Appendix 1 

Emissions Inventory Support Memorandum 
Printing and Publishing Industry 
1

MEMORANDUM 

TO: Anne Pope, EPA 

FROM: Darcy Wilson, ERG 

DATE: July 23, 2010 

SUBJECT: Emissions Data Used in Residual Risk Modeling for Printing and 

Publishing 

The purpose of this memorandum is to provide information on the RTR database used in 

estimating residual risk for the Printing and Publishing Maximum Achievable Control 

Technology (MACT) source category. 

BACKGROUND 

Section 112 of the Clean Air Act (CAA) establishes a two-stage regulatory process to 

address emissions of hazardous air pollutants (HAPs) from stationary sources. In the first 

stage, section 112(d) requires the Environmental Protection Agency (EPA) to develop 

technology-based standards for categories of industrial sources. In the second stage, 

known as the residual risk stage, section 112(f)(2) requires EPA to assess the health and 

environmental risks that remain after sources come into compliance with MACT. If 

additional risk reductions are necessary to protect public health with an ample margin of 

safety or to prevent adverse environmental effects, EPA must develop standards to 

address these remaining risks. As part of this second stage, data were gathered to assess 

the residual risks from the Printing and Publishing MACT source category. 

EMISSIONS DATA USED IN RESIDUAL RISK MODELING 

The 2002 National Emissions Inventory (NEI) data served as the starting point for this 

assessment. Using the process MACT code,1 a subset of the NEI was developed that 

contained facility, process, and emissions data for each facility in the Printing and 

Publishing source category (MACT code 0714). The 2002 NEI data for Printing and 

Publishing facilities were released through an Advanced Notice of Proposed Rulemaking 

(ANPRM) in March of 2007, where NEI revisions for facilities in the MACT source 

category were solicited from State and local agencies, industry representatives, and EPA. 

The revisions that were provided to EPA were incorporated into the NEI prior to the 

initial NATA modeling. 

Risks associated with facilities covered by the Printing and Publishing MACT standard 

were modeled in the initial 2005 NATA risk assessment in June of 2009. Coordinate 

revisions were made for one facility based on EPA’s review of the results. 

 

1

 Assigning data with MACT codes allows EPA to determine reductions attributable to the MACT 

program. The NEI associates MACT codes corresponding to MACT source categories with stationary 

major and area source data. 
2

EPA also evaluated the facility-wide risks for Printing and Publishing facilities using the 

2005 NEI data and risk assessment results that were released in the 2005 NATA Risk 

Preview with State and local agencies in June of 2010. Emission revisions for five 

facilities were made based on EPA’s review of the facility-wide results. Six facilities 

were removed from the category because they are not subject to the Printing and 

Publishing NESHAP, and one was identified as being closed in 2005. These revisions 

were included in the risk analyses, and will be reflected in the final NATA risk 

assessment. EPA research also resulted in the addition of about 10 facilities to the source 

category that were not included in the risk analyses, but will be reflected in the final 

NATA risk assessment.