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. 
Marine Tank Vessel Loading Operations 
1

MEMORANDUM

TO: Anne Pope, EPA

FROM: Darcy Wilson, ERG

DATE: March 9, 2011

SUBJECT: Emissions Data Used in Residual Risk Modeling for Marine Vessel 

Loading Operations

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

estimating residual risk for the Marine Vessel Loading Operations 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 Marine Vessel Loading Operations 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 Marine Vessel 

Loading Operations source category (MACT code 0603). The 2002 NEI data for Marine 

Vessel Loading Operations 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 Marine Vessel Loading Operations MACT 

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

reviewed the results of this analysis, and performed an in-depth review of the NEI data 

 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

set for the source category. The NEI was reviewed to identify additional processes with 

Marine Vessel Loading Operation Source Classification Codes (SCCs), and the NEI data 

were compared with data in the EPA’s Toxic Release Inventory (TRI). MACT code and 

emission revisions were made as a result of these analyses. For facilities in the NEI that 

have Marine Vessel Loading Operations but do not have HAP emission estimates (only 

volatile organic compound (VOC) estimates, EPA applied speciation profiles to develop 

surrogate HAP emission estimates. EPA also identified two facilities that are not subject 

to the Marine Vessel Loading Operations NESHAP. 

EPA evaluated the facility-wide risks for Marine Vessel Loading Operations 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. Two facilities were removed from 

the category—one was not subject to the NESHAP (NEIDE0050093), and the other has 

ceased marine vessel loading operations (NEIIN371). The location coordinates were 

revised for the marine tank vessel loading operations at NEIFLT$4246. Revisions were 

made to the emission estimates, locational coordinates, MACT code assignments, and 

stack parameters for two facilities (NEITX20191 and NEI8135), and the emissions were 

updated for one facility (NEI6451).
Pharmaceuticals Production 
1

MEMORANDUM 

TO: Anne Pope, EPA 

FROM: Darcy Wilson, ERG 

DATE: July 15, 2010 

SUBJECT: Emissions Data Used in Residual Risk Modeling for Pharmaceuticals 

Production 

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

estimating residual risk for the Pharmaceuticals Production 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 Pharmaceuticals Production 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 Pharmaceuticals 

Production source category (MACT code 1201). The 2002 NEI data for Pharmaceuticals 

Production 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 Pharmaceuticals Production MACT 

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

NATA comments on the initial risk assessment draft that have been incorporated into the 

 

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

2005 NEI are identification of a closed facility in Puerto Rico (closed in 2008), and 

revisions to emissions, MACT code assignments, and locational coordinates for the 

facility. 

No additional revisions have been received for this source category based on the 2005 

NATA Risk Preview with state and local agencies in June of 2010. 
Polymers and Resins I 
1

MEMORANDUM 

TO: Anne Pope, EPA 

FROM: Darcy Wilson, ERG 

DATE: July 19, 2010 

SUBJECT: Emissions Data Used in Residual Risk Modeling: Polymers and Resins I 

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

estimating residual risk for four Polymers and Resins I Maximum Achievable Control 

Technology (MACT) source categories—Epichlorohydrin Elastomers Production, Nitrile 

Butadiene Rubber Production, Polybutadiene Rubber Production, and Styrene Butadiene 

Rubber and Latex Production. 

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 four Polymers and Resins I MACT source categories. 

EMISSIONS DATA USED IN RESIDUAL RISK MODELING 

Information collected from industry served as the starting point for these assessments. 

This information was also incorporated into the 2002 National Emissions Inventory 

(NEI) by assigning the emissions estimates to the specific process MACT codes1 within 

the NEI (1311, 1321, 1325, and 1339). The 2002 NEI data for Polymers and Resins I 

were released through an Advanced Notice of Proposed Rulemaking (ANPRM) in March 

of 2007, where NEI revisions for facilities in the MACT source categories were solicited 

from State and local agencies, industry representatives, and EPA. The revisions that were 

provided to EPA were incorporated into the 2005 NEI prior to the initial NATA 

modeling. 

 

 

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

Epichlorohydrin Elastomers Production 

Risks associated with the facility covered by the Epichlorohydrin Elastomers Production 

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

EPA reviewed the results of this analysis, and performed an in-depth review of the NEI 

data set for the source category. EPA also incorporated information received in response 

to an industry Information Collection Request (ICR), and evaluated the facility-wide risks 

for Epichlorohydrin Elastomers Production 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. Revisions were made to the emissions estimates for the facility based on 

these analyses and updated information. These revisions were included in the risk 

analyses, and will be reflected in the final NATA risk assessment. 

Nitrile Butadiene Rubber Production 

Risks associated with the facility covered by the Nitrile Butadiene Rubber Production 

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

EPA reviewed the results of this analysis, and performed an in-depth review of the NEI 

data set for the source category. EPA also incorporated information received in response 

to an industry ICR, and evaluated the facility-wide risks for Nitrile Butadiene Rubber 

Production 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. Revisions were 

made to the locational coordinates and emissions estimates for the facility based on these 

analyses and updated information, and closed facilities, minor sources, and sources that 

no longer manufacture nitrile butadiene rubber were identified. These revisions were 

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

Polybutadiene Rubber Production 

Risks associated with facilities covered by the Polybutadiene Rubber Production MACT 

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

reviewed the results of this analysis, and performed an in-depth review of the NEI data 

set for the source category. EPA also evaluated the facility-wide risks for Polybutadiene 

Rubber Production 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. 

Revisions were made to the emissions estimates for one facility based on these analyses. 

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

NATA risk assessment. 

Styrene Butadiene Rubber and Latex Production 

Risks associated with facilities covered by the Styrene Butadiene Rubber and Latex 

Production MACT standard were modeled in the initial 2005 NATA risk assessment in 

June of 2009. EPA reviewed the results of this analysis, and performed an in-depth 

review of the NEI data set for the source category. EPA also evaluated the facility-wide 

risks for Styrene Butadiene Rubber and Latex Production using the 2005 NEI data and 
3

risk assessment results that were released in the 2005 NATA Risk Preview with State and 

local agencies in June of 2010. Revisions made based on these analyses consisted of 

identification of closed facilities. These revisions were included in the risk analyses, and 

will be reflected in the final NATA risk assessment.