Appendix 1 Emissions Inventory Support MemorandumPrinting and Publishing Industry1 MEMORANDUM

TO: Anne Pope, EPA

FROM: Darcy Wilson, ERG

DATE: July 23, 2010

SUBJECT: Emissions Data Used in Residua l 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 a nd Publishing Maximum Achievable Control Technology (MACT) source category.

BACKGROUND

Section 112 of the Clean Air Act (CAA) establ ishes a two-stage regu latory process to address emissions of hazardous air pollutants ( HAPs) from stationary sources. In the first stage, section 112(d) requires the Environmental Protecti on Agency (EPA) to develop technology-based standards for categories of industrial sour ces. In the second stage, known as the residual risk stage, section 112( f)(2) requires EPA to a ssess the health and

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

additional risk reductions are ne cessary to protect public health with an ample margin of safety or to prevent adverse environmenta l 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 an d Publishing MACT source category.

EMISSIONS DATA USED IN RESIDUAL RISK MODELING

The 2002 National Emissions Inventory (NEI) data served as the star ting 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 revision s for facilities in the MACT source category were solicited from State and local agencies, industry repr esentatives, 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 ba sed 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 corresp onding to MACT source categories with stationary major and area source data.2 EPA also evaluated the facility-wide risks fo r Printing and Publishing facilities using the

2005 NEI data and risk assessment results th at 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 th ey 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 faci lities to the source category that were not included in the risk analyses, but will be reflected in the final

NATA risk assessment.