Air Toxics

MARAMA Fumigation Workgroup – MARAMA manages the members workgroup to share information and practices concerning Fumigation in the region. In 2019, this workgroup merged with the National Fumigation Workgroup, managed by EPA Region 2 & NJ.

MARAMA Emerging Pollutants (EP) Workgroup – Our goal with this workgroup is to learn and share information that pertains to the monitoring, measuring and control of emerging pollutants along with gathering new information and gaining perspective from our neighboring state & local agencies. Some technical and regulatory issues discussed include ethylene oxide (EtO), used for sterilization, Per- and Polyfluoroalkyl Substances (PFAS), found in Teflon and fire-fighting foam, and other toxic air pollutants that emerge like 1-Bromopropane (1-BP) which is the first pollutant to be added to the EPA Hazardous Air Pollutants list. Contact Debbie Wilson or Jenny St. Clair for more information on joining this workgroup.

The next scheduled EP webinars in 2021 are Tuesday, September 14 and November 9 @ 1 PM Eastern.

For general information about, visit PFAS.

Technical Assistance to MARAMA on EPA Cumulative Exposure Project (CEP): Review of Air Toxics Modeling, January 1999, P.T. Roberts, H.H. Main, S.B. Hurwitt, Sonoma Technology, Inc.

EPA’s Cumulative Exposure Project toxics modelingwere reviewed.  Model-estimated concentrations for 1990 of toxic air pollutants were compared with 1996 ambient concentrations in Philadelphia, New Brunswick (NJ), and Baltimore.  Ambient data is from PAMS monitoring sites, which only operate during the summer, while the model estimates are annual averages. Morning data was compared, because a comparison of summer morning data to 24-hour, year-round canister data for 8 HAPs at Philadelphia showed good agreement.  It should be noted that the modeling methods used at the time this report was prepared are not necessarily the same as modeling methods currently used by EPA.  Three overall issues were identified in reviewing EPA’s modeling:

• It is inappropriate to rely on model results at the census-tract level. The model is only reliable over larger areas.
• Expected model performance and uncertainty varies widely by pollutant. Hazardous Air Pollutant (HAP) vary in their emission, chemical reactivity, transport and dispersion, and background characteristics, and all these factors influence model performance.
• EPA modeling guidance for dispersion models indicates that short-term concentrations should be within a factor of two of monitored values, and annual average model performance is expected to be better than short-term estimates. EPA’s own model performance evaluation performed as part of the CEP compared available ambient data for 19 HAPs with model results and found that 68% of the comparisons were within a factor of three. Sonoma raises the question of whether this is acceptable performance.

Sonoma’s comparison of monitored and modeled concentrations in Philadelphia, New Brunswick, and Baltimore led them to several conclusions, including those listed below. Of the HAPs investigated in this study, benzene, formaldehyde, and carbon tetrachloride are the most important with respect to cancer risk based on ambient data. Measured concentrations of these HAPs were well above cancer a risk benchmark of 1 in 1 million lifetime exposure risk.

• Measured concentrations of species highly associated with motor vehicles (e.g., benzene, toluene, and xylenes) were typically within a factor of two or three of the model’s estimates. (The ambient concentration was usually lower than predicted by the model. This is consistent with recent studies showing that benzene has declined in the 1990s due to the use of reformulated gasoline.)
• PAMS carbonyle compound concentrations were typically about twice those modeled. The model chemistry may be inadequate to reflect the secondary formation of carbonyles (e.g., formaldehyde).
• Measured and modeled concentrations of methylchloride and carbon tetrachloride concentrations were similar and were typically at about the level the model assumed as a background concentration. (Data only for Philadelphia.)
• Several differences between modeled and monitored concentrations may indicate problems with emissions factors or activity data used to estimate emissions:
  • Ethylene dibromide was monitored at 20 times the level predicted by the model. The model may be missing key sources. (Data only for Philadelphia.)
  • Measured ethylene dichloride was at least an order of magnitude lower than modeled. Emissions estimates may be overstated. (Data only for Philadelphia.)
• Ambient variability in concentrations is often much greater than reflected in the model.
• Some pollutants are measured at very low concentrations, near the detection limits, of monitoring equipment.

• District of Columbia DOEE’s source-specific HAP standards.

Delaware state-specific language applicable to HAP sources is included in Regulations1100 and 1138 as follows:

• Delaware Toxics Regulation: 7 DE Admin Code 1100 
• Delaware Air Toxics Regulation: 7 DE Admin Code 1138

Delaware started with EPA Part 63 MACT/GACT standards applicable to area sources in Delaware and then revised them to be appropriate for Delaware. A couple of examples follow:

• Sub M (Perc Dry Cleaning) – DE does not exempt coin-operated machines as EPA had done.
• Sub T (Halogenated Solvent Cleaning) – DE included additional operating and design requirements that were already in place for degreasers under Regulation 1124.

Philadelphia AMS – Links to Philadelphia’s air toxics regulation and associated guidelines:

• https://www.phila.gov/media/20181031151841/Control-of-Emissions-of-Carbon-Monoxide-from-Stationary-Sources-REG6.pdf
• https://www.phila.gov/media/20181031153836/AMR-VI-Guidelines.pdf

West Virginia – State Rule 34 adopts selected federal standards related to HAPs. State Rule 27 is for a specific list of toxic air pollutants that are HAPs. State Rule 13 has HAPs limits for permitting purposes.

Rule 13: https://dep.wv.gov/daq/small%20business/Documents/45CSR13_Final.pdf
Rule 27: https://dep.wv.gov/daq/planning/Documents/45-27.pdf
Rule 34: https://dep.wv.gov/daq/rulessummary/Documents/2018%20Final%20Rules/45CSR34_Final.pdf

Some state-specific information on WVDEP’s Division of Air Quality air toxics rules is below:

• West Virginia State Air Toxics Rule 27 (45CSR27)
• West Virginia State Air Toxics Rule 27
• West Virginia State minor source permitting rule – HAPs thresholds
• West Virginia DEP-DAQ Air Toxics webpage

Maryland – MDE

Maryland state-specific language applicable to HAP sources is included in COMAR as follows:

• http://www.dsd.state.md.us/COMAR/SubtitleSearch.aspx?search=26.11.15.*
• http://www.dsd.state.md.us/COMAR/SubtitleSearch.aspx?search=26.11.16.*