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.Marine Tank Vessel Loading Operations1 MEMORANDUM

TO: Anne Pope, EPA

FROM: Darcy Wilson, ERG

DATE: March 9 , 201 1

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 sta g e, known as the residual risk stage, section 112(f)(2) requires EPA to assess the hea l th 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 w ere gathered to assess

the residual risks from the Marine Vessel Loading Operations MACT source category.

EMISSI ONS DATA USED IN RESIDUAL RISK MODELING

The 200 2 National Emissions Inventory (NEI) data served as the start ing 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 ). T he 2002 NEI data for Marine Vessel Loading Operations w ere released through an Advanced Notice of Proposed Rulemaking (ANPRM) in March of 2007 , where NEI revisio ns for facilities in the MACT source category were solicited from S tate 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 wit h 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 stati onary major and area source data.2 set for the sourc e 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 Tox ic Release Inventory (TRI). MACT code and

emission revisio ns 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 H AP 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 (NEII N371). The location coordinates were revised for the marine tank vessel loading op erations at NEIFLT$4246. Revisions were

made to the emission estimates , locational coordinates, MACT code assignments, and stack parameters for tw o facilit ies ( NEI TX20191 a nd NEI 8135 )

, and the emissions were updated for one facility (NEI6451)

.Pharmaceuticals Production1 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 Pharm aceuticals Production 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 ai r pollutants (HAPs) from stati onary 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 Pharmaceutic als Production 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 da ta for each facility in the Pharmaceuticals Production source category (MACT code 1201) . The 2002 NEI data for Pharmaceuticals

Production facilities were re leased 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 cove red 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 dr aft 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 corresp onding to MACT source categories with stationary major and area source data.2 2005 NEI are identification of a closed facili ty in Puerto Rico (closed in 2008), and revisions to emissions, MACT code assignm ents, and locational coordinates for the facility.

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

NATA Risk Preview with state and local agencies in June of 2010.Polymers and Resins I1 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—Epichl orohydrin Elastomers Production, Nitrile Butadiene Rubber Production, Polybutadien e Rubber Production, and Styrene Butadiene

Rubber and Latex Production.

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 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 estimate s to the specific process MACT codes 1 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 cate gories were solicited from State and local agencies, industry repres entatives, 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 corresp onding to MACT source categories with stationary major and area source data.2 Epichlorohydrin Elastomers Production

Risks associated with the f acility covered by the Epichlor ohydrin Elastomers Production

MACT standard were modeled in the initia l 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 in corporated information received in response to an industry Information Collection Request (ICR), and evaluated th e facility-wide risks for Epichlorohydrin Elastomers Production us ing 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. Thes e 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 f acility covered by the Nitril e Butadiene Rubber Production

MACT standard were modeled in the initia l 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 in corporated information received in response to an industry ICR, and evaluated the fac ility-wide risks for Nitrile Butadiene Rubber Production using the 2005 NEI data and risk asse ssment 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 coordina tes 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 bu tadiene rubber were identified. These revisions were included in the risk analyses, and will be re flected in the final NATA risk assessment.

Polybutadiene Rubber Production

Risks associated with facilities covere d by the Polybutadiene Rubber Production MACT

standard were modeled in the initial 2005 NAT A risk assessment in June of 2009. EPA reviewed the results of this analysis, and pe rformed an in-depth review of the NEI data set for the source category. EPA also evalua ted the facility-wide risks for Polybutadiene Rubber Production using the 2005 NEI data a nd risk assessment re sults that were

released in the 2005 NATA Risk Preview with State and local agencies in June of 2010.

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

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

NATA risk assessment.

Styrene Butadiene Rubber and Latex Production

Risks associated with facilities covere d 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 ca tegory. EPA also evaluated the facility-wide risks for Styrene Butadiene Rubber and La tex Production using th e 2005 NEI data and3 risk assessment results that were released in the 2005 NATA Risk Pr eview with State and local agencies in June of 2010. Revisions ma de based on these analyses consisted of

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

will be reflected in the final NATA risk assessment.