of substances is to assist the Air Resources Board staff (ARB staff) with the selection of pollutants for review as Toxic Air Contaminants. In addition to assisting with the selection of substances for review as Toxic Air Contaminants, the list serves to: identify the substances of potential concern in California as Toxic Air Contaminants; fulfills the requirements of state law by setting priorities for the review of listed substances (Health and Safety Code section 39660(f)); informs the public of the substances under evaluation; and provides the public with the opportunity to comment on the priorities of the Toxic Air Contaminant Program. Subsections 2, 3, and 4 provide general background information on the Toxic Air Contaminant Program. This information is intended to provide a more complete perspective concerning the role that the list plays in the Toxic Air Contaminant Program. 2. What is a Toxic Air Contaminant? California Health and Safety Code section 39655 defines a Toxic Air Contaminant as an air pollutant which may cause or contribute to an increase in mortality or an increase in serious illness, or which may pose a present or potential hazard to human health. In addition, substances which have been identified as Hazardous Air Pollutants pursuant to section 7412 of Title 42 of the United States Code shall be identified by the Air Resources Board as Toxic Air Contaminants. -1- SI* 063400 3. How are substances selected for review as Toils Air Contaminants? In setting priorities for the substances being evaluated as Toxic Air Contaminants, the ARB staff is required to consider factors -elating to public exposure and health risk, quantity of emissions, use and atmospheric persistence. These evaluation activities are done in const, ation with the Department of Health Services, the Scientific Review Panel, and local air pollution control districts. 4. How are substances identified as Toxic Air Contaminant!? Prior to listing a substance as a Toxic Air Contaminant, the ARB and Department of Health Services' staffs develop a comprehensive report on the candidate Toxic Air Contaminant. The report include* estimates of outdoor and Indoor exposure and health risk, estimated emiss is, and the atmospheric persistence of the candidate substance. After public review and comment, the report is revised as appropriate before being submitted to the Scientific Review Panel (SRP) on Toxic Air Contaminants (Health and Safety Code section 39670 et. seq.). This prestigious panel of experts, representing a range of scientific disciplines, evaluates the scientific procedures and methods used, the health effects and exposure data, as well as the conclusions presented In the report. Based on the SRP's comments, the report may require revisions. The SRP Is required to submit written findings to the Board regarding the document. As part of their findings, the SRP makes a recommendation as to whether the substance should be identified by the Board as a Toxic Air Contaminant. The next step in the process Is formal submittal of the report to the Board for consideration. The final decision regarding the listing of a candidate substance as a Toxic Air Contaminant Is made by the B;: d at a public hearing. If the Board approves the ARB staff's recommer 'ion that the candidate substance meets the criteria for identification a Toxic Air Contaminant, it is listed as a Toxic Air Contaminant In tht California Code of Regulations. 6. What happens after a substance Is Identified as a Toxic Air Contaminant? Once a substance Is Identified as a Toxic Air Contaminant the ARB staff in consultation with local air pollution control districts (districts), affected sources and the Interested public, evaluates the need for and appropriate degree of regulation for each Toxic Air Contaminant. The result of the evaluation may lead to the development of a control regulation(s) which the Board would consider for adoption at a public hearing. -2- SL 063401 6. Whv is it necessary to revise the list of substances? This year it is necessary to revise the list to: update the status of substances that were on the February 1990 list (e.g., inorganic arsenic, vinyl chloride, trichloroethylene, and chloroform have now been formally identified by the Board as Toxic Air Contaminants and as such are no longer in the review process); revise the list category definitions to more accurately reflect the status of substances in the process as well as the factors evaluated for selecting substances for review as Toxic Air Contaminants; and reflect recent amendments to the Federal Clean Air Act. 7. How are we proposing to revise the category definitions? Category II on the February 1990 Toxic Air Contaminant Identification List is defined as "Substances currently under review for identification as Toxic Air Contaminants, scheduled for review, or nominated for review but not yet scheduled. It will be necessary to develop Information on exposure in California to some substances in this category before pursuing review." The February 1990 list Includes two Subcategories (IIA and IIB). Subcategory IIA includes "Substances already in the review process." Subcategory IIB includes "Substances not yet under review." The revised definition to Category II is proposed to state "Substances currently under review or nominated for review for identification as Toxic Air Contaminants." Subcategory IIA is proposed to be revised to state "Substances already in the review process." Subcategory IIB Is proposed to be revised to state "Substances nominated for review." Category III on the February 1990 Toxic Air Contaminant Identification List is defined as "Compounds for which health effects information is limited or not yet sufficient to support review. Substances in this category are produced and emitted to the air In quantities which might make them of concern at such time as health effects Information is strong enough to support review." The revised definition to Category III is proposed to state "Substances which are being evaluated for entry into Category II (IIA or IIB). Factors considered in this evaluation include carcinogenic and noncarcinogenic health effects, emissions and exposure in California." In addition, we are proposing to add two Subcategories (IIIA and IIIB). Subcategory IIIA is proposed to state "Substances known to be emitted in California (includes Hazardous Air Pollutants identified in the Federal Clean Air Act known to be emitted in California)." Subcategory IIIB is proposed to state "Substances identified as Hazardous Air Pollutants in the Federal Clean Air Act for which California emissions information is not currently available." -3- SL 063402 8. What Is the reason for revising the Category II dflOalilam? The reason for revising the definitions for Category II is to clarify that substances in Category II are either currently under review for Identification as Toxic Air Contaminants or nominated for review for identification as Toxic Air Contaminants. 9. js-thftjttflsan-tar- revising, the.Category III -def In titans? The reason for revising the definition for Category III is to clarify that carcinogenic as well as noncarcinogenic health effects are considered when evaluating substances for possible review as Toxic Air Contaminants. The definition is also clearer in identifying the factors that are evaluated to determine whether a substance should be elevated Into the review phase of the process (Category II). In addition, Category III is revised to address recent amendments to section 112 of the Federal Clean Air Act. Specifically, 189 substances are now listed as Federal Hazardous Air Pollutants. This amendment has a direct effect on the list because the Board is required to identify Hazardous Air Pollutants as Toxic Air Contaminants (see subsection 2 of the Overview for background). As a result, it is appropriate to include all (189) of the Hazardous Air Pollutants on the list. To focus evaluation efforts on the substances with available information, it is proposed that Category III be revised to include Subcategory IIIA and IIIB. The purpose of Subcategory IIIA and IIIB is to separate the substances based on the availability of California emissions data. Emissions information was selected as the criterion for separating substances into Category IIIA and IIIB because emissions are an indicator of potential public exposure, and toxics emissions data are available for many facilities throughout California. The information relied upon to determine whether a substance is emitted in California Included: the Toxic Chemical List developed pursuant to Title III, section 313 of the Superfund Amendments and Reauthorization Act of 1986; the Bay Area Air Quality Management District's Air Toxics Inventory (October 27, 1990); the South Coast Air Quality Management District's Air Toxics Inventory (1983 and 1985 Update); and summaries of preliminary emissions information provided by districts under the Air Toxics "Hot Spots" Information and Assessment Act of 1987. As stated, Federal Hazardous Air Pollutants added to the list were placed in either Subcategory IIIA or IIIB based on review of California emissions data. In addition, if emissions were reported for substances that are not ieral Hazardous Air Pollutants, they were added to Subcategory IIIA. TSubcategory IIIA includes substances (Federal Hazardous Air Pollutants as well as substances that are not Federal Hazardous Air Pollutants) for which California emissions data are available. -4- SL 063403 10. Who reviewed the proposed Toiic Air Contaminant Identification Lisi? On December 4, 1990, the category definitions for the draft proposed Toxic Air Contaminant Identification List were considered by the SRP. Based on the SRP's comments, the list was revised prior to being released for public review and comment. On December 26, 1990, the Proposed Toxic Air Contaminant Identification List was sent out for public review and comment (Appendix B). The list was sent to over 800 members of the interested public. Comments received from the public as well as ARB staff responses are included in Appendix C. 11. Summary of the recommended revisions to the Februarv_199Q list The revised list entitled "Toxic Air Contaminant Identification List, February 1991" is presented in Table 1. The revised list Includes; 14 substances in Category I (the February 1990 list Included ten substances In this category); nine substances in Subcategory IIA (the February 1990 list included 11 substances in this category); 22 substances in Subcategory IIB (the February 1990 list included 25 substances in this category); 117 substances in Subcategory IIIA (the February 1990 list Included 16 substances in Category III); and 70 substances In Subcategory IIIB. The recommended revisions to the February 1990 Toxic Air Contaminant Identification List are as follows: o Move inorganic arsenic, trichloroethylene, vinyl chloride, and chloroform from Subcategory IIA to Category I. The purpose of this change is to reflect the fact that these substances have been identified by the Board as Toxic Air Contaminants; o Move styrene from Subcategory IIB to Subcategory IIA. The purpose of this change is to reflect the fact that styrene is currently under review for identification as a Toxic Air Contaminant. Styrene was selected for review because it is considered a possible human carcinogen by IARC, significant amounts of styrene are emitted to the atmosphere in California, and styrene is detected in the ambient air throughout the state; o Move inorganic lead from Subcategory IIB to Subcategory IIA. The purpose of this change is to reflect the fact that inorganic lead is currently under review for identification as a Toxic Air Contaminant. Inorganic lead was selected for review because lead and inorganic lead compounds are considered possible human carcinogens by IARC, significant amounts of lead and lead compounds are emitted to the atmosphere in California, and lead is detected in the ambient air throughout the state; -5- SL 063404 Table 1 Proposed Toxic Air Contaminant Identification List February 1991 I. Substances identified as Toxic Air Contaminants by the Air Resources Board, pursuant to the provisions of AB 1807. Asbestos Benzene Cadmium (metallic cadmium and cadmium compounds) Carbon tetrachloride Chlorinated dioxins and dibenzofurans (IS species) Chloroform Chromium VI Ethylene dibromide Ethylene dichloride Ethylene oxide Inorganic arsenic Methylene chloride Trichloroethylene Vinyl chloride II. Substances currently under review or nominated for review for identification as Toxic Air Contaminants. A. Substances already in the review process. Acetaldehyde Benzo(a)pyrene 1,3-Butadiene Diesel exhaust B. Substances nominated for review. Formaldehyde Inorganic lead Nickel and nickel compounds Perchloroethylene Styrene Acrylamide Acrylonitrile Beryllium compounds Dialkylnttrosamines p- Dichlorobenzene t, 1 - DimethyIhydrazine Di(2-ethylhexyl)phthalate t ,4-Dioxane Oimethyt sulfate Environmental tobacco smoke Ethyl acrylate Hexachlorobenzene Hydrazine Mercury compounds 4,4'-Methylenediar me N-Nitrosomorpholin-s PAHs PCBs Propylene oxide Radionuclides Toluene diisocyanates 2,4,6-Tnchiorophenol III. Substances which are being evaluated for entry into Category II (IIA or IIB). Factors considered in this evaluation include carcinogenic and noncarcinogenic health effects, emissions and exposure in California. A. Substances known to be emitted in California (includes Hazardous Air Pollutants identified In the Federal Clean Air Act known to be emitted in California). Acetone Acetonitrile Acrolein Acrylic acid Allyl chloride Aluminum Ammonia Ammonium nitrate Ammonium sulfate Antimony compounds Arsenic compounds Barium compounds Benzoyl chloride Benzyl chloride Biphenyl 8is(2-ethythexyl) adipate Bromine compounds (inorganic) Butyl acrylate Butyl benzyl phthalate Captan Carbon black extracts Carbary! Carbon disulfide Carbonyi sulfide Catechol Chlorinated fluorocarbons Chlorine Chlorine dioxide Chloroacetic acid Chlorobenzenes Chlorophenois Chromium compounds Cobalt compounds Copper compounds Creosotes Cr-sols/cresylir ac t!. oir and mixtures) C.vstalline silica Subcategory IIIA Continued Cumene hydroperoxide Cyanide compounds Cyclohexane Cumene 2,4- D (salts and esters) Diaminotoluene (mixed isomers) Dibenzofuran Dibutylphthalate Decafaromodiphenyl oxide 1,3- Dichloropropene Olchlorvos Oicofol Diethanolamine Dimethyl phthalate 4,6-Dimtio-o-cresol (and salts) Epichlorohydrin 1,2*Epoxybulane Ethyl benzene Ethyl chloride Ethylene glycol Ethylene thiourea Gasoline vapors Glutaraldehyde Glycol ethers Hexachlorocydohexanes Hexachloroethane Hexane Hydrochloric add Hydrogen fluoride Hydrogen sulfide Hydroquinone isopropyl alcohol 4,4'-lsopropylidenediphenol Lead compounds Maleic anhydride Manganese compounds Methanol Methyl bromide Methyl chloride Methyl ethyl ketone Methy1 hydrazine Methyl isobutyl ketone Methyl methacrylate Methyl tert-butyl ether Methylene diphenyl diisoeyanate Molybdenum trioxide n-Butyl alcohol Nitrobenzene 2-Nitropropane Nitric add Nitrilotriacetic add Parathion Peracetic add Phenol 2-Phenyiphenoi Phosphine Phosphoric add Phosphorus Phthalic anhydride 1,3-Propane sultone Propionaidehyde Propoxur Propene Propylene dichloride sec-Butyt alcohol Silver compounds Sodium hydroxide Sulfuric add Titanium tetrachloride Terephthalic acid tort-Butyl alcohol Thiourea Toluene 1,1,1 -Trichloroethane 1,2.4-TrimethyIbenzene 2,2,4-Trimethylpentane Vinyl acetate Vmylidene chloride Xylenes (o, m, p) Zinc compounds B. Substances identified as Hazardous Air Pollutants in the Federal Clean Air Act for which California emissions information Is not currently available. Acetamide Acetophenone 2-Acetylammofluorene 4-Aminobi phenyl Aniline o-Anisidlne Benzidine Benzotrichloride Bis(chk>romethyl)ether Bromoform Caldum cyanamide Caprolactam Chloramben Chlordane 2- Chloroacetophenone Chlorobenzilate Chloromethyl methyl ether Chloroprene Coke-oven emissions DDE Diazomethane 1,2-Dibromo-3-chloropropane 3,3-Dichlorobenzidine Dichloroethyt ether Diethyl sulfate 3.3`-Dlmethoxybenzidine Dimethylaminoazobenzene 3,3'-Dimethyl benzidine Dimethyl carbamoyl chloride Dimethyl formamide 2.4-Dinitrophend 2,4-Dinitrotoluene t ,2-Diphenythydrazine Ethyl carbamate Ethylene imine Ethytidene dichloride Fine mineral libers Heptachlor Hexachlorobutadiene Hexachlorocydopentadiene Hexamethylene-1,6-diisocyanate Hexamethytphosphoramide Isophorone Lindane Methoxychlor 4,4'-Methylene bis(2-enioroamline) Methyl iodide Methyl isocyanate N.N-Dimethylaniline 4-Nitrobiphenyl 4-Nitrophenol N-Nitroso-N-methyl urea Pentachioronitrobenzene p-Phenylenediamine Phosgene Polycyclic organic matter beta- Propioiactone 1,2-Propylenimine Quinoline Quinone Selenium compounds Styrene Oxide 1,1.2,2- Tetrachloroethane 2,4-Toluene diamine o-Toluidine Toxaphene 1,1,2-Tochloroethane Triethylamine Trifluralm Vinyl bromide -7- SL 063406 o Move coke-oven emissions from Subcategory IIB to Subcategdry II18. The purpose of this change is to reflect the fact that there are no known emission sources of coke-oven emissions operating in California; o Revise the definition of Category II to state "Substances currently under review or nominated for review for identification as Toxic Air Contaminants"; o Revise Subcategory IIA to state "Substances already in the review process"; o Revise Subcategory IIB to state "Substances nominated for review"; o Revise Category III to state "Substances which are being evaluated for entry into Category II (IIA or IIB). Factors considered in this evaluation include carcinogenic and noncarcinogenic health effects, emissions and exposure in California"; o Add Subcategory IIIA which states "Substances known to be emitted in California (includes Hazardous Air Pollutants identified in the Federal Clean Air Act known to be emitted in California)"; o Add Subcategory IIIB which states "Substances Identified as Hazardous Air Pollutants in the Federal Clean Air Act for which California emissions information is not currently available"; and o Add 170 substances to the February 1990 Toxic Air Contaminant Identification List; 102 to Subcategory IIIA and 66 to Subcategory IIIB. The purpose of this change is to reflect recent amendments to the Federal Clean Air Act wherebv 189 substances are now listed as Hazardous Air Pollutants. In ad; tion, substances for which California emissions data Is available, based on review of air toxics databases, were added to the list. RECOMMENDATION The ARB staff recommends that the Board approve the proposed revisions to the February 1990 Toxic Air Contaminant Identification List presented in this report. -8- SL 063407 I. CHANGES IN SUBSTANCE STATUS The purpose of this Chapter is to summarize the changes in the status of substances which were on the February 1990 Toxic Air Contaminant Identification List. These changes are reflected in the Proposed Toxic Air Contaminant Identification List, February 1991 (Table 1). A. INORGANIC ARSENIC On July 13, 1990 inorganic arsenic was identified as a Toxic Air Contaminant by the Board. As a result of this action, it Is recommended that inorganic arsenic be moved from Subcategory IIA to Category I. The following information which is presented in the staff report "Proposed Identification of Inorganic Arsenic as a Toxic Air Contaminant" (ARB, 1990a) contributed towards the Board's decision to Identify Inorganic arsenic as a Toxic Air Contaminant: o the California Department of Health Services found "the evidence for human carcinogenicity due to inhaled arsenic to be strong;" o inorganic arsenic is listed as a Federal Hazardous Air Pollutant; o inorganic arsenic is emitted from a variety of sources detected in the ambient air throughout California; and and is o inorganic arsenic is highly mobile in the environment, and is not naturally removed or detoxified at a rate that would significantly reduce public exposure. B. TRICHLOROETHYLENE On October 12, 1990 trichloroethylene was identified as a Toxic Air Contaminant by the Board. As a result of this action, it is recommended that trichloroethylene be moved from Subcategory IIA to Category I. The -9SL 063408 following information which is presented in the staff report to the "Proposed Identification of Trichloroethylene as a Toxic Air Contaminant" (ARB, 1990b) contributed towards the Board's decision to Identify trichloroethylene as a Toxic Air Contaminant: o trichloroethylene has been identified as an animal carcinogen and should be regarded as a potential human carcinogen; o trichloroethylene is emitted into the air by a variety of stationary sources In California; o trichloroethylene 1$ detected In the ambient air throughout California; o indoor exposure to trichloroethylene may be a major route of exposure for many people; and o trichloroethylene has an atmospheric lifetime estimated to range from four to 15 days. C. VINYL CHLORIDE On December 13, 1990 vinyl chloride was Identified as a Toxic Air Contaminant by the Board. As a result of the Board's action, it 1$ recommended that vinyl chloride be moved from Subcategory IIA to Category I. The following information which is presented in the staff report "Proposed Identification of Vinyl Chloride as a Toxic Air Contaminant" (ARB, 1990c) contributed towards the Board's decision to identify vinyl chloride as a Toxic Air Contaminant: o there is strong evidence that exposure to vinyl chloride results in animal and human carcinogenicity; o vinyl chloride is listed as a Federal Hazardous Air Pollutant; o vinyl chloride is detected in the ambient and indoor air near known emission sources of vinyl chloride; and o vinyl chloride does not break down in the atmosphere at a rate that would eliminate public exposure. 0. CHLOROFORM On December 13, 1990 chloroform was identified as a Toxic Air Contaminant by the Board. As a result of the Board's action, it is recommended that chloroform be moved from Subcategory IIA to Category I. The following information which is presented in the staff report "Proposed -10- SL 063409 Identification of Chloroform as a Toxic Air Contaminant" (ARB, 1990d) contributed towards the Board's decision to identify chloroform as a Toxic Air Contaminant: o chloroform has been identified as an animal carcinogen and should be regarded as a potential human carcinogen; o chloroform is emitted into the air by a variety of stationary sources in California. It is emitted indoors and can give rise to concentrations that are greater than outdoor levels; o chloroform is detected in the ambient air throughout California; and o chloroform has an atmospheric lifetime (based on its reaction with hydroxyl radicals) estimated to range from 150 to 230 days. E. STYRENE It is recommended that styrene be moved from Subcategory IIB to Subcategory IIA. The purpose for this change Is to reflect that styrene is currently under review for identification as a Toxic Air Contaminant. A formal request for a health effects evaluation of styrene was sent to the California Department of Health Services on April 4, 1990 (Appendix D). The decision to review styrene for Identification as a Toxic Air Contaminant was based on the following information: o the International Agency for Research on Cancer has listed styrene in Group 2B of their weighting scheme (IARC, 1987). Substances In Group 2B of IARC's weighting scheme are considered possible human carcinogens; o limited monitoring data show that styrene is detected In the ambient air at toxics monitoring stations located throughout California; o styrene is emitted in substantial amounts in California (COEA, 1990). California emissions for reporting facilities In 1989 are estimated at approximately 1.7 million pounds; o there are Individual facilities operating in California that emit significant amounts of styrene (BAAQMD, 1990). Eleven facilities in the Bay Area Air Quality Management District are each estimated to emit over 10,000 pounds of styrene per year; and o based on its reaction with hydroxyl radical, the daytime atmospheric lifetime of styrene is estimated at approximately three hours (Atkinson, 1989). Therefore, styrene does not break down in the atmosphere at a rate sufficient to eliminate public exposure. -11- SL 063410 F. COKE-OVEN EMISSIONS It Is recommended that coke-oven emissions be moved from Subcategory IIB to Subcategory IIIB. The purpose of this recommendation is to reflect the fact that there are no known emission sources of "coke-oven emissions" operating in California. The Environmental Protection Agency (EPA) defines "coke-oven emissions" as emissions that are emitted directly from a coke oven (49 FR 36560). Based on EPA's definition there are no sources of "coke-oven emissions" in California (ARB, 1991). 6. INORGANIC LEAD It is recommended that inorganic lead be moved from Subcategory IIB to Subcategory IIA. The purpose for this change Is to reflect that inorganic lead is currently under review for identification as a Toxic Air Contaminant. A formal request for a health effects evaluation was sent to the Department of Health Services on February xx, 1991 (Appendix E). The decision to review inorganic lead for identification as a Toxic Air Contaminant was based on the following Information: o the International Agency for Research on Cancer has listed lead and inorganic lead compounds in Group 2B of their weighting scheme (IARC, 1987). Substances In Group 2B of IARC's weighting scheme are considered possible human carcinogens; o monitoring data show that lead is detected In the ambient air throughout California; o lead and lead compounds e emitted in substantial amounts in California (COEA, 1990). California emissions for reporting facilities In 1989 are estimated at 75,533 pounds for lead and 23,756 pounds for lead compounds; o there are Individual facilities operating In California that emit significant amounts of lead or lead compounds (BAAQMD, 1990). Several facilities in the Bay Area Air Quality Management District are estimated to emit over 50 pounds per year with one facility estimated to emit 520 pounds per year; and o exposure to lead and lead compounds may also occur through noninhalation pathways (e.g., soil ingestion). As a result, risk assessments prepared under the Air Toxics "Hot Spots" Information and Assessment act are to address inhalation as well as noninhalation exposure and risk to lead and lead compounds (CAPCOA, 1991). -12- SL 063411 II. PROPOSED.CHANGES TO DEFINITIONS AMD LIST FRAMEWORK A. CATEGORY DEFINITIONS The ARB staff proposes to revise the definitions for Category II and III of the Toxic Air Contaminant Identification List of substances. The recommendation to revise the list category definitions reflects comnents made by the SRP on December 4, 1990. In addition, over 800 letters presenting the proposed revisions to the list were sent out to the interested public for review and comment (Appendix B). The comments received as well as ARB staff responses are presented in Appendix C. 1. Revisions to Category II definition Category II on the February 1990 Toxic Air Contaminant Identification List is defined as "Substances currently under review for Identification as Toxic Air Contaminants, scheduled for review, or nominated for review but not yet scheduled. It will be necessary to develop Information on exposure in California to some substances in this category before pursuing review." The February 1990 list Includes two Subcategories (IIA and IIB). Subcategory IIA includes "Substances already in the review process." Subcategory IIB includes "Substances not yet under review." It is recommended that the definition for Category II be revised to state that Category II includes "Substances currently under review or nominated for review for identification as Toxic Air Contaminants." In addition, it is recommended that Subcategory IIA be revised to state that it represents "Substances already in the review process" and Subcategory IIB be revised to state that it represents "Substances nominated for review." The purpose of the revisions to Category II and Subcategory IIA and IIB is to clarify the role of Category II. Specifically, the purpose of Category II is to identify those substances that are currently in the -13- SI* 063412 identification process of the Toxic Air Contaminant Program (IIA) and those substances which have been nominated for review as Toxic Air Contaminants (IIB) and as such are undergoing further evaluation to determine if and when movement to Subcategory IIA is appropriate. 2. Rgyjs tons ..to Category III definition Category III on the February 1990 Toxic Air Contaminant Identification List is defined as "Compounds for which health effects information is limited or not yet sufficient to support review. Substances in this category are produced and emitted to the air in quantities which might make them of concern at such time as health effects information is strong enough to support review." It is recommended that the definition for Category III be revised to state that Category III includes "Substances which ere being evaluated for entry Into Category II (IIA or IIB). Factors considered In this evaluation include carcinogenic and noncarcinogenic health effects, emissions and exposure In California." The purpose of the revisions to Category III Is to clarify that substances associated with carcinogenic and/or noncarcinogenic health effects are included and evaluated for nomination for review as Toxic Air Contaminants. The revised definition Is also clearer as to the factors that are evaluated prior to nominating a substance for review as a Tcxic Air Contaminant. B. CHANGES TO LIST FRAMEWORK Addition of Subcategory IlIA-and J1IB It Is recommended that two Subcategories (IIIA and IIIB) be added to the Toxic Air Contaminant Identification List. The primary purpose of this change 1$ to address recent amendments to section 112 of the Federal Clean Air Act. Amendments to the Federal Clean Air Act. On November 15, 1990, the President of the United States signed Into law amendments to the Federal Clean Air Act. The amendments are broad In scope and will impact federal, state, and local air pollution control programs on a number of fronts. However, one of the amendments has a direct and Immediate impact on ARIi's Toxic Air Contaminant Identification List. Specifically, the amendments to the Federal Clean Air Act identify 189 substances as Hazardous Air Pollutrts. Prior to the amendments, eight substances were listed as Hazardoi r Pollutants. These amendments are important to ARB's list because Ca nia Health and Safety Code section 14SL 063413 39655 states that substances which have been identified as Hazardous Air Pollutants pursuant to section 7412 of Title 42 of the United States Code shall be identified by the Board as Toxic Air Contaminants. Thus, it is appropriate to incorporate the new Hazardous Air Pollutants into the Toxic Air Contaminant Identification List. Add Hazardous Air Pollutants to Category III. Including the new Hazardous Air Pollutants on the Toxic Air Contaminant Identification List will allow ARB staff to prioritize the substances for evaluation. Rather than listing all of the Hazardous Air Pollutants under Category III, it was determined that including two Subcategories (IIIA and IIIB) would be a more effective approach for evaluating and selecting substances for review as Toxic Air Contaminants. The purpose of the subcategories is to separate substances based on available data. Using this approach, those substances with available emissions information would be placed into Subcategory IIIA and as a result be further evaluated for entry into Category II sooner than those substances in Subcategory IIIB. Use of emissions data. Emissions information was identified as an effective tool for initially separating substances under Category III. Emissions information was selected for placing substances In Category III because emissions information is an indicator of potential public exposure, emissions information is currently available from some local air pollution control districts that maintain air toxics inventories, emissions information for air toxics 1$ reported In response to federal law, and a comprehensive emissions database at the state level is currently under development. Emissions information for thousands of facilities submitted in response to state law (the Air Toxics "Hot Spots" Information and Assessment Act of 1987) will be incorporated into an ARB maintained database over the next several years. Section C, Emissions Data Used to Categorize New Substances, discusses the emissions information that was used to place substances into Category III. Subcateaorv IIIA. For the reasons discussed above It Is recommended that Subcategory IIIA and IIIB be added to the list. Subcategory IIIA states that it includes "Substances known to be emitted in California (Includes Hazardous Air Pollutants Identified in the Federal Clean Air Act known to be emitted In California)." As indicated, Subcategory IIIA is to include Hazardous Air Pollutants as well as other substances for which California emissions data are available. Subcategorv IIIB. The proposed Subcategory IIIB is to state that it includes "Substances identified as Hazardous Air Pollutants in the Federal Clean Air Act for which California emissions information is not currently available." -15- SL 063414 C. EMISSIONS DATA USED TO CATEGORIZE NEW SUBSTANCES In order to place the new Hazardous Air Pollutants Into the proper Subcategory (IIIA or IIIB) as well as Identify additional substances for placement into Subcategory IIIA, it was necessary to review California emissions data. l. Mhtt .ml mans .data were., used? To ensure that substances known to be emitted In California wure included on the list, the most comprehensive sources of information were used. The emissions data that were relied upon Included: the Bay Area Air Quality Management District's Air Toxics Inventory for emissions year 1989/1990 (BAAQMD, 1990); the Toxic Chemical List developed pursuant to Title III, section 313 of the Superfund Amendments and Reauthorization Act of 1986 for emissions year 1989 (COEA, 1990); the South Coast Air Quality Management District's Air Toxics Inventory for emissions years 1982 and 1984 (SCAQMD, 1983; SCAQMD, 1985); and summaries of preliminary emissions information, collected under the Air Toxics "Hot Spots" Information and Assessment Act of 1987 (AB 2588) for emissions year 1989. Th* Air Toxics "Hot Spots" Program information was informally provided by local air pollution control districts to the ARB staff for purposes oi revising the Toxic Air Contaminant Identification List. To obtain the emission data reported under AB 2588, the- ARB staff surveyed California's 41 local air pollution control districts. A number of districts provided a summary of emissions Information for facilities that submitted inventory reports under the program. However, the data provided in the survey do not reflect formal transmittal of AB 2588 inventory reports by districts to the ARB staff. 2. Bow mm .the .aitss.1ant-data, used? The emissions data reviewed to update the list were used to answer a basic question; that Is, what substances are emitted to the air In California? For Federal Hazardous Air Pollutants that were not included on the February 1990 list, the answer to the question on emissions determined whether the substance was placed in Subcategory IIIA or IIIB. For air pollutants, other than the Federal Hazardous air Pollutants that were not included on the February 1990 11 ;t, the answer to the question on emissions was used to determine what additional substances should be placed into Subcategory IIIA. D. EFFECT OF REVISED CATEGORY DEFINITIONS The purpose of this section is to summarize the effect the revised definitions have on the list. The revisions to the Category II definitions -16- SL 063A15 do not affect the status of substances on the proposed list. However, as presented in Chapter I, the status of certain substances in Category I and II has changed due to progress in the Toxic Air Contaminant Program during 1990. The revision to the Category III definition has resulted in the addition of Federal Hazardous Air Pollutants to Subcategory IIIA and IIIB. In addition, if California emissions data are available, substances which are not Hazardous Air Pollutants were also placed in Subcategory IIIA. The number of substances that have been added to Category III (IIIA and IIIB) is discussed under Section E. E. SUMMARY OF PROPOSED CHANGES TO THE LIST As a result of the recommended changes to the list, there are 232 substances on the Proposed February 1991 Toxic Air Contaminant Identification List. The February 1990 Toxic Air Contaminant List Included 62 substances. Thus, we are proposing to add 170 substances to the list. The Proposed February 1991 Toxic Air Contaminant Identification List includes: 14 substances In Category I; nine substances In Subcategory IIA; 22 substances in Subcategory IIB; 117 substances in Subcategory IIIA; and 70 substances in Subcategory IIIB. Table 2 summarizes the results of revising the list to Include Subcategory IIIA. Based on the proposed revisions, 117 substances are listed in Subcategory IIIA. However, fifteen of the substances (acrolein, allyl chloride, benzyl chloride, chlorobenzene, chlorophenols, cresols, glycol ethers, maleic anhydride, manganese, methyl bromide, methyl chloroform (1,1,1-trichloroethane), nitrobenzene, phenol, vlnylldene chloride, and xylenes) were present In Category III of the February 1990 Toxic Air Contaminant Identification List. Table 3 summarizes the results of revising the list to include Subcategory IIIB. Based on the proposed revisions, 70 substances are listed in Category IIIB. However, two of these substances were previously present on the February 1990 Toxic Air Contaminant Identification List; one was listed in Subcategory IIB (coke-oven emissions) and the other was listed in Category III (chloroprene). F. LISTING OF SUBSTANCES AND SUBSTANCE CATEGORIES Table 4 (this table, which provides the same information as Table 1, is presented again for the reader's convenience) lists the 232 substances that are included on the February 1991 Proposed Toxic Air Contaminant Identification List. The table also specifies which category or subcategory each substance is in. -17- 063416 Table 2 Summary of Substances in Proposed Subcategory illA r Substances previously in Category III Hazardous Air Pollutants with emissions data Other pollutants with emissions data Total substances in Subcategory IllA 71 46 b 117,c J a These 19 subetenoes which war* previously In Category W of fhe February 19M Toxic Air Contaminant ktenattcation Uat aro alao Hazardous Air Pollutante. b - Thaaa pollutante which ara not Federal Hazardous Air Pollutanta were added to the Hat baaad on available CaWomla amiaaiona data. c - Thla total otliT aubataneaa tncludaa 15 aubataneaa that wara pravloualy In Category HI of tha February 1990 Toxic Air Contaminant Identification Uat Table 3 Summary of Substances In Proposed Subcategory IIIB r Substances previously in Subcategory IIB Substances previously in Category 111 a 1 b 1 Hazardous Air Pollutants without emissions data 70 Total substances in Subcategory IIIB 70it J a - Coke oven amiaaiona which It a Hazardous Air Pollutant was moved trom Subcategory lie to Subcategory IIIB because there are no known emission sources In California. b Chloroprene wsa previously listed In Category III of the February 1990 Toxic Air Contaminant Identification Uat. c - Thla total of 70 aubataneaa Includes one substance that was pravloualy in Category III (chloroprene) and f substance that was previously In Subcategory in (coke-oven emissions) of tha February 1990 Toxic Air Contaminant ldentific?tir . t. -18- SL 063417 Table 4 Proposed Toxic Air Contaminant Identification List February 1991 I. Substances identified as Toxic Air Contaminants by the Air Resources Board, pursuant to the provisions of AB 1807. Asbestos Benzene Cadmium (metallic cadmium and cadmium compounds) Carbon tetrachloride Chlorinated dioxins and dibenzofurans (15 species) Chloroform Chromium VI Ethylene dibromide Ethylene dichloride Ethylene oxide Inorganic arsenic Methylene chloride Trichloroethylene Vinyl chloride II. Substances currently under review or nominated for review for identification as Toxic Air Contaminants. A. Substances already in the review process. Acetaldehyde Benzo(a)pyrene 1,3-Butadiene Diesel exhaust B. Substances nominated for review. Formaldehyde Inorganic lead Nickel and nickel compounds Perchloroethylene Styrene Acrylamide Acrylonitrile Beryllium compounds Dialkylmtrosamines p- Dichlorobenzene 1,1 -Dlmethylhydrazine Di(2-ethylhexyl)phthalate 1,4-Dioxane Dimethyl sulfate Environmental tobacco smoke Ethyl acrylate Hexachlorobenzene Hydrazine Mercury compounds 4,4'-Methytenedianiline N-Nitrosomorpholine PAHs PCBs Propylene oxide Radionuclides Toluene diisocyanates 2,4,6-Trichlorophenol ill. Substances which are being evaluated for entry into Category II (IIA or MB). Factors considered in this evaluation include carcinogenic and noncarcinogenic health effects, emissions and exposure in California. A. Substances known to be emitted in California (includes Hazardous Air Pollutants identified in the Federal Clean Air Act known to be emitted in California). Acetone Acetonitrile Acrolein Acrylic add Ally! chloride Aluminum Ammonia Ammonium nitrate Ammonium sulfate Antimony compounds Arsenic compounds Barium compounds Benzoyl chloride Benzyl chloride Biphenyl Bis(2-ethylhexyl) adipate Bromine compounds (inorganic) Butyl acrylate Butyl benzyl phthalate Captan Carbon black extracts Carbaryl Carbon disulfide Carbonyl sulfide -1 Q_ Catechol Chlorinated fluorocarbons Chlorine Chlorine dioxide Chloroacetic add Chlorobenzenes Chlorophenols Chromium compounds Cobalt compounos Copper compounds Creosotes Cresols/cresylic acid (isomers and mixtures) Crystalline silica SL 063418 Subcategory IIIA Continued Cumene hydroperoxide Cyanide compounds Cyclohexane Cumene 2,4-0 (salts and asters) Diamlnotoluene (mixed isomers) Dibenzofuran Dibutylphthalate Decabromodlphenyl oxide 1,3-Dichloropropene Dichlorvos Oicofoi Diethanolamine Dimethyl phthalate 4,6-Dinitro-o-creeol (and salts) Epichiorohydnn 1,2-Epoxybutane Ethyl benzene Ethyl chloride Ethylene glycol Ethylene thiourea Gasoline vapors Glutaratdehyde Glycol ethers Hexachlorecydohexanes Hexaehloroethane Hexane Hydrochloric add Hydrogen fluoride Hydrogen sulfide Hydroqulnone Isopropyl alcohol 4,4'-lsopropylldenediphenol lead compounds Maleic anhydride Manganese compounds Methanol Methyl bromide Methyl chloride Methyl ethyl ketone Methyl hydrazine Methyl isobutyl ketone Methyl methacrylate Methyl ten-butyl ether Methylene diphenyl dflsocyanata Molybdenum trioxide rvButyl alcohol Nitrobenzene 2-Nitropropane Nitric add NiWotnaceOc add Paratton Peracetic add Phenol 2-Phenylphenol Phosphine Phosphoric add Phosphorus Phthalic anhydride 1,3-Propane suitone ProptonakJehyde Propoxur Propone Propylene dlchlonde sac-Butyl alcohol Silver compounds Sodium hydroxide Sulfuric acid Titanium tetrachloride Terephthalle acid tert-Butyl alcohol Thiourea Toluene 1,1,1-Trichloroethane 1,2,4-Trimethy ibenzene 2,2.4-Trimethylpentane Vinyl acetate Vlnylldene chloride Xylenee (o. m. p) Ztnc compounds B. Substances identified as Hazardous Air Pollutants in the Fedorsl Clean Air Act tor which California amissions Information is not currently available. Acetamide Acetophenone 2-Acetylaminofluorene 4-Aminobi phenyl Amline o-Anisidine Benzidine Benzotrichloride Bts(chkxomethyi)ether Bromolorm Calcium cyanamlde Caprolactam Ohioramben Chlordane 2-Chloroaoetophenone Chlorobenzilate Chloromethyl methyl ether Chloroprene Coke-oven emissions DDE Diazomethane 1,2-Dibromo-3-chloropropane 3,3'-Dichlorobenzidine Dichloroethyl ether Diethyl sulfate 3,3`-Dimelhoxybenzidlne Dimethytaminoazobenzene 3,3`-Dimethyl benzidine Dimethyl carbamoyl chloride Dimethyl tormamide 2,4-Dlrvtropheool 2,4-DMbotoluena 1,2-Dlphenylhydrazine Ethyl carbamate Ethylene irnlne Ethylidene dtchtortde Fine mineral libers Heptachior Hexachlorobutadiene Hexachlorocydopentadiene Hexmelhylene-1,6-diisocyanate Hexamethylphoephoramide Isophorone Lindane Methoxychlor 4,4'-Methylene bis(2-chloroaniline) Methyl iodide Methyl isocyanate N,N-Dimethy!aniline 4-Nitrobiphenyl 4-Nitrophenol N-NItroso-N-methyl urea Pentachioroni&obenzane p-Phenylenediamine Phosgene Polycyclic organic matter beta-Propiofactone 1.2-Propylenimlne Quinoline Quinane Selenium compounds Styrene oxide 1,1,2,2-Tetrachloroethane 2.4-Toluene diamine o-Toluidine Toxaphene 1,1,2-Trichloroethane Triethylamine Trilluralm Vinyl bromide SL 063A19 4. The list includes several individual substances (e.g., p- dichlorobenzene) and classes of substances (e.g., chlorobenzenes). As with this example, a listed substance may belong to a substance category which is also listed. The purpose of the apparent double-listing is to reflect where substances and substance categories are in the Toxic Air Contaminant Program. For example, p-dichlorobenzene and hexachlorobenzene are in Subcategory IIB and as such have been nominated for review for identification as a Toxic Air Contaminants. However, chlorobenzenes (other than p-dichlorobenzene and hexachlorobenzene) is in Subcategory IIIA and as such will be evaluated for entry into Category II (HA or IIB). Based on future evaluation of chlorobenzenes (see Chapter III concerning the selection of substances for identification), the ARB staff may recommend that the entire class or a specific chlorinated benzene(s) be elevated to Category II. -21- SL 063420 in. FUTURE DIRECTION A. THE LIST OF SUBSTANCES During 1991, the ARB staff plans to evaluate emissions data to determine if additional substances should be added to the list of substances. The primary source of emissions information that will be used for this purpose will be that submitted under the Air Toxics "Hot Spots" Program. Uic of AB 2588 emissions data Currently, districts throughout California have received hundreds of comprehensive emissions inventory reports submitted by facilities complying with the requirements of the Air Toxics "Hot Spots" Program. This information will be formally transmitted to the ARB staff during 1991 where it will undergo further evaluation before being made available to the public through the Air Toxics Emission Data System. When complete, this information will be one of the most comprehensive sources available for determining If a particular substance Is emitted in California. B. PRIORITIZATION OF SUBSTANCES In setting priorities for which substances should be evaluated and regulated as Toxic Air Contaminants, the ARB staff in consultation with the Department of Health Services is to give priority to substances based on factors relating to the risk of harm to public health, amount or potential amount of emissions, manner of usage in California, persistence in the atmosphere, and ambient concentrations in the community (Health and Safety Code section 39660 (f)). Taking these factors into account and in consultation with the SRP and local air pollution control districts, the ARB staff maintains and updates the list of substances. 1. Use of AB 2588 emissions data One of the primary sources of emissions information relied upon to prioritize substances for identification is that submitted in response to the requirements of AB 2588. -22- SL 063421 2. Use of health effects data We also rely on the most recent Information available concerning adverse health effects of substances under evaluation. The ARB staff will continue to coordinate prioritization activities with the Department of Health Services to ensure that the best available health effects data are used. One source of information that will be relied upon Is the CAPCOA Air Toxics "Hot Spots" Program Risk Assessment Guidelines. The guidelines, which were developed for the Hot Spots Program, Include health guidance values for both carcinogenic and noncarcinogenlc health effects. The health guidance values in these guidelines are based on recommendations by the Department of Health Services and are updated on an annual basis. Other sources of health effects information that will be relied upon include literature developed by the International Agency for Research on Cancer, the National Toxicology Program, and the Environmental Protection Agency. Another source of information that will be used is the Integrated Risk Information System (IRIS). The IRIS is an on-line computer database which provides Information such as chemical properties and carcinogenic and noncarclnogenic health effects data for a number of substances. 3. Use of ambient monitoring data Currently, the ARB monitors for over 30 toxic substances at 20 monitoring stations located at sites throughout California. Results from these monitoring efforts will also be used to prioritize substances. In addition to data from ARB's toxics monitoring network, monitoring data collected by air pollution control districts, researchers and others is utilized in our prioritization efforts. 4. Utf .of inforwt loti-on-atmospheric, lifetimes of substances Finally, we also make use of Information on the atmospheric persistence of substances being evaluated. ARB staff will obtain Information on the atmospheric persistence of substances from ARB sponsored-research as well as the published literature. -23- SL 06342 REFERENCES ARB, 1991 California Air Resources Board, 1991., Memorandum from Beth Schwehr of the Air Resources Board to Janette Brooks of the Air Resources Board concerning coke-oven emissions In California, January 28, 1991. ARB, 1990a California Air Resources Board, "Proposed Identification of Inorganic Arsenic as a Toxic Air Contaminant." Staff Report. May 1990. ARB, 1990b California Air Resources Board, "Proposed Identification of Trichloroethylene as a Toxic Air Contaminant." Staff Report, Executive Summary, August 1990. ARB, 1990c California Air Resources Board, "Proposed Identification of Vlnvl Chloride as a Toxic Air Contaminant." Staff Report/Executive Summary, October 1990. ARB, 1990d California Air Resources Board, "Proposed Identification of Chloroform as a Toxic Air Contaminant." Staff Report/Executive Summary, September 1990. Atkinson, 1989. "Atmospheric Lifetime and Fate of Stvrene." A report submitted in partial fulfillment of California Air Resources Board Contract No. A732-107, "Lifetimes and Fates of Toxic Air Contaminants in California's Atmosphere." November 1989. BAAQMD, 1990 "Current BAAOMD Air Toxics Inventory. October 27. 1990." prepared by the staff of the Bay Area Air Quality Management District, October 27, 1990. CAPC0A, 1991 Ca.,1 ifom.ia Air Pollution Control Officers Association (CAPC0A1 Air Toxics "Hot Soots" Program Risk Assessment Guidelines, prepared by the AB 2588 Risk Assessment Committee of CAPC0A, January 1991. -24- SL 063423 COEA, 1990 The Toxic Chemical List developed pursuant to Title III, section 313 Preliminary Toxic Chemical Release Inventory, Superfund Amendments and Reauthorization Act of 1986., 1989 emissions information reported to the California Office of Environmental Affairs. December 1990. 49 FR 36S60 Federal Register Notice, 49 FR 36560, No. 182, Tuesday, September 18, 1984, "National Emission Standards for Hazardous Air Pollutants; Addition of Coke Oven Emissions to the List of Hazardous Air Pollutants." IARC, 1987. IARC Monograph on the Evaluation ofL the Carclnooen1c,,R1slt_of . Chemicals in Humans. Supplement 7. International Agency for Research on Cancer, 1987. SCAQMD, 1983 "Engineerino Division Report on Emissions of Potentially Toxic/Hazardous Air Contaminants in the South Coast j^ir lasin." South Coast Air Quality Management District, September 30, 1983. SCAQMD, 1985 "Engineering Division Report on Emissions of Potentially. Toxic/Hazardous Air Contaminants in the South Coast. Air Basin. 1984 Update." South Coast Air Quality Management District, September 21, 1985. -25- SL 063424 APPENDIX A FEBRUARY 1990 TOXIC AIR CONTAMINANT IDENTIFICATION LIST SL 63425 I. II. III. TOXIC AIR CONTAMINANT IDENTIFICATION LIST FEBRUARY 1990 Substances Identified as toxic air contaminants by the Air Resources Board, pursuant to the provisions of AB 1807. asbestos, benzene, cadmium, carbon tetrachloride, chlorinated dioxins and dlbenzofurans (IS species), chromium (VI), ethylene dlbromlde, ethylene dlchlorlde, ethylene oxide, methylene chloride Substances currently under review for Identification as toxic air contaminants, scheduled for review, or nominated for review but not yet scheduled. It will be necessary to develop Information on exposure In California to some substances In this category before pursuing review. A. (Substances already In the review process.) acetaldehyde. benzo(a)pyrene, 1.3-butadlene, chloroform, diesel exhaust, formaldehyde. Inorganic arsenic, nickel, perchloroethylene, trichloroethylene, vinyl chloride B. (Substances not yet under review.) acrylamide, acrylonitrile, beryllium, coke-oven emissions, dlalkylnltrosamines, p-d1 chlorobenzene, 1,1-dImethy1hydraz1ne, d1(2-ethylhexy1)phtha1 ate, 1,4-dloxane, dimethyl sulfate, environmental tobacco smoke, ethyl acrylate, hexachlorobenzene, hydrazine. Inorganic lead, mercury, 4,4'-methylenedianil1ne, N-nltrosomorphollne, PANs, PCBs, propylene oxide, radionuclides, styrene, toluene dlIsocyanates, 2,4,6-trlchlorophenol Compounds for which health effects Information Is limited or not yet sufficient to support review. Substances In this category are produced and emitted to the air In quantities which might make them of concern at such time as health effects Information Is strong enough to support review. acrolein, allyl chloride, benzyl chloride, chlorobenzene, chlorophenols, chloroprene, cresols, glycol ethers, maleic anhydride, manganese, methyl bromide, methyl chloroform, nitrobenzene, phenol, vinylIdene chloride, xylenes A-l SL 063426 APPENDIX B REQUEST FOR INFORMATION ON THE TOXIC AIR CONTAMINANT PROGRAM LIST SL 063427 i t cf ;*n*o*Nii a q RESOURCES 102 2 $T#fIT ' rj SO* 10'3 *C#AMtnTO 5il2 BOARD (3 orge 0ukffl|lon. cn. December D5, 1990 Dear Sir or Madam: Request for Information on the Toiic Air Contaminant Program List The purpose of this letter is to request Information for use in updating the Toxic Air Contaminant Identification List of Substances. The proposed list (Attachment I) is used to assist the Air Resources Board with the selection of substances for entrance into the Toxic Air Contaminant Identification Process. In addition to requesting information for use in updating the list, we are requesting your review and comment on proposed changes to the Toxic Air Contaminant Identification List of Substances. The specific changes that we propose to make to the list, including the basis for the change, are provided below: Automatic Changes Inorganic arsenic, trichloroethylene, chloroform, and vinyl chloride have been moved from Category IIA to Category I because they have been identified by the Air Resources Board as Toxic Air Contaminants (TACs). In addition, styrene has been moved from Category IIB to Category IIA because it has formally entered the identification phase of the process. Proposed Changes to Category II We are proposing to revise the definition of Category II to state that the substances in Category II are either under review for identification as TACs (IIA) or nominated for review for Identification as TACs (IIB). The purpose of this change is to provide a clearer definition for Category II. The previous definition for Category II can be found on the February 1990 Toxic Air Contaminant Identification List (Attachment II). 3-1 SL 063428 -2- TecemDer 2*_. prnaosed Changes to Category III We ere also proposing to revise Category III to state that it includes substances being evaluated for entry into Category II (IIA or IIB).' The definition also states that factors considered in the evaluation include carcinogenic and noncareinogenic health effects, emissions and exposure in California. The purpose of this revision is to provide a more accurate definition of the factors that are considered prior to entry into Category II. The definition is also clearer in conveying the fact that the substances in Category III may be associated with carcinogenic and/or noncareinogenic health effects. For Category III we propose having two subcategories: IIIA and IIIB. Category IIIA would include Federal hazardous air pollutants as well as additional substances for which California emissions data are available. Category IIIB would only include hazardous air pollutants for which California emissions data are not available. The purpose of Including Category IIIA and IIIB is due to recent amendments to the Federal Clean Air Act. The amendments which were signed by the President in mid-November identify 189 substances as hazardous air pollutants. Because California Health and Safety Code Section 39655 states that substances identified as hazardous air pollutants shall be Identified by the Air Resources Board as Toiic Air Contaminants, revisions to the list are needed. The proposed revisions to the definition for Category III will provide the necessary framework for Incorporating the hazardous air pollutants into the Toxic Air Contaminant Identification List. Emissions Information for Revising Cateoorv III In order to develop the draft proposed list of substances (Attachment I), staff reviewed three air toxics emissions databases: 1) Title III, Section 313 of the Superfund Amendments and Reauthorization Act (emissions year 1989); 2) the Bay Air Quality Management District's Air Toxics Inventory (October 27, 1990); and 3) the South Coast Air Quality Management District's Air Toxics Inventory (1983 and 1984 update). Based on Information in the aforementioned toxics databases, hazardous air pollutants were placed in Category IIIA (emissions in California) or Category IIIB (no California emissions data). Currently, we are surveying local air pollution control districts to obtain information on the emission of toxic pollutants reported under the Air Toxics "Hot Spots" Information and Assessment Act of 1987. We plan to also use this information in updating the Toxic Air Contaminant Identification List. b-2 SL 063429 -3- '-cemoer :-??o We request that you provide any information or conments to us by January 9, 1991. Please send the information to the following address: Richard Corey Special Projects Section/SSD Re: Toxic Air Contaminant Identification List California Air Resources Board P.0. Box 2815 Sacramento, CA 95812 The information received from this request will be evaluated for use in preparing a draft report for updating the list of substances. We expect the draft report to be available in mid-February. If you are interested in obtaining a copy please fill out the attached request (Attachment III) and return to Richard Corey at the noted address. If you have any questions regarding this request for information and comments, please call Janette Brooks, Manager of the Special Projects Section, at (916) 322-9148 or Richard Corey of her staff at (916) 327-5631. Sincerely cc: Scientific Review Panel for Toxic Air Contaminants Attachments Peter D. Venturini, Chief Stationary Source Division B-3 SL 063430 Attachment I Proposed Toxic Air Contaminant identification i f* December 1990 I. Substances identified ss Toxic Air Contaminants by the Air Resources Board, pursuant to the provisions of AB1807. AeOtBIbe Oman* Cadmium Cation levecWortde CNorinaad dtodna and abonzofcrano (IS poc*es) CNoratonm CtaemtumVI EWyttno dbromde EVtytene dichtonde Efttyenoondo Inorgemc ar*ene Mettytene efdoride Trtddoroeityene Vkiytcfclonde II. Substances currently under review or nominated for review for identification as Toxic Air Contaminants. A. Substances already in the review process. Benzo(a)pyione i.9>Buiadano Otael exftauet B. Substances nominated for review. Nickel PercMoreeViyiene Styrene Aoryiarride AorytorWie Beryttum Coke-oven emission* Olatkykiowmin** p-OteMorobenzene i.i-Dtmemytiydman* Oi(2-eiylhexyl)pMhelaie 1,4-Otoxane Mnetiyl sultat* Ejwwonmenai tobacco smek* Eliytaayiate Haxaohtorobonzene Hydrazna morgante lead MMOMy 4.4' MoHytonodiondno N-Nflroeomorpnoi.ne PAH* PCBo Propytana oxide Radionuclide* Tokren# diaoeyanate* 2.4.6-TrtcMoropnonol iii. Substances which are being evaluated for entry into Category II (HA or llB). Factors considered in this evaluation include carcinogenic and noncarcinogenie health effects, emissions and exposure in California. A. Substances known to be emitted in California (includes hazardous air pollutants identified in the Federal Clean Air Act known to be emitted In California). Aeotvto AcMoneie Aczyiamde Aoyieaacl Allyl tftionde Aluminum Ammonia Ammonium r Ammonium tm Antimony oompc it Anthracene Amomc compound* Bantm compound* Bonzoyt chloride Bonzyl ehlonde Biphenyl Bi(2"*lhythexyi) adipate Butyl acrylate Butyl benzyl phtnaiate Captan Casoaryi Carbon disulfide Caroonyl suttide Catechol -1 CNodnated Huoroeartoons Chlorine CNonne dioxd* CMoraaeeoc aod Chlorobenzenes Chromium compounds Cobalt compounds Copper compounds Cresola/cretyiic acid (isomers and mixtures) Cienene hydroperoxide Cyanide compound* SL 063431 Category IIIA Continued Cyclohexane Cumene 2.4-0 (saib and esters) DWtwnotoiuene {mixed CHbenzoturen Dfeutytphmauna OecabromoOphenyt end* 1.2-0lehtofoeihane 1.3-0teMo(ocrop*n DicNotvoa Otoharwlamlne Dimethyl phthalaia Dimethyl suite* 4.6-Dinitro-o^reaot (and sale) Epfchlorohydrtn 1.2-Epoxybutane Etfryl benzene Ethyl ehionde Ehytene glycol Ehytena hiourea Qaaobna Glycol ether* HaxacNoraahana Hydrochloric aad Hydrogen fluonde Hydrogan auihde Hydrogurone laopropyi alcohol M'-laoprapyManaaphanyi Laad compound* Maleic anhydride Moiganeee compounds Mananol Methyl bromide Metiyl Chlande Metyt ehyt katana Mebyl hydrazine Methyl laooutyl ketone Matiyi mamacrytata Mahyl tart butyl ether Mehytene diphenyl diaocyanata PrWfOwWn IIUHW N-Butyl alcohol Napntialano 2-Nltrapropane NMcaod NMHotrtaoaoc aod Paratnien Pentacmoropnanoi Peraoaocaod Phenol 2-Phenyl phenol Phoaphonc aad Phthellc anhydride Propozur Propano Propytana dKNonda see-Butyl Mcahot Saver compounds Sullutcaad Tttanwni tavatfiionde TerephhMieaad Tan-Butyl alcohol Thiourea Toluana 1.2.4- Triddorabanzana l.l.Mrlchloroathana 1.2.4- Tfjmahytoafuana VtnyHdene chloride Xylansa (o. m. p) Zkte compowids B. Substance* identified a* hazardous air pollutants in the Federal Clean Air Act for which California emissions Information Is not currently available. Aeetamde Aoaiophanona 2-Aoatytammolluorene Acrolein 4-Amnot*phenyl Anllina o-AnieMine Benzidine Benzotnchioride BM2-e*oraan*na) Bta<chloromehyl)eiher Bramotorm CScfcim cyanamlda Caprolactam CNoramben Chlordana 2-Chloroaoaiophanona Chlorotoenzital# CWoromethyt methyl ether Chloroprana DOE Diazomethane 1.2- Dibromo- 3-chloropropane 3.3- Dichloroeenztoene Dichloroethyl ether Diethyl suitste 3.3- Dimetnoxybenztdine Dimethyl aminoazobenzene 3,3*-0imahyl banadina Olmediyt carbamoyl chloride Dtmehyl tarmamde 1,1 -Obnyhythydrazine 2.4- PinlVcphenol 2.4- Diraffotoiuene 1,2-0lphanytydrazina Ehytarbama* ciiyvni iiwh CViyilM-n-V- Oj|WIlUrInO|-V| I Rn vnmraHIbm H4pQN0f HMAcNoratouttditnA HaxachloracyciopantadMna Hoxamathyiena-i 6-diaocyanate Hexarnetftyipnotpnoramde Hexane laaphorona Undana Mathoxychlor Methyl iodide Methyl isocyanatB N.N-Diethyl anmne Nitrobenzene 4-NitrooiQhenyi 4-NHrophenol N-Nieoeo-N-mathyl urea W'WsWIHjsiyflmsli N-Nltceomorphotine Penactsororwobenzene p-Phenytenediamne PhoapMna Phoaphorua Phoagana 1.3-Propane euNana PotycycHc organic maitar beta-Proproiactone Ptopnnaldahyda 1.2-Propyienenme Quinoline Qianone Selenium compounds Styrene oxide i. 1,2.2-Tetrachloroethane 2.4-Toluene dlamme o-ToKjidina Toxaphene 2.4.S-Trichlorophenol 1.1.2-Trichloroetnane Triethylamina Tntturalin 2.2.4-Tnmethyipentane Vinyl bromide -2- P- c ^ 063432 I. II. III. Attachment II TOXIC AIR CONTAMINANT IDENTIFICATION LIST FEBRUARY 1990 Substances Identified as tosic air contaminants by the Air Resources Board, pursuant to the provisions of AB 1807. asbestos, benzene, cadmium, carbon tetrachloride, chlorinated dioxins and dibenzofurans (IS species), chromium (VI). ethylene dibromide, ethylene dichloride, ethylene oxide, methylene chloride Substances currently under review for identification as toxic air contaminants, scheduled for review, or nominated for review but not yet scheduled. It will be necessary to develop information on exposure in California to some substances in this category before pursuing review. A. (Substances already in the review process.) acetaldehyde, benzo(a)pyrene, 1,3-butadiene, chloroform, diesel exhaust, formaldehyde, inorganic arsenic, nickel, perchloroethylene, trichloroethylene, vinyl chloride B. (Substances not yet under review.) acrylamide, acrylonitrile, beryllium, coke-oven emissions, dlalkylnltrosamlnes, p-dlchlorobenzene, 1,1-dimethy1hydrezine, di(2-ethy1hexy 1)phthalate, 1,4-dloxane, dimethyl sulfate, environmental tobacco smoke, ethyl acrylate, hexaehlorobenzene, hydrazine, inorganic lead, mercury, 4,4'-methy1ened1anil1ne, N-nitrosomorpholfne, PAHs, PCBs, propylene oxide, radionuclides, styrene, toluene diIsocyanates, 2,4,6-tr1chloropheno1 Compounds for which health effects information is limited or not yet sufficient to support review. Substances in this category are produced and emitted to the air in quantities which might make them of concern at such time as health effects Information is strong enough to support review. acrolein, allyl chloride, benzyl chloride, chlorobenzene, chloropheno Is, chloroprene, cresols, glycol ethers, maleic anhydride, manganese, methyl bromide, methyl chloroform, nitrobenzene, phenol, vinylidene chloride, xylenes SL 063433 Attachment III REQUEST FORM for Toxic Air Contaminant Identification List Update To order a copy of the above report please supply your name and address below: Name of Individual and Company Address City, State, Zip Code PLEASE PRINT OR TYPE CLEARLY Return this form to: Richard Corey Special Projects Sectlon/SSO Re: Toxic Air Contaminant Identification List California Air Resources Board P.0. Box 2815 Sacramento, CA 95812 B-7 SL 063434 APPENDIX C COMMENTS RECEIVED FROM PUBLIC WITH STAFF RESPONSES SL 063435 APPENDIX C COMMENTS RECEIVED FROM PUBLIC WITH STAFF RESPONSES TABLE OF CONTENTS 1. January 10, 1991 letter from Dr. Geraldine V. Cox of the Chemical Manufacturers Association to Richard Corey of the Air Resources Board (Air Resources Board staff response attached) 2. January 8, 1991 letter from R. Bruce Dickson of the Law Offices of Paul, Hastings, Janofsky, & Walker to Peter D. Venturlnl, Chief of the Stationary Source Division, of the Air Resources Board (Air Resources Board staff response attached) 3. January 8, 1991 letter from Jonathon T. Busch of the Chemical Manufacturers Association to Peter D. Venturini, Chief of the Stationary Source Division, of the Air Resources Board (Air Resources Board staff response attached) 4. January 8, 1991 letter from Dr. Geraldine V. Cox of the Chemical Manufacturers Association to Richard Corey of the Air Resources Board (Air Resources Board staff response attached) 5. January 4, 1991 letter from Mark Poindexter of the Kings County Air Pollution Control District to Peter D. Venturini, Chief of the Stationary Source Division, of the Air Resources Board (Air Resources Board staff response attached) 6. January 8, 1991 letter from Paul Buttner of Resource Management International, Incorporated to Richard Corey of the Air Resources Board (Air Resources Board staff response attached) 7. January 3, 1991 letter from Dr. R. J. Barnhart of the Chrome Coalition to Richard Corey of the Air Resources Board (Air Resources Board staff response attached) 8. January 3, 1991 letter from Dr. Thomas A. Robinson of Vulcan Chemicals to Richard Corey of the Air Resources Board (Air Resources Board staff response attached) 9. January 10, 1991 letter from John C. Paulsen of U. S. Borax to Richard Corey of the Air Resources Board (Air Resources Board response attached) C-l SL 063436 CHEMICAL MANUFACTURERS ASSOCIATION Geraldine V Cox. Ph.D Vice PresiOent-Tecnmcai DifeclOf January 10, 1991 Via Federal Express Mr. Richard Corey Special Projects Section/SSD California Air Resources Board 1219 K Street Sacramento, California 95814 Re: Toxic Air Contaminant Identification List Dear Mr. Corey: The Carbon Disulfide Panel (Panel) of the Chemical Manufacturers Association (CMA) submits these coanents in response to the California Air Resources Board's (ARB) request for information for use in updating the Toxic Air Contaminant (TAC) Identification List of Substances. Summary and Recommendation The Panel recognizes that carbon disulfide must be listed as a TAC pursuant to Section 39655 of the California Health and Safety Code because it has been identified as a "hazardous air pollutant" under the Clean Air Act Aamndments of 1990. Emissions of carbon disulfide reported In California are very low, however, and the Panel urges that the ARB give carbon disulfide a priority atatus commensurate with these low emission levels when the ARB establishes its list of priorities pursuant to Section 39660(f) of the California Health and Safety Code. *See letter from P. Venturini (Dec 26, 1990). Although Mr. Venturini's letter requested that constants be received on or before January 9, 1991, the Panel understands from Ms. Janette Brooks, Manager of the Special Projects Section, that comments received on or before January 11, 1991, will be considered by ARB in its preparation of a draft report for updating the list of substances. *'Cn. t * r C-2 . ^afl'" 'VI Toio* AQA1T SL 063437 Mr. Richard Corey January 10, 1991 Page 2 The Carbon Disulfide Panel The Carbon Disulfide Panel is part of the Chemical Self-funded Technical Advocacy and Research Division (CHEMSTAR) of the Chemical Manufacturers Association (CMA). CHEMSTAR panels are formed to initiate research, conduct advocacy and/or monitor federal, state and international activities pertinent to the chemical about which the Panel is concerned. Carbon Disulfide Panel members include Akzo Chemicals Inc., Courtaulds Fibers Inc., Flexel, Inc., North American Rayon Corporation, PPG Industries, Inc., Teepak, Inc. and Viskase Corporation. Panel members manufacture carbon disulfide or use it in their respective manufacturing processes. The Panel thus has an interest in this rulemaking, and welcomes this opportunity to introduce itself to the ARB and present its views on this matter. Comments Pursuant to California Health and Safety Code Section 39655, substances identified as "hazardous air pollutants" under the federal Clean Air Act's national emission standards for hazardous air pollutants (NESHAPs) program, must be identified by the ARB as "toxic air contaminants" under the state program. Carbon disulfide is included on the list of hazardous air contaminants in Title III (hazardous air pollutants) of the Clean Air Act Amendments of 1990. Accordingly, the ARB has proposed to include carbon disulfide in Category II of the TAC list. According to Mr. Venturini's letter, substances included in Category IIIA are federal hazardous air pollutants (and other substances) for which California emissions data are available. Reportedly, there are three databases that were reviewed to determine whether substances should be placed on the Category IIIA (emissions in California) or Category IIIB (no California emissions data) list: the Superfund Amendments and Reauthorization Act (SARA) Section 313 Toxics Release Inventory (TRI) (emissions year 1989); the Bay Area Quality Management District's Air Toxics Inventory (October 27, 1990); and the South Coast Air Quality Management District's Air Toxics Inventory (1983 and 1984 update). The Panel understands that carbon disulfide was placed in Category IIIA solely on the basis of TRI emissions data, and that neither the Bay Area nor the South Coast database has data that are accessible specific with respect to carbon disulfide emissions in California. According to the TRI database, sources in Conversation with L. Bergeson, legal counsel to the Panel, and Ms. Janette Brooks, January 4, 1991. C-3 SL 063438 Mr. Richard Corey January 10, 1991 Page 3 California reported a total of 27,680 pounds of carbon disulfide released in 1989. Conclusion Pursuant to California Health and Safety Code Section 39660(f), the ARB and the California Department of Health Services (DHS) must establish priorities for evaluation and control of candidate substances based on the risk of harm to public health, the amount of or potential aaount of emissions, the manner of usage of the substance, its persistence in the atmosphere, and ambient concentrations of the substance in the community. Baaed on the very low emission levels of carbon disulfide reported in California, the Panel believes carbon disulfide properly belongs at the bottom of the list of priorities to be established under Section 39660(f), and that regulatory action of any kind with respect to evaluating and/or controlling carbon disulfide as a toxic air contaminant is unwarranted. The Panel appreciates this opportunity to submit comments on this important matter. If you have any questions regarding these comments, please call Susan R. Howe of my staff at (202) 887*1293. Geraldine V. Cox, Ph.D. Vice President-Technical Director cc: Mr. Paul Kronenberg, CICC 3,The California Office of Environmental Affairs reported this total includes releases from two facilities: Amvac Chemical Corporation; air-408 pounds, P0TW -250, off-site-500 pounds; and, Columbian Chemical Company: air-26, 522 total 27.680 total pounds. SL 063439 C-4 CALIFORNIA AIR resources board ;'C2 0 STREET p,0. SOX 2815 SACRAMENTO. CA 95812 PETE IILSOH, Governor February 8, 1991 Geraldine V. Cox, Ph.D. Vice President-Technical Director Chemical Manufacturers Association 2501 M Street, N.W. Washington, D.C. 20037 Dear Dr. Cox: Comments on the Proposed Toxic Air Contaminant Identification List Thank you for your January 10, 1991 letter in which you provided information concerning carbon disulfide. Specifically, you recommended that carbon disulfide receive a low priority when the Air Resources Board evaluates substances for entry into the Toxic Air Contaminant Identification Program. The primary basis for your recommendation is that reported emissions of carbon disulfide in California are very low. As you know, we plan to use the proposed Toxic Air Contaminant Identification List to select substances for review as Toxic Air Contaminants. Selecting substances for review will Include a detailed evaluation of information concerning emissions in California, exposure, toxicity, and the atmospheric persistence of the listed substances. Based on this evaluation, specific substances will be entered into the review process or nominated (i.e., entered into Category II) for review as Toxic Air Contaminants. The evaluation of the listed substances will Involve use of the best information available. For example. In response to the requirements of the Air Toxics "Hot Spots" Information and Assessment Act of 1987, thousands of facilities throughout California are submitting comprehensive emissions information on hundreds of toxic substances. The Air Resources Board staff will use the most current Air Toxics "Hot Spots" Program data available when evaluating substances for entry into Category II. Until substances on the proposed list are evaluated in this type of detail, it is premature to determine whether carbon disulfide will be recommended for placement into Category II of the Toxic Air Contaminant Identification List or remain in Subcategory IIIA. The Air Resources Board staff plans to evaluate substances in Category III during 1991 and to reevaluate the list in subsequent years. SL 063AAO iieraldine V. Cox, Ph.D. -2- February 8, 199 Thank you for taking the time to respond to our request for information. If you have any questions regarding this letter or the. proposed Toxic Air Contaminant Identification List, please call me at (916) 322-9148. Sincerely, rooks. Manager al Projects Section SL 063441 C-6 .[[ O *UL AOSC*'*' * "AtTlNO* ,CO*>4*0 * v*NO'UT ,,o* angci-c* office 555 50UTW rLOwCB STREET -Oi anGElE*. CALIFORNIA 900*( clc-onc (2iji AU'flooa ohahoc cOyNTv office ess town center o*ivc COSTA W(SA, CALIFORNIA 9texa TCi-ER^ONE (7IAI 641-1100 WEST ^OS ANOLLES OFFICE '209 OCCAN AVCNUC SANTA MON'CA. CALIFORNIA OOAOl TClCAmONC (2131 ABl'llOO WRITER'S iRECT Dial numRER 202-457-9423 LAW OFFICES OF Paul, Hastings, Janofsky & Walker A AMTNC**MlF INCLuO<N9 PdOrtlllONAh CORPORATIONS twelfth FLOOR 1050 CONNECTICUT AVENUE, N. W, WASHINGTON, D. C. 20036 TELEPHONE (202) 223*9000 TWX 7iO - 922 - 9092 TCHCOFltF: 1202) AB2-9IA9 January 8, 1991 ATLANTA OPFlCC CCOROlA.AACiFiC CENTER 133 RCACmTAcC Street, n c, ATLANTA, GECRO'A 30303 telephone iaq4i etS'Seoc CONnCCT'CoT office ONC CANTC*Sg*y GREEN STAMFORO, CONNECTICUT 0#90i TClCFwOnC <*03) 37-OiOO NEW OR Office 9 WEST ST-* STREET NEW YORK. NEW FORA iOQIQ TELEPHONE <2i2) 93S-9IOO TOKYO OFFICE TORAnOMQn OwTORl Builoinc *-J. toranOmon i-chomc MINATO-Ru, TOKYO 109 TEWCRHONE (03) 107-0730 OUR FilC NQ Peter D. Venturini, Chief Stationary Source Division Air Resources Board 1102 Q Street P. O. Box 2815 Sacramento, California 95812 Re: Request for Information on the Toxic Air Contaminant Program List Dear Mr. Venturini: We are writing as counsel to the Chlorobenzene Producers Association (CPA) to provide comments on the proposed revision to Category III of the Proposed Toxic Air Contaminant Identification List, which you sent to me last week. You have added category III and have included a recitation of factors considered in the evaluation of substances for inclusion in Category II. We believe that your inclusion of factors raises several questions and should be deleted. As your letter acknowledges, California Health and Safety Code, Section 39655 states that substances identified by the federal legislation as hazardous air pollutants shall be identified by the ARB as Toxic Air Contaminants. Thus regardless of the toxicity of these substances, they must be listed. However, if the proposed caption for Category III is finalized, the inclusion of a substance in that category SL 063442 jaix Hastings. Janofsky & Walker Peter D. Venturini, Chief January 8, 1991 Page 2 might imply an unintended finding by ARB regarding toxicity endpoints (carcinogenic or noncarcinogenic health effects). Because all Clean Air Act hazardous air pollutants must be included as toxic air contaminants, regardless of any toxicity finding, the presence of a substance on the federal list should be mentioned as an additional factor. In the alternative, you could delete the listing of "factors considered." Category III could simply provide: "Substances which are being evaluated for entry into category II (IIA or IIB)." If you have any questions, please do not hesitate to contact us. very truly yours, RBD:cs R. Bruce Dickson Counsel to the Chlorobenzene Producers Association SL 063443 CALIFORNIA ATR RESOURCES BOARD : ;:2 Q STREET P.o. SOX 2815 SACRAMENTO, CA 95812 PETE HIISON, Governor February 8, 1991 R. Bruce Dickson Counsel to the Chlorobenzene Producers Association Law Offices of Paul, Hastings, Janofsky & Walker 1050 Connecticut Avenue, N.W. Washington, D.C. 20036 Dear Mr. Dickson: Comments on the Proposed Toxic Air Contaminant Identification List Thank you for your January 8, 1991 letter to Mr. Venturini in which you commented on the proposed revision to the definition for Category III. You state that the proposed definition for Category III may imply an unintended finding regarding the potency or toxicity of the substances listed under Category III (IIIA or IIIB). The proposed revision to the definition for Category III is to clarify the factors that will be considered when substances listed under Category III are evaluated for entry into Category II (IIA or IIB). Specifying the factors considered during the evaluation does not infer knowledge about the toxicity or potency of substances listed under Category III. The basis for listing substances under Category III is specific. Subcategory IIIA consists of "Substances known to be emitted in California (includes Hazardous Air Pollutants identified in the Federal Clean Air Act known to be emitted in California)." Subcategory IIIB consists of "Substances identified as Hazardous Air Pollutants in the Federal Clean Air Act for which California emissions information is not currently available." We believe that we are providing important information to the public by listing the factors that are considered prior to elevating substances from Category III to Category II. By defining Category III this way, the list can stand alone from the staff report which describes how substances are moved up in priority. SL 063444 R. Bruce Dickson 2- - February 8, 1951 Thank you for taking the time to respond to our request for information. If you have any questions regarding this letter or the. proposed Toxic Air Contaminant Identification List, please call me at (916) 322-7072. Sincerely, Senevleve Shiroma, Chief Toxic Air Contaminant Identification Branch c-io SL 063445 CHEMICAL MANUFACTURERS ASSOCIATION January 8, 1991 DECEIVED .IflW 1 0 *qqi Sloliunui p Sown Division 'IrBatourcmSar ' Peter D. Venturini, Chief Stationary Source Division Air Resources Board 1102 Q Street P. 0. Box 2815 Sacramento, California 95812 Re: Response to Request for Information on the Toxic Air Contaminant Program List Dear Mr. Venturini: I am writing on behalf of the Chemical Manufacturers Association Vinylidene Chloride Panel in response to the request for information on the proposed revision to Category III of the Proposed Toxic Air Contaminant Identification List contained in your December 16, 1990 letter to the Panel's counsel, R. Bruce Dickson, last week. You have added Category III and have included a recitation of factors considered in the evaluation of substances for inclusion in Category II. We believe that your inclusion of factors for inclusion in Category II is incomplete and should be revised or deleted. As your letter acknowledges, California Health and Safety Code Section 39655 states that substances identified by the federal legislation as hazardous air pollutants shall be identified by the ARB as Toxic Air Contaminants. Thus, regardless of the toxicity of these substances, they must be listed. However, this criterion is not included in the list of factors considered in the evaluation of substances. If the proposed changes to Category III are finalized, the inclusion of a substance might imply an unintended finding by ARB regarding toxicity endpoints (carcinogenic or noncarcinogenic health effects). Because all Clean Air Act hazardous air pollutants must be included as toxic air c ntaminants, the presence of a substance on the 2501 m Sfeei NW Wasnmaton DC 20037 202-8S7-1100 Teiex 89617 iCMA W$H) SL 06344 federal list should be mentioned as an additional factor. In the alternative, you could delete the listing of "factors considered . Category III could simply provide: "Substances which are being evaluated for entry into Category II (IIA or IIB)." If you have any questions, please do not hesitate to contact me at 202/887-1189. Very truly yours, Jonathon T. Busch Manager Vinylidene Chloride Panel C-12 SL 063447 STtT: -jF CALIFORNIA aiTresources board ;102 0 STREET = 0 30X 2815 SACRAMENTO. CA 95812 PETE WILSON. Governor February 8, 1991 Jonathon T. Busch, Manager Vinylidene Chloride Panel Chemical Manufacturers Association 2501 M Street, N.W. Washington, D.C. 20037 Dear Mr. Busch: Comments on the Proposed Toxic Air Contaminant Identification List Thank you for your January 8, 1991 letter to Mr. Venturini in which you commented on the proposed revision to the definition for Category III. You state that the proposed definition for Category III may imply an unintended finding regarding the potency or toxicity of the substances listed under Category III (IIIA or IIIB). The proposed revision to the definition for Category III is to clarify the factors that will be considered when the substances listed under Category III are evaluated for entry into Category II (IIA or IIB). Specifying the factors considered during the evaluation does not infer knowledge about the toxicity or potency of substances listed under Category III. The basis for listing substances under Category III is specific. Subcategory IIIA consists of "Substances known to be emitted in California (includes Hazardous Air Pollutants identified in the Federal Clean Air Act known to be emitted in California)." Subcategory IIIB consists of "Substances identified as Hazardous Air Pollutants in the Federal Clean Air Act for which California emissions information is not currently available." We believe that we are providing important information to the public by listing the factors that are considered prior to elevating substances from Category III to Category II. By defining Category III this way, the list can stand alone from the staff report which describes how substances are moved up in priority. f-1 SL 063448 Jonathon T. Busch, Manager 2- - February 8, 1991 Thank you for taking the time to respond to our request for information. If you have any questions regarding this letter or the. proposed Toxic Air Contaminant Identification List, please call me at (916) 322-7072. Sincerely, Genevieve Shlroma, Chief Toxic Air Contaminant Identification Branch ^ * SL 063449 CHEMICAL MANUFACTURERS ASSOCIATION Geraldine V Co*. Ph 0 Vice Pres'Oeni-Tecnmcai Director January 8, 1991 Richard Corey Special Projects Section/SSD Re: Toxic Air Contaminant Identification List California Air Resources Board P.O. Box 2815 Sacramento, CA 95812 Dear Mr. Corey: I am writing on behalf of the Chemical Manufacturers Association ("CMA") Cobalt Panel in response to a letter of December 26, 1990, from Peter D. Venturini, requesting information on CAJRB's Toxic Air Contaminant Program List. The CMA Cobalt Panel was formed in 1989 to interact with regulatory agencies, like the Air Resources Board, and other organizations that may have occasion to address health, safety, and environmental issues involving the production, processing, transportation, use, handling, and disposal of cobalt and cobalt compounds. Panel members include various producers, processors, and users of cobalt and cobalt chemicals. The Cobalt Development Institute is an honorary member of the Panel and contributes its knowledge and expertise to Panel activities. Attachment I to Mr. Venturini's letter of December 26, 1990 is a proposed list which is to assist the Air Resources Board in selecting substances ''for entrance into the Toxic Air Contaminant Identification Process." An entry for "Cobalt compounds" is included in Category III.A. on the proposed list. This means that "Cobalt compounds," like the other substances that are listed in Category III, will be evaluated for entry into Category II, where they will be reviewed, or nominated for review, for identification as Toxic Air Contaminants. We understand from Mr. Venturini's letter that "Cobalt compounds" and more than 100 other chemicals or chemical groups are being added to Category III because they have been identified as hazardous air pollutants under the federal Clean Air Act Amendments of 1990, not because there has been any finding that SL 063450 2 they present a significant risk to the general public in California as a result of emissions to the ambient air. In that connection, we wish to make two points. First, the fact that 189 chemicals or chemical groups were added to the federal list of hazardous air pollutants by Congress does not mean that all of these chemicals present a significant air pollution-based health risk to the general public in California or elsewhere in the United States. In contrast to those chemicals that were identified as hazardous air pollutants by the U.S. Environmental Protection Agency ("EPA") in earlier years, the newly listed chemicals have not been scientifically reviewed and evaluated by EPA (or, for that matter, by Congress) to determine the nature and magnitude of the risk, if any, that emissions of the chemicals present to public health. Many of the newly listed chemicals (or individual compounds within named compound groups, like "Cobalt compounds") may present no public health risk of any consequence whatsoever as a result of emissions to the ambient air. Second, Congress implicitly recognized this first point, by establishing a delisting mechanism in Section 112(b)(3) of the Clean Air Act, as amended. Under that delisting procedure, any person may petition EPA to delete either (i) a listed substance having a CAS number or (ii) a unique chemical substance within a listed compound group, e.q., a particular cobalt compound within the listed group "cobalt compounds". We anticipate that delisting petitions will be filed under Section 112(b)(3) for a variety of listed pollutants and/or unique chemical substances within listed compound groups. Delisting petitions for unique chemical substances within a listed compound group are most likely to be filed within the next nine months, since EPA may not promulgate an emissions standard applicable to such a chemical if it is the subject of a pending delisting petition filed within 12 months of enactment of the Clean Air Act Amendments. In short, the fact that a particular substance or group of compounds has been listed as a hazardous air pollutant by Congress in the Clean Air Act Amendments of 1990 does not mean that the chemical actually presents a significant public health risk as a result of emissions to the ambient air. Nor does it mean that the chemical will remain on the list of hazardous air pollutants under the federal Clean Air Act. The Air Resources Board should bear these points in mind as it makes future SL 063451 3 decisions on identifying substances for review as possible Toxic Air Contaminants in California. The Panel appreciates this opportunity to comment on this important matter. If you have any questions regarding these comments, please call Ms. Susan R. Howe of my staff at (202) 887-1293. Sincerely your, cc: Paul Kronenberg, CICC tSeraldine V. Cox, Ph.D. Vice President-Technical Director 017 SL 063452 TATE JE CALIFORNIA AIR RESOURCES BOARD 1102 Q STREET 3.0. BOX 2815 SACRAMENTO, CA 95812 _ ____ ________________Govgrn'' February 8, 1991 Geraldine V. Cox, Ph.D. Vice President-Technical Director Chemical Manufacturers Association 2501 M Street, N.W, Washington, D.C. 20037 Dear Dr. Cox: Conrnents on the Proposed Toxic Air Contaminant Identification List Thank you for your January 8, 1991 letter fn which you provided coiments concerning the addition of "Cobalt compounds" to the proposed Toxic Air Contaminant IdentifIcatlon List. Specifically, you stated that emissions of substances listed as Hazardous Air Pollutants (HAPs) under Section 112 of the Federal Cleon Air Act may not represent a significant risk to the public. You also stated that the Air Resources Board (ARB) should bear this in mind when making future decisions on selecting substances for review as Toxic Air Contaminants. As you know, we are proposing to add all of the HAPs to our list because we are required by state law to identify these substances under our Toxic Air Contaminant Program. We are In agreement that air emissions of some of these HAPs may not represent a significant health risk to the public in California. As acknowledged In your letter, substances in Category 111 will be evaluated for entry Into Category II based on those substances which pose the greatest potential health Impacts. We understand that there Is a delisting provision for HAPs listed under Section 112 of the Federal Clean Air Act. If California emissions data are available for a substance In Subcategory II1A which the Environmental Protection Agency (EPA) removes from Its list. It may be removed from the Toxic Air Contaminant Identification List due to consideration of health effects information including that which formed the basis for EPA's delisting as a HAP. However, if a substance, which Is currently in Subcategory IIIB of the Toxic Air Contaminant Identification List, is deleted from the list of HAPs It will in turn be removed from the Toxic Air Contaminant Identification List. If California emissions data becomes available, a substance previously removed from Subcategory IIIB of the Toxic Air Contaminant Identification List due to Its delisting as a HAP may be added to Subcategory IIIA of the list. C-18 SL 063453 Geraldine V. Cox, Ph.D. 2- - February 8, 1991 Thank you for taking the time to respond to our request for information. If you have any questions regarding this letter or the. proposed Toxic Air Contaminant Identification List, please call me at (916) 322-9148. Sincerely, JapWlte Brooks, Manager Special Projects Section *O SL 63454 COUNTY OF KINGS AIR POLLUTION CONTROL DISTRICT SHELDON R. MINKIN, D. 0 \1R foiumrw control officer 330 CAMPUS DRIVE HANFORD, CALIF. 93230 (209) 584-1411 January 4, 1991 Peter Vanturini, Chiaf St ationary Sourea Division Air Resources Board 1102 Q Street P.0. Bom 2815 Sacramanto, CA 95812 SUBJECT! Requested Information - Toxic Air Contaminant List In reviewing tha Dacambar 1990 Proposad Toxic Air Contaminant Identification list, I noted one substance for which wa have additional information. Hexane is in category III B - substances for which California amissions information is not currently available. One source of hexane emissions is vegetable oil extraction plants. There is one such facility in Kings County which produces safflower and cotton seed oils. It is in the ARB's emission inventory as facility #6 in Kings County. Emissions data was corrected beginning in 1988 to reflect permitted annual emissions of 394 tons and actual annual emissions of 164 tons. These emissions are nearly all as hexane vapor. I have no other comments on the lists or substances listed. know if you have any questions. Let me Sincerely Sheldon R. Minkin, D. 0. Air Pollution Control Officer T- 1'iarK Poindexter Air Quality Engineer N:-`/tC c-20 063^5 SL STATE JF CALIFORNIA AIR RESOURCES BOARD '102 0 STREET P.O. SOX 2815 SACRAMENTO, CA 95812 PETE WILSON, Governor February 8, 1991 Mark Poindexter Air Quality Engineer Kings County Air Pollution Control District 330 Campus Drive Hanford, CA 93230 Dear Mr. Poindexter: Comments on the Proposed Toxic Air Contaminant Identification List Thank you for your January 4, 1991 letter In which you provided hexane emissions information from a facility in your Air Pollution Control District. Based upon the information you provided, hexane has been moved from Subcategory IIIB "Substances identified as Hazardous Air Pollutants in the Federal Clean Air Act for which California emissions Information Is not currently available" to Subcategory IIIA "Substances known to be emitted In California..." Thank you for taking the time to respond to our request for information. If you have any questions regarding this letter or the proposed Toxic Air Contaminant Identification List, please call me at (916) 322-9148. Sincerely, r-71 SL 063456 RMI I! U (H t ! MaNAOIMINT International, Inc. January 8, 1991 Mr. Richard Corey Special Projects Section/SSD California Air Resources Board P. 0. Box 2815 Sacramento, CA 95812 Subject: Review of Category I1IA Compounds Dear Mr. Corey: This is in response to your December 26, 1990 request for information on the Toxic Air Contaminant Identification List. It is clear that the amendments to the Federal Clean Air Act have had a tremendous impact on your program. The Air Resources Board has responded quickly to incorporate the additional substances resulting from the 1990 amendments. I am aware of nine current studies coordinated by the National Toxicology Program (NTP) involving compounds listed in Category QIA. These are long-term animal studies for carcinogenesis conducted by the National Institute of Environmental Health Sciences, Toxicology Research and Testing Program. The substances currently being studied are the following: Substance CAS # 1. Acetone 2. Acetonitrile 3. Dibutylphthalate 4. 1,2-Dichloroethane 5. Diethanolamine 6. Dimethyl phthalate 7. Ethyl benzene 67-64-1 75-05-8 84-74-2 107-06-2 111-42-2 131-11-3 100-41-4 3100 Zinfandel Drive, Slot 600 . Sacramento, CA 95 70 (916) 852 !3L0 . Far 1916) a;> y, - '------ n ^ tesift.c.r 4MFNTO CA 956 ;- 516 063^57 SL. Mr. Richard Corey January 8, 1991 Page Two 8. Ethylene glycol 9. Ethylene thiourea 107-21-1 96-45-7 Additionally, I am aware of two studies scheduled for completion in fiscal year 1989-90 by the same organization. These two substances are the following: Substance CAS #_ 1. Ethyl chloride 2. Hydroquinone 75-00-3 123-31-9 The above information is from a November 1989 NTP document entitled, "Review of Current Department of Health and Human Services, Department of Energy and Environmental Protection Agency Research Related to Toxicology". 1 hope this information is of use in your review of the Toxic Air Contaminant Program List. Please call me if you have any questions or if I may be of further assistance to you. C-23 SL 063458 TATE Cf CALIFORNIA xlR ReSfllliTCES BOARD 102 O STREET .0. BOX 2315 ACfUMENTO, CA 3S8J2 February 8, 1991 PETE IfLSQN, 6ov*rnor Paul Buttner Resource Management International, Inc. 3100 Zinfandel Ortve, Suite 600 Sacramento, CA 95670 Dear Mr. Buttner: Comments on the Proposed Toxic Air Contaminant Identiftcaltan-LI&t Thank you for your January 8, 1991 letter in which you provided information concerning the availability of health effects studies for a number of substances listed on the proposed Toxic Air Contaminant Identification List. As you know, In proposing to revise the Toxic Air Contwainant Identification List, our Intent Is to Incorporate the Federal Hazardous Air Pollutants, and other potentially toxic compounds for which we have available emissions data. Specifically, Federal Hazardous Air Pollutants proposed to be added to the list are placed In Category III. Hazardous Air Pollutants for which California Missions data Is available are placed In Subcategory IIIA while Hazardous Air Pollutants without California Missions data are placed in Subcategory IIIB. In addition, several substances that are not Hazardous Air Pollutants are added to Subcategory IIIA. The basis for proposing to add these substances to Subcategory IIIA Is the availability of Missions Information for California. During 1991, the Air Resources Board staff will evaluate the substances in Category III for entry Into Category II. The factors that will be used to evaluate the substances Include current Information on their respective potencies and toxicities. With the assistance of the California Department of Health Services, we will evaluate the health effects studies cited In your letter. Thank you for taking the time to respond to our request for information. If you have any questions regarding this letter or the proposed Toxic Air Contaminant Identification List, please call me at (916) 322-9148. cc: Melanie Marty, Ph.D., DHS C-24 SL 063 459 CHROME COALITION January 3, 1991 Mr Richard Corey Special Projects Section/SSD California Air Resources Board Post Office Box 2815 Sacramento, California 95812 Re: Toxic Air Contaminant Identification List Dear Hr. Corey: These comments are on behalf of the Chrome Coalition and are in response to the Request for Information on the Toxic Air Contaminant Program List of December 26, 1990. We understand that the listing of chromium compounds as a class of chemi cals in the recent amendments to the Federal Clean Air Act has triggered the same listing in Category III of the Toxic Air Contaminant Identification List. However, it should be recognized that the Clean Air Act list may be modified by the Administrator to delete individual substances or "...one or more uniqu chemical substances that contain a listed hazardous air pollutant not having a CAS number..." We recommend that the draft report updating the list of sub stances consider this possibility and detail how the list would be affected. In particular, we anticipate that one or more petitions will be submitted under the Federal Clean Air Act to delete specific classes of chromium com pounds including trivalent chromium compounds. It should be clarified as to whether a favorable ruling by the Administrator on this type petition would automatically remove these substances from the California list or whether the same information should be submitted to the California Air Resources Board for a separate determination. Since in this particular case trivalent chromium compounds have already been examined by the Air Resources Board and the deter mination made that they are not a Toxic Air Contaminant, we do not believe that this process should have to be repeated unless new, compelling informa tion is introduced* We appreciate this opportunity to comment. Sincerely yours, RJB/sk R. J. Barnhart, Ph.D. Chairman, Chrome Coalition Administered by. INDUSTRIAL HEALTH FOUNDATION, INC. U Penn Circle We*i Piiuburjh, Pi. 152CS SL 063460 STATE OF CALIFORNIA AIR RESOURCES BOARD U02 Q STREET >.Q. BOX 2815 SACRAMENTO, CA 95812 PETE I i LOON, Governor February 8, 1991 R. J. Barnhart, Ph.D. Chairman, Chrome Coalition Industrial Health Foundation, Inc. 34 Penn Circle West Pittsburgh, Pa. 15206 Dear Dr. Barnhart: Comments on the Proposed Toxic Air Contaminant Identificatlfln Lilt Thank you for your January 3, 1991 letter In which you provided comments on behalf of the Chrome Coalition. Specifically, you recommended that the draft report updating the list of substances address how deletions to the list of Federal Hazardous Air Pollutants will be treated. As stated in you letter, the Chrome Coalition anticipates petitioning the Environmental Protection Agency (EPA) to have specific classes of chromium compounds, including trlvalent chromium compounds, removed from the Federal list. As you know, we are proposing to update the Toxic Air Contaminant Identification List by adding substances identified as Hazardous Air Pollutants and additional potentially toxic substances for which California emissions data are available. If the Administrator of the EPA deletes a substance or class of substances from the list of Hazardous Air Pollutants, corresponding changes to the Toxic Air Contaminant Identification List may be appropriate. If California emissions data are available for a substance in Subcategory IIIA which EPA removes from its list. It may be removed from the Toxic Air Contaminant Identification List due to consideration of health effects information including that which formed the basis for EPA's delisting as a Hazardous Air Pollutant. However, If a substance, which is currently in Subcategory 12IB of the Toxic Air Contaminant Identification List, is deleted from the list of Hazardous Air Pollutants It will in turn be removed from the Toxic Air Contaminant Identification List. If California emissions data becomes available, a substance previously removed from Subcategory IIIB of the Toxic Air Contaminant Identification List due to its delisting as a Hazardous Air Pollutant may be added to Subcategory IIIA of the list. 063461 R. J. Barnhart, Ph.D. 2- - February 8, 1991 For chromium compounds, we will take into consideration our previous evaluation on non-hexavalent chromium compounds, depending on any future EPA action to retain or delete "chromium compounds" from its list. Because the Air Resources Board specifically identified hexavalent chromium as a Toxic Air Contaminant, "chromium compounds" remains on the proposed Toxic Air Contaminant Identification List specifically because It is listed as a Hazardous Air Pollutant. Thank you for taking the time to respond to our request for information. If you have any questions regarding this letter or the proposed Toxic Air Contaminant Identification List, please call me at (916) 322-9148. Sincerely, SL 063462 Vulcan CHEMICALS A DIVISION Of VULCAN MATERIALS COMPANY January 3, 1991 P.O. BOX 530390 BIRMINGHAM ALABAMA 35253 0390 (205) 877-3556 THOMAS A. ROtINSON, M.A. MANAGER, regulatory AFFAIRS Mr. Richard Corey Special Projects Section/SSD California Air Resources Board P. O. Box 2815 Sacramento, CA 95812 Re: Toxic Air Contaminant Identification List Dear Mr, Corey: This letter is in response to Mr. Venturini's letter of December 26, 1990 which contained proposed changes to the Toxic Air Contaminant Identification List. In reviewing the proposed revision, we noted that ethylene dichloride is listed as a Category I substance, while 1,2-dichloroethane is listed as a Category IHA substance. Ethylene dichloride and 1,2-dichloroethane are one and the same chemical and one of the above listings should be deleted. Sincerely yours, VULCAN CHEMICALS Thomas A. Robinson, Ph.D. am C-28 SL 063463 STATl ;r CALIFORNIA AIR RESOURCES BOARD 1102 0 STREET p 0. BOX 2815 SACRAMENTO, CA 95812 PETE VILSOM. Governor February 8, 1991 Thomas A. Robinson, Ph.D. Vulcan Chemicals P.0. Box 530390 Birmingham, Alabama 35253-0390 Dear Dr. Robinson: Comments on the Proposed Toxic Air Contaminant Identification List Thank you for your January 3, 1991 letter In which you connented that a substance was listed twice. Specifically, you stated ethylene bichloride and 1,2-dlchloroethane are the same chemical and one of the listings should be deleted. You are correct In pointing out that ethylene bichloride, which has been Identified as a Toxic Air Contaminant by the Air Resources Board and as such Is listed In Category I, is the same chemical as 1,2-dlchloroethane which Is listed In Subcategory IIIA. In response to your conment we are removing 1,2-dichloroethane from Subcategory IIIA. Thank you for taking the time to respond to our request for information. If you have any questions regarding this letter or the proposed Toxic Air Contaminant Identification List, please call me at (916) 322-9148. Sincerely, c-29 SL 63464 ILSBuHAX January 10, 1991 Hr. Richard Coray Special Projects Section/SSD California Air Raaourcaa Board P.O. Box 2815 Sacramento, CA 95812 RE: TOXIC AIR CONTAMINANT IDENTIFICATION LIST Dear Mr. Coreyt This letter is to draw your attention to an apparent redundancy in the referenced list as proposed. "Inorganic arsenic", as listed in Category I, has been identified as a TAC. It is noted however, that "Arsenic compounds" as listed in category III A as being evaluated for entry into Category II. It is our understanding that the Category I listing for "inorganic arsenic" is synonymous with inorganic "arsenic compounds". A similar situation occurs with "Inorganic lead" (Category II B and "Lead compounds" (Category III A). It is suggested that this listing be clarified to avoid any misinterpretation of the list. Resoectfully. John C, Paulsen Principal Environmental Engineer Government 6 Public Affairs JCPigw , %, . 3 07 WlL*<"Hf*C ttl UUKVASD * LOS ANOtUCS V *t SL 063465 > `%\ STATE TF CALIFORNIA AIR RESOURCES BOARD 1102 2 STREET P.O. BOX 2815 SACRAMENTO. CA 95812 PETE WILSON, Governor February 8, 1991 John C. Paulsen Principal Environmental Engineer Government & Public Affairs U.S. Borax & Chemical Corporation 3075 Wilshire Boulevard Los Angeles, CA 90010-1294 Dear Mr. Paulsen: Comments on the Proposed Toxic Air Contaminant Identification List Thank you for your January 10, 1991 letter in which you provided conroents on the proposed Toxic Air Contaminant Identification List. Specifically, you point out an apparent redundancy in that "inorganic arsenic" is in Category I and "arsenic compounds" is in Subcategory IIIA. In your letter, you also raise a similar point concerning "Inorganic lead" and "lead compounds." You are correct in stating that the Air Resources Board (ARB) has identified inorganic arsenic as a Toxic Air Contaminant. However, inorganic arsenic and arsenic compounds are not synonymous in that there may be arsenic substances emitted in California that are not covered under the category "Inorganic arsenic." Under Section 112 of the Federal Clean Air Act, the Environmental Protection Agency lists "Arsenic compounds (inorganic including arsine)" as a Hazardous Air Pollutant. The ARB evaluated inorganic arsenic Including arsine when it identified Inorganic arsenic as a Toxic Air Contaminant. However, California emissions data Is available for what is referred to as arsenic compounds. Emissions of "arsenic compounds" In California are not necessarily limited to Inorganic arsenic. Thus, "arsenic compounds" is proposed to be listed In Subcategory IIIA. The reason for listing both inorganic lead and lead compounds on the list is similar. Specifically, the category "lead compounds" is listed as a Hazardous Air Pollutant under Section 112 of the Federal Clean Air Act. Because the category "lead compounds" is not limited to inorganic lead, it is necessary to place "lead compounds" on the list. "Lead compounds" is placed in Subcategory IIIA because there is California emissions data for what is referred to as "lead compounds." C-31 SL 063466 John C. Paulsen -2- February 8, 1991 It is possible that the emissions data reported as lead or arsenic compounds Is primarily or even exclusively Inorganic lead or arsenic.However, the limitations of the emissions data do not provide for such a determination at this time. Thus, we believe ttu it is prudent to place lead and arsenic compounds In Subcategory IIIA as opposed to IIIB. Thank you for taking the time to respond to our request for information. If you have any questions regarding this letter or the proposed Toxic Air Contaminant Identification List, please call me at (916) 322-9148. Sincerely, SL 063467 APPENDIX D STYRENE HEALTH EFFECTS EVALUATION REQUEST SI 63A68 State f California MEMORANDUM To Ed Mendoza, Assistant Doputy Director Date April 4, 1990 F Public Haaith Department of Haaith Sarvleas Subject : Haaith Effects 714 P Straat Evaluation of Sacramento, CA 96814 Styrene From Jamas 0. Boyd .Executive OfflIcar Air Rasourcas Board 0 This memorandum is a formal request that the Department of Health Services evaluate the health effects of styrene as a candidate toxic air contaminant In accordance with Haaith and Safety Code Section 39660 ot sea. Attached for your staff's consideration In evaluating styrene are the references on styrene health effects which were Identified In an Air Resources Board (ARB) letter of public Inquiry and provided by the public In response to that letter. Ambient air monitoring of styrene began earlier this year. Although we do not have specific data at this time, we will provide ambient levels data for your staff later this year. According to Health and Safety Code Sections 39660*62, the Department of Health Services has 90 days from receipt of this letter to submit a written evaluation to the ARB with recommendations on the health effects of styrene. If necessary, the Department of Health Services may request a 30 day extension. If you have questions regarding this request, please contact me at 445*4383 or have your staff contact Peter D. Venturlnl, Chief of the Stationary Source Division, at 446-0660. Attachment cc: Jananne Sharpless, Chairwoman, ARB George Alexeeff, DHS, w/Atchs Richard Jackson, DHS, w/Atchs Henry Voss, DFA Members of the Scientific Review Panel Assemblywoman Sally Tanner 1 Senator Ralph Dills Senator Art Torres n-i SL 063469 APPENDIX E INORGANIC LEAD HEALTH EFFECTS EVALUATION REQUEST SL 063470 ite of California :morandum Ed Mendoza, Assistant Deputy Director Public Health Department of Health Services 714 P Street Sacramento, California 95814 Date : February 21, 1991 Subject : Request for Health Effects Evaluation of Inorganic Lead This memorandum is a formal request that the Department of Health Services (DHS) evaluate the health effects of inorganic lead as a candidate toxic air contaminant (TAC) In accordance with Health and Safety Code Section 39650 et sea. In the past, we provided health effects references and responses to the public information request at the same time we requested a compound's health effects evaluation. For Inorganic lead, your staff are aware that the references from our literature search on health effects will follow this request In a few weeks and that we will forward you responses from the public Information request as we receive them. Ambient monitoring data on lead Is available from our Ambient Air Quality Data Reports. Due to the sampling method used, we expect that these measurements primarily represent ambient inorganic lead concentrations. Please let us know if you intend to identify particular inorganic lead species of health interest as we will need to adjust our monitoring method. According to Health and Safety Code Sections 39660-62, the DHS has 90 days from receipt of this letter to submit a written evaluation to the Air Resourced Board (ARB) with recommendations on the health effects of inorganic lead. If necessary, you may request a 30-day extension. If you have questions regarding this request, please contact me at (916) 445-4383 or have your staff contact Peter D. Venturlni, Chief of the Stationary Source Division, at (916) 445-0650. cc: Jananne Sharpless, Chairwoman, ARB George Alexeeff, DHS Richard Jackson, DHS Henry Voss, DFA Members of the Scientific Review Panel Assemblywoman Sally Tanner Senator Ralph Dills Senator Art Torres SL 063471