Written By Bob Phillips For Neighborhood Net(tm)
News Summary And Background
Memo From Kansas Describing Study Results
Memo From California Suggesting Next Steps
Editorial Opinion: How A Top California Air Quality District Handles Pollution
Response To This Article From JC Environmental Department
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News Summary And Background
Mike Boothe, Johnson County Environmental Department Air Quality Program Manager, has provided NeighborhoodNet with the results of a study conducted by the Kansas Department Of Health And Environment. This study was done at Mike's request to address neighbors' concerns about the emissions from Metcalf Auto Body, which is located near Metcalf and 162nd St. A children's day care center is located close by the autobody shop.
[Editor's note: According to Mike, after reviewing a draft of this article prior to publication, the Environmental Department has decided to write a response. That response will be published on the website.]
The study predicts how the concentrations of one pollutant, toluene, would be dispersed over surrounding areas. Dana Morris, of the Kansas Bureau of Air and Radiation, who conducted the study, pointed out in a telephone interview that toluene is probably the major constituent of the emissions. He also stated that he assumed continuous emission of toluene, which is probably not the case, so actual figures would be lower than those shown.
The bottom line of the study was that over the course of a year, the average concentration of toluene at the day care center would be at levels far below ones considered hazardous. The concentrations would be at 1.6 to 2.5 micrograms per cubic meter (ug/m3). The relevant EPA measurement, called a "reference concentration", is 400 ug/m3. Basically this estimate says if you continuously breathed 400 ug/m3 over your lifetime, there would likely be no appreciable risk of harm to you. The 400 ug/m3 is an estimate that is thought to be within an order of magnitude correct - that means the estimate could be anywhere from, say, 70 ug/m3 to 700 ug/m3, rather than exactly 400 ug/m3, that you could breathe with essentially no risk of harm.
A second map provided by Kansas shows the highest 24 hour concentrations near the day care center. On this map the concentrations at the day care center run from 60 ug/m3 to 100 ug/m3, still well below the 400 ug/m3 reference estimate. Children would not breathe the highest 24 hour concentrations on a continuous basis, of course. The only comparison figure provided for short term exposure hazard was 188,000 ug/m3, which is of course far above anything predicted for the emissions from the autobody shop.
The maps show that the highest concentrations of toluene occur generally just north of the auto body shop. The reason for this is that over the course of the year the average wind direction is northerly, according to Dana. Since winds actually vary, the direction of greatest concentration also would vary. Dr. Lynn Hildemann, an Associate Professor at Stanford University who provided additional information, points out that high concentrations are possible at ground level just downwind of a building because of "building downwash".
The California Bay Area Air Quality Management District (BAAQMD) (see below) states that toluene itself is not considered a toxic air pollutant, so these results are in line with that assessment. Richard Bode, who works for the California Air Resources Board, states in an e-mail to NeighborhoodNet:
"There are many substances with much higher toxicities than toluene in those coatings. You would want your county environmental office to include emissions of these highly toxic substances in their evaluation. Your situation may depend on the operations of the autobody shop near you. Some are clean, with the best control technology and using coatings that have eliminated the most toxic compounds. However, there are also shops that have few controls and use cheap paints with lots of toxic substances."
If there are more toxic substances released by the autobody shop, Dana felt their concentrations would be lower than that of toluene and that their dispersion might be estimated by simply multiplying the concentrations for toluene by the appropriate factors.
The data for the study were obtained by Mike from the paintshop owner, who identified the products being used and the physical characteristics of the building, such as smokestack size and height, and from the German manufacturer of the products. Mike cannot release the full list of ingredients for the products because the manufacturer considers some of them proprietary data. So the full list of ingredients will be returned to the manufacturer without being published. However, NeighborhoodNet will be provided with the list of products in use, along with non-proprietary materials data sheets describing relevant chemicals.
The study itself was originally going to be conducted by experts in Wyandotte County government, but they moved to new positions. Mike eventually identified the Kansas state official, Dana S. Morris, who did agree to perform the study.
Date: January 27, 1998
To: Mike Booth
From: Dana S. Morris
Subject: Dispersion Modeling for Metcalf Auto Body
Dispersion modeling has been conducted to estimate the maximum possible ambient impact of toluene emissions from the Metcalf Auto Body Shop upon the nearby neighborhood and day care center. An emission rate of .95 g/sec (7.54 lb/hr) was used. This corresponds to slightly more than one gallon per hour of evaporative toluene emissions, which is probably more than the facility would emit under normal operation.
Stack parameters were based upon the information you provided. Conservative assumptions were made to obtain missing data where needed. Historical weather data from Kansas City International Airport were used in the analysis. Weather data for calendar year 1989 was used. A review of the results did not show ambient levels of toluene high enough to justify the need to run the analysis for additional years of weather data.
Maximum annual averages at the day care center were predicted to be 1.6 - 2.5 ug/m3 [editor; micrograms per cubic meter]. The ACGIH [editor:American Conference of Governmental Industrial Hygienists] workplace standard for toluene is 188,000 ug/m3. A review of EPS's IRIS database for toluene shows an inhalation reference concentration for toluene of 400 ug/m3. EPA defines the reference concentration as: "the RFC is an estimate (with uncertainty spanning perhaps an order of magnitude) of a daily inhalation exposure of the human population (including sensitive subgroups) that is likely to be without an appreciable risk of deleterious effects during a lifetime." Taking this definition into account, it seemed most appopriate to compare the 24 hr average model output to the EPA RFC.
Printouts of the model output and the information from EPA's IRIS database are attached. Note that in the interest of saving time, conservative assumptions were used to provide the dispersion model with required data. A more detailed analysis would lower the predicted ambient impacts.
Should you have any questions regarding this material, please contact me at (785) 296-1578.
Kansas provided two maps that show the estimated concentration of toluene near Metcalf Autobody. These maps show how much toluene you would expect to find in the air at different distances from the smokestack. Rather than showing a whole bunch of separate points - "50 feet north of the shop you expect 20 ug/m3" - the maps show lines. Everywhere on one line the concentration of toluene is the same. For instance, next to the day care center is a line that says "6". If you stood anywhere on that line, you could expect to find 6 micrograms of toluene in each cubic meter of air.
One of the maps, the "Annual Average Toulene Concentration", shows what you would expect to find on average along each line. So even though the concentration might be 100 ug/m3 one day, it might be 0 ug/m3 on other days, and the average over the year is 6 ug/m3, which is what is shown.
The second map, "Highest 24 hour Touluene concentrations", shows what you would expect to find during the worst 24 hour period during the year. It is of course much worse than the annual average, since it is averaged over the worst day of the year.
I have provided 3 versions of the maps provided:
This is the best version. It shows the concentrations of toluene, along with map layers showing all the streets, the neighborhoods, the lots, and the type of businesses adjacent to Metcalf Autobody (you can turn these layers on and off). On these maps you can turn on and off the two concentration layers, zoom out to a wide area, pan across the map, point at the lines to see the concentrations where they are not labeled, etc. You need the free MapGuide Plug-in to see this map.
For those of you who have not downloaded and installed the MapGuide Plug-in, I created two images of the map seen on that plug-in. These will show you the concentrations in relation to the day care center and other features and you can see them on any browser without the plug-in.
Finally, I have scanned in the original maps: low and high concentrations. These show the body shop and the day care center and the concentration lines. They do not show any other features, such as streets, lot boundaries, other businesses, etc.
To create the MapGuide Maps I converted the original scanned map images to latitude/longitude coordinates, based on the two buildings shown in the drawings and based on the distances shown. I just guessed where the buildings would fall within their lot boundaries on the MapGuide Maps. So all the distance relationships among the concentration lines and the two buildings are correct, but they might be a few feet off from the underlying features like lot boundaries. Nothing significant is lost.
For those of you, if any, who really want to get technical, you can measure the distances on the MapGuide Map and compare them to the ones on the scanned images. You will find that the distance measuring tool in MapGuide has a bug - it always measures a distance as 1.28 times its actual length. For instance, the distance from 159th street to 167th street along Metcalf is exactly one mile, but the measuring tool shows 1.28 miles. Fortunately, the problem is with the measuring tool and the tool is consistent - wrong, but consistent. So always divide the MapGuide distances you measure with the tool by 1.28. The maps themselves display everything correctly.
[Editor's note: this memo is in response to a request for information made to the California Bay Area Air Quality District on how to evaluate the emissions from an autobody shop.]
Dear Mr. Phillips -
I will forward your note on to Mark Watkins who is the coordinator at the Air Resources Board (ARB) for the Autobody Industrywide Risk Assessment Guidelines. These guidelines were developed by the ARB and the California Air Pollution Control Officers Association (CAPCOA) to provide guidance to the local air districts in estimating air toxics emissions and performing a generic risk assessment.
Local districts are required to evaluate Autobody shops as part of the State of California's Air Toxics Hot Spots Program. This Program requires most businesses in California to be evaluated to determine if there are any localized areas of high risk due to exposure to toxic substances. We maintain a Program website at:
Information about the risk assessment portion of the Program can be found at:
That site also contains information about the Autobody Industrywide Risk Assessment Guidelines. Unfortunately, you cannot download the Guidelines from the Web site. If you contact Mark with your address he can mail a copy to you. He can be contacted at: firstname.lastname@example.org or by phone at (916) 327-5623.
After you get your copy, you'll have lots of questions for Mark and should give him a call. The Guidelines include generic automotive coating formulations, substance by substance lists of the toxic substances found in the many automotive coatings used. There are many substances with much higher toxicities than toluene in those coatings. You would want your county environmental office to include emissions of these highly toxic substances in their evaluation. Your situation may depend on the operations of the autobody shop near you. Some are clean, with the best control technology and using coatings that have eliminated the most toxic compounds. However, there are also shops that have few controls and use cheap paints with lots of toxic substances. Your local environmental agency can ask the shop for the Material Data Safety Sheets (MSDS) for the coatings they use and determine exactly what is in the coatings and estimate what may be emitted. If you need more information, feel free to contact me and Mark Watkins.
Manager, Emission Inventory Methods Section
Technical Support Division
Air Resources Board
Editorial Opinion: How A Top California Air Quality District Handles Pollution
While researching this article I ran across the website for the California Bay Area Air Quality Management District (BAAQMD). Their website states: "In June of 1995, the Air District became the largest metropolitan area in the country to attain the federal ozone standard. The District was able to achieve redesignation to attainment by taking a progressive approach to regulating air pollution. Through its reasonable regulations, flexible permitting procedures, compliance assistance, proactive enforcement and effective public outreach, the Air District has developed one of the most responsive air quality programs in the nation."
I was impressed with how much information they collect. The BAAQMD states it has data on virtually all point sources which emit more than 2.5 tons of pollutants per year. These are contained in an emission inventory, openly available to any citizen for $25. As some of you may recall, the autobody paint shop of concern to us is exempt from all pollution regulation because it emits only about 3 tons per year, less than the 30+ tons per year which is regulated.
Our neighborhoods have been able to obtain the toluene study through the good offices of one individual in Johnson County, Mike Booth. He diligently pursued the matter over a course of a year in spite of facing higher priority work, key individuals resigning, resistance from the manufacturer to providing ingredients (many of you may not be aware, but Mike took considerable effort, working through the Federal EPA, I believe in New York, to get that data), etc.
Wouldn't it be great to know what type of pollutants and how much of each are emitted by the point sources around us? And to know what the concentrations are inside our neighborhoods under different wind conditions. This would be particularly valuable to help guide decisions on whether more polluters are allowed into the area. Currently, the fact that one autobody shop was already here was considered an argument in favor of letting in another. The opposite should be true for industries that pollute: if we now have two autobody shops raising the concentration of pollutants, that should be a factor in limiting more in this locality.
For instance, here in Blue Valley we have the Reno operation and two autobody paint shops (and perhaps others of which we are not aware). Mike has studied the Reno operation and determined that it meets all regulations and guidelines. Since there is no inventory of actual emissions, there is no way to know if there are any health effects. Are there any toxic chemicals that all three of these emit in common? It would be comforting to know that there are not.
If one talks to the residents of Metcalf South Estates, Blue Valley Riding, and Blue Valley Paddock, one knows that the stench from the Reno operation can be a real nuisance on occasion. Here is the way the California law handles nuisances: "Occasionally, the District receives a number of complaints which are confirmed to a particular plant or facility. This may result in a determination that the facility is creating a public nuisance. The California Health and Safety Code and District regulations prohibit emissions of air contaminants which cause nuisance or annoyance to a considerable number of people, or that present a threat to public health, or damage to property. "
I was also impressed with the procedures BAAQMD uses for responding to air quality complaints. Their procedure for handling complaints from citizens appears standardized, well thought out, and apparently well funded.
Several of us in the neighborhood have talked off and on about how nice it would be if someone was actually measuring air quality in the area in a systematic, on-going way. That way we would actually know if we had a problem. If there were no problem, we would be establishing a baseline against which to measure as new development occured in the area. Once again, here is how BAAQMD handles this:
"The Air District's toxics network initially began with five sites (in addition to the ARB site) but has now expanded to eleven sites. A background site at Fort Cronkhite on the Pacific coast yields valuable baseline data to use for comparison with values obtained at other sampling stations. This network of 16 stations is thought to constitute the largest toxic air contaminant network on a systemized schedule in the nation. The compounds sampled include benzene; 1,1,1 trichloroethane (TCA); trichloroethylene (TCE); chloroform(TCM); 1,2 dichloroethane (EDC); 1,2 dibromoethane (EDB); methylene dichloride(DCM); carbon tetrachloride, and tetrachloroethylene (perc); vinyl chloride and toluene (while not considered a toxic air contaminant, toluene was chosen to better assess the origin of benzene emissions). In addition, sampling for the heavy metals lead, nickel, manganese and total chromium is carried out at the five ARB sites in Fremont, Richmond, Concord, San Francisco and San Jose."
Mike passed on to me that none of the chemicals being monitored by BAAQMD, other than toluene, are being emitted by the Metcalf auto body paint shop.
It's interesting to note that toluene is itself not considered a toxic air contaminant.
The question is still then open whether Metcalf Autobody does emit toxic air contaminants. And whether Country Side Auto Body emits toxic air contaminants. And whether the Reno operation does.
Hopefully, the low concentrations of toluene indicate low concentrations of more toxic chemicals, at least for one of these.
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