P . 

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BEFORE TH E UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

APPENDICES TO PETITION OF THE CHEMICAL MANUFACTURERS ASSOCIATION KETONES PANEL TO DELIST METHYL ETHYL KETONE UNDER SECTION 313 OF THE EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT OF 1986

VOLUMEIOFV
SUBMITTED BY CHEMICAL MANUFACTURERS ASSOCIATION

1300 Wilson Blvd . Arlington, VA 22209 (703) 741-5000 

# cB1

November 27, 1996

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LIST OF APPENDICE S 

### Volume 1 A. Table of Reference s B . Exxon Chemical Company I~EK Technical Product Brochure C . Report of the ENSR Air Dispersion Modeling Stud y D . MEK emissions by zip code E. Table of Ambient Air Concentration Levels of MEK (taken from a study conducted by the New Jersey Department of Environmental Protection in 1978) F . Houston Regional Monitoring Report (excerpts) G. North Baton Rouge Volatile Organic Screening Study H . IRIS Database entry for ME K 1 . 1988 EPA Memorandum from J.V. Nabholz to EPA Chemical Review and Evaluation Branch J. Table Summarizing Acute Toxicity of MEK to Aquatic Organism s K. EPA Memorandum from Acting Assistant Administrator for Air and Radiation to EPA Office of Toxic Substance s L. EPA TRI Information Collection Request Report (excerpts) M . GAO Report on EPA Uses of TRI Dat a N. EPA Public Release on 1994 TRI Data, Appendix D. 0. Comparison of MEK Ernissions in Ozone Nonattainment Areas to MEK Emissions in a Areas Volume 2 P. Legislative I-fistory of EPCRA Section 313 Volumes 3,4 and 5 Q. References

### APPENDIX A TABLE OF REFERENCES

### p . 4

TABLE OF REFERENCES' 

### *Alderson M.R- and Rattan N. S . (1980) . Mortality of workers on an isopropyl alcohol plant and two MEK dewaxing plants . British J Indust. Med 37 : 85-89. *Altenldrch, H ., Stoltenburg, G. and Wagner, H .M. (1978) . Experimental Studies on Hydrocarbon Neuropathies Induced by Methyl-Ethyl-Ketone (MEK) . Journal ofNeurology 219 : 159-70 . *Ambrose, D ., Effender, J .H., Lees, E .B ., Sprake, C .H.S . and Townsend, R. (1975). Thermodynamic properties of organic oxygen compounds X3CKM . Vapour pressures of some aliphatic ketones . J Chem. 7herm. 7 :453-72 . *BozzeUi, J. et al . (1980). New Jersey Institute of Technology Air Pollution Research Laboratory, Analysis of Selected Toxic and Carcinogenic Substances in Ambient Air in New Jersey, prepared for Office of Cancer and Toxic Substances Research, State of New Jersey, Department of Environmental Protection . *Bridie, A.L ., Wolff, C .J .M . and Winter, M . (1979). BOD ano COD of Some Petrochemicals . Water Research 13 : 627-30 . *Brooke, L .T . et al . (1984) . Acute Toxicities of Organic Chemicals to Fathead Minnows (Pimephales promelas), Center for Lake Superior Environmental Studies, University of Wisconsin - Superior, WI ; Vol . 1 : 99-100 . *Brooks, T .M ., Meyer, A .L. and Hutson, D .H . (1988). The genetic toxicology of some hydrocarbon and oxygenated solvents . Mutagenesis 3 : 227-32 . *Carpenter, C .P ., Smyth, H .F ., and Pozzani, U.C. (1949) . The Assay of Acute Vapor Toxicity, and the Orading and Interpretation of Results on 96 Chemical Compounds
. Journal ofIndus. Hygiene and Toxicol . 31 : 34346. *Cavender, F .L. et al (1983) . A 90-day Vapor Inhalation Study of Methyl Ethyl Ketone
. Fundwn. Appl . Toxicol . 3 : 264-70 . *Chou, W .L ., Speece, R .E . and Siddigi, R .H . (1979). Acclimation and Degradation of Petrochemical Wastewater Components by Methane Fermentation . Biotech Bioeng . Symp. 8 : 391414. *Corwin, J .F . (1969) . Volatile Oxygen-Containing Organic Compounds in Sea Water : Determination . Bull . Marine Science 19(3): 504-09 . *Cox, R.A., Patrick, K.F. and Chant, S .A. (1981) . Mechanism of Atmospheric Photooxidation of Organic Compounds. Reactions of Alkoxy Radicals in Oxidation of n-Butane and Simple Ketones . EnWromnental Sci. Technol . 15(5) : 587-92 . Two copies of all references denoted with an asterisk have been submitted with this petition .

### p . 5

*Deacon, M .M. et al . (1981) . Embryo- and Fetotoxicity of Inhaled Methyl Ethyl Ketone in Rats . Toxicol andAppl

. Phartnacol

. 59 : 620-22 . 

### *Dick, R.B ., Kreig, E .F ., Jr., Setzer, J. and Taylor, B . (1992) Neurobehavioral Effects from Acute Exposures to Methyl Isobutyl Ketone and Methyl Ethyl Ketone . Fundwn. Appl ToxicoL 19 : 453-73 . *Dick, R-B ., Setzer J .V., Taylor B .J . and Shukla R. (1989). Neurobehavioral effects of short duration exposures to acetone and methyl ethyl ketone . Brifish J Ind Med 46 : 111-2 1 . *Dietz, F .K. and Traiger, G.J. (1979). Potentiation of CCL4of Hepatotoxicity in Rats by a Metabolite of 2-Butanone : 2,3-Butanediol . Toxicolog~ 14 : 209-15 . Dourson, M .L. and Stara, JR. (1983). Regulatory History and Experimental Support of Uncertainty (Safety) Factors . Reg

. Toxicol . Phamacol 3 : 224-38 . *Dumant J.P. and Adda J . (1978) . Occurrence of Sesquiterpenes in Mountain Cheese Volatiles . J. Agric. Food Chem. 26 : 364-67 . *ECETOC Technical Report #70: Chronic Neurotoxicity of Solvents (February 1996) . European Centre for Ecotoxicology and Toxicology of Chemicals at pp. 147-5 1 . *Elkins, H. (John Wiley & Sons 1959). The Chemistry of Industrial Toxicology at pp. 118-21 . *Ewing, B .B . et al . (1977). Monitoring to Detect Previously Unrecognized Pollutants in Surface Waters . EPA 560/6-77-15 . USEPA, Office of Toxic Substances . *Florin, I ., Rutberg ., L., Curvall, M . and Enzell, C .R. (1980). Screening of Tobacco Smoke Constituents for Mutagenicity Using the Ames' Test . Toxicolosy 18 : 219-32 . *Gordon, D .T . and Morgan ME . (1979). Principal Volatile Compounds in Feed Flavored Milk . J Dairy Sci . 55 : 905-12 . *Grosjean, D . (1982). Formaldehyde and Other Carbonyls in Los Angeles Ambient Air. Environ . Sci . Techn. 16: 254-62 . *Hamburger, S .J . (1980) . CHDH Aquatic Static Acute Toxicity Test - First Nominees Complete . Internal Exxon memorandum. Heitrnuller, P .T ., Hollister T .A. and Parrish, P .R. (198 1). Acute Toxicity of 54 Industrial Chemicals to Sheephead Minnows (Cyprinodon varlegatus) . Bull . Environ. Contam. Toxicol . 27 : 596-604. *Hewitt, L .A-, Ayotte, P . and Plaa, G .L . (1986) . Modifications in Rat Hepatobiliary Function following Treatment with Acetone, 2-Butanone, 2-Hexanone, Mirey, or Chlordecone and Subsequently Exposed to Chloroform . Toxicol . andAppl. Phartnacol

. 83 : 465-73 . *Hewitt, W .R., Brown, E .M ., and Plaa, G.L . (1983) . Relationship Between the Carbon Skeleton Length of Ketonic Solvents and Potentiation of Chloroform-Induced Hepatotoxicity in Rats . Toxicol . Lett . 16 : 297-304 . 2

### p . 6

*Howard, P .H . et al . (Lewis Publishers 1990) . Handbook of Environmental Fate and Exposure Data for Organic Chemicals . Vol . 11 : 33440 . 

### *Isidorov V .A., Zenkevich I .G ., Ioffe BV. (1985). Volatile Organic Compounds in the Atmosphere of Forests. Atmos. Environ. 19 : 1-8. *Jungclaus, G.A., Lopez - Avila, V. and Hites, R.A. (1978). Organic Compounds in an Industrial Wastewater: A Case Study of Their Environmental Impact . EnWron. Sci. Technol . 12(l) : 88-96 . *Kimura, E., Ebert, D . and Dodge, P . (1971). Acute Toxicity and Limits of Solvent Residue for Sixteen Organic Solvents . Toxicol, andAppl. Pharmacol 19 : 699-704. Knasko S .C ., Gilbert, A.N ., Sabini, J. (1990) . Emotional state, physical well-being and performance in the presence of feigned ambient odor . J Appl . Soc. Psychol

. 20 : 1345-57. 2 *Krasavage, W.J. O'Donohogue, J .L. and DiVincenzo, G.D . (John Wiley & Sons 3rd ed . 1982) . Ketones in : Patty's Industrial Hygiene and Toxicology at pp . 4728-33, 47874800. *LaBeffe, C .W ., and Brieger, H . (1955). The Vapor Toxicity of a Composite Solvent and its Principal Components . Arch. Ind Health 12 : 623-27 . 3Lande, S ., Durkin, P . Christopher, D ., Howard, P ., Saxena, J ., Syracuse Research Corp . (1976) . Investigation of Selected Potential Environmental Contaminants ; Ketonic Solvents, prepared for Office of Toxic Substances, Environmental Protection Agency . *Lovegreen, N.V., Fisher, G.S ., Legendre, M .G. and Schuller, W .H. (1979) . Volatile Constituents of Dried Legumes . J Agric. Food Chem. 27 : 851-53 . *Lyman, W.J ., Reehl, W.F . and Rosenblatt, D .H . (McGraw-Hill Book Co . 1982) . Handbook of Chemical Property Estimation Methods at pp . 15-1 to 15-34 . *Mariiett, L .J., Hurd, H . K., Hollstein, M . C ., Levin, D . E ., Esterbauer, H . and Ames, B. N . (1985) . Naturally occurring carbonyl compounds are mutagens in Salmonella tester strain TA104 . Mutation Research 148 : 25-34. *Mast, T.J. et al . (1989). Inhalation Developmental Toxicology Studies : Teratology Study of Methyl Ethyl Ketone in Mice . Prepared for the National Institute of Environmental Health Sciences, No . NIHY01-ES-70153 . 4 *National Toxicology Program Fiscal Year 1987 Annual Plan . NTP-87-001 (May 1987) . Salmonella Data at p. 70 ; In Vitro Cytogenetics/Sister Chromatid Exchange Data at p . 87. 2 Only the chapter on Ketones has been submitted . 3 This is the same reference as EPA 560/02-76-003 (1976) . 4 Only the cover page and pages 70 and 87 have been submitted. 3

### p . 7

Nelson, B .K ., Brightwell, W .S ., Khan, A ., Burg, JR . and Goad, P .T. (1988) . Lack of Selective 

### Developmental Toxicity of Three Butanol Isomers Administered by Inhalation to Rats. Fundcan. Appl . Toxicol . 12 :469-79 . *Nelson, K.W., Ege, J .F., Ross, M ., Woodman, L .E. and Silverman, L . (1943) . Sensory Response to Certain Industrial Solvent Vapors . J of Indus. Hygiene and Toxicol . 25 : 282-85 . *Nestmann, E .R-, Lee, E ., Matula, T.I ., Douglas, G .R. and Mueller, J .C . (1980) . Mutagenicity of Constituents Identified in Pulp and Paper Mill Effluents Using the Salmonella/Mammalian-Microsome Assay. Mutation Research 79 : 203 -12 . *O'Donoghue, J .L ., Haworth, S .R., Curren, R .D ., Kirby, P .E ., Lawlor, T ., Moran, E .J ., Phillips, R .D ., Putnam, D .L ., Rogers-Back, AM ., Slesinski, R.S . and Thilagar, A- (1988) . Mutagenicity studies on ketone solvents : methyl ethyl ketone, methyl isobutyl ketone, and Isophorone. Mutation Research 206 :149-61 . Opdyke, D .L.J . Monographs for Fragrance Raw Materials -- Methyl Ethyl Ketone (1977) . Food Cosmetic Toxicol. 15 : 627-632 . 

### *Patty, F .A., Schrenk, H .H ., and Yant, W .P. (1935). Acute Response of Guinea Pigs to Vapors of Some New Commercial Organic Compounds-VIII . Butanone .'U .S . Public Health Service Report . *Perocco, P ., Bolognesi, S. and Alberghini, W . (1983). Toxic Activity of Seventeen Industrial Solvents and Halogenated Compounds in Human Lymphocytes Cultured In Vitro . Toxicol, Lett . 16: 69-75 . Pozzani U.C ., Weil C .S . and Carpenter C .P . (1959) . The toxicological basis of Threshold Limit Values : 5. The Experimental Inhalation of Vapor Mixtures by Rats With Notes Upon the Relationship Between Single Dose Inhalation and Single Dose Oral Data . Am. Ind Hyg . Assoc . J 20 : 364-69. *Price, K. S ., Waggy, G.T. and Conway, R .A. (1 974) . Brine Shrimp bioassay and seawater BOD of petrochemicals . J Water Pollut . Control Fed 46 : 63-77 . *Ralston, W .H ., Hilderbrandt, R-L ., Uddin, D .E ., Andersen, M .E . and Gardier, R.W. (1985). Potentiation of 2,5-hexanedione neurotoxicity by methyl ethyl ketone . Toxicol. andAppl. Pharmacol. 81 :319-27 . *Randall, T.L . and Knopp, P .V. (1980). Detoxification of specific substances by wet oxidation . Water Res . 14 : 2117-30 . * Saida, K ., Mendell, J. and Weiss, H . (1976) . Peripheral Nerve Changes Induced by Methyl n-Butyl Ketone and Potentiation by Methyl Ethyl Ketone. J Neuropathol . andErperim. Neurology 35 : 207- 25 . *Schwetz, BA-, Leong, B .K.J . and Gehring, P .J . (1974) . Embryo- and Fetotoxicity of Inhaled Carbon Tetrachloride, 1, 1 -Dichloroethane and Methyl Ethyl Ketone in Rats . Toxicol . andAppl . Pharmacol, 28 : 452-64. 4

### p . 8

*Schwetz, B .A ., Mast, T.J ., Weigel, R.J., Dill, JA. and MorTissey, R-E . (1991) . Developmental 

### Toxicity of Inhaled Methyl Ethyl Ketone in Swiss Mice . Fundwn. Appl . Toxicol, 16: 742-48 . Shirasu, Y . (1976). Mutagenicity testing of pesticides . Kogia to Taisaku . J ofEnWron. Pollution Control 12 : 407-12 . Smyth H .F ., Carpenter C .P ., Weil C .S ., Pozzani U .C. and Striegel J.A- (1962) . Range-Finding Toxicity Data : List VI . Am. Ind Hyg . Assoc. J 23 : 95-107. *Snider, J .R- and Dawson, G.A- (1985) . Tropospheric Light Alcohols, Carbonyls, and Acetonitrile Concentrations in the Southwestem United States and Henry's Law Data . J Geophys. Res. D . Atmos. 90:3797-3805 . *Specht, H ., Miller, J .W., Valaer, P .J . and Sayers, R .R . (1940) . Acute Response of Guinea Pigs to the Inhalation of Ketone Vapors . U . S. Public Health Service, NIH Bulletin No . 176 : 1-66 . * Spencer, P . S. and Schaumburg, H . (1976) . Feline Nervous System Response to Chronic Intoxication With Commercial Grades of Methyl n-Butyl Ketone, Methyl isobutyl Ketone, and Methyl Ethyl Ketone . Toxicol. andAppl . Pharmacol. 3 7 : 3 0 1 -11 . *Takeoka, G .R., Flath RA.and Guntert, M . (1988). Nectarine Volatiles : Vaccuum Steam Distillation Versus Headspace Sampling J Agric. Food Chem. 36 : 553-60 . *Takeuchi, Y., Ono, Y . Hisanaga, N., Iwata, M . Aoyarna, M ., Kitoh, J. and Sugiura, Y . (1983) . An experimental study of the combined effects of n-Hexane and methyl ethyl ketone . British J Indust . Medicine 40: 199-203 . Tanii, H ., Tsuji, H . and Hashimoto, K. (1986) . Structure - Toxicity Relationship of Monoketones . Toxicol Lett. 30 : 13 -17. *Traiger G.J . and Bruckner, J .V. (1976) . The Participation of 2-Butanone in 2-Butanol-Induced Potentiation of Carbon Tetrachloride Hepatotoxicity . J Pharmacol. Experim . Therapeutics 196: 494- 500. *Traiger, G .J ., Bruckner, J .V., and Cooke, P .H. (1975). Effect of 2-Butanol and 2-Butanone on Rat Hepatic Ultrastructure and Microsomal Drug Metabolizing Enzyme Activity . Toxicol, andAppl . Pharmacol, 33 : 132 . *Tumbull, H . ; Demann, J.G . and Weston, R.F . (1954) . Toxicity of Various Refinery Materials to Fresh Water Fish . Ind & Eng. Chem. 46(2) : 324-3 3 . *Verschueren, K . (Van . Nostrand Reinhold Co . 2nd ed . 1983). Handbook of Environmental Data on Organic Chemicals at pp . 850-5 1 . Wen C.P ., Tsai S .P ., Weiss N. S., Gibson R .L., Wong 0 . and McClellan W.A- (1985). Long-term Mortality Study of Oil Refinery Workers. IV . Exposure to the Lubricating-Dewaxing Process . J Nat/ . Cancer Inst. 74 : 11-18. IN 5

### P . 9

*Zimmerman, F .K ., Mayer, V .W ., Scheel, I . and Resnick, M .A. (1985) . Acetone, methyl ethyl ketone, ethyl acetate, acetonitrile, and other polar aprotic solvents are strong inducers o f 

### aneuploidy in Saccharomyces Cerevisiae . Mutation Research 149: 3 39-5 1 .

6P . 10

APPENDIX B 

### EXXON CHEMICAL COMPANY MEK TECHNICAL PRODUCT BROCHURE

# N CHEMICALS



# METHYL ETHYL KETONE

## Copyrighted page/s removed. Copyrighted material is not available in Regulations.gov since it may not be reproduced without consent of the copyright holder. Contact the EPA Docket Center’s Public Reading Room to view or receive a copy of this document. Requests for copies may be made as follows: In person/writing: Environmental Protection Agency, Docket Center 1301 Constitution Ave NW, 2822T, Room 3334 Washington, DC. 20004 Telephone: 202-566-1744 Fax: 202-566- 9744 Email: docket-customerservice@epa.govp . 13



# METHYL ETHYL KETON E

(MEK) 0 11 CM3-C-CHaCM3 Methyl ethyl ketone (MEK) is a low-boiling . chemically stable compound similar in properties to acetone . Sometimes referred toss butanoi MEKisaflammbble . colorless liQuid prossusing a typical ketonic odor . Not Quite as volatile as acetone . 4 is neriienheless a fast evaporator, its evaporation rate being roughly comparable to that of ethyl acetate . MEK is a good solvent for many natural and synthetic resms. It is miscible with most organic solvents . MEK is only partially miscible with water and forms a constant boiling rnixture at 73 .69C (164 .54F) containing appipiximately 11 per cent by weight of water . The pure ketone boils at 79 6*C (1 75-30F) . low viscosity at high solids concentration . MEK is of

"To speoftse~ 11111111110 %womeam high purity and has a toluene dilution ratio of 4 .3 ; Us 8W'C @gal WA % OMM" twon Chowrwof 1W 34 therefore it can tolerate a high percentage of low-cost CAW . "aww"44101114 10 am Dim aromatic diluent without allowing the nitrocellulose Dammen to precipitate . Its low specific gravity enables formuV40 2"W4 Pe" 78 STA1173-7r). M-

_ orv pool 41 M177SPI . MW lators to produce larger volumes of base lacquers 0 ftnp i VC* ?-It) or thinners per pound of MEK than is possible with 79 VC heavier solvents. fto@~%Vftlftmw~ efloom 0 13 U Dow CrWeeft"Oft . Di m

fte" ."NOWN Another use for MEK is in thinner blends for acrylic Nray. I" G C . wt .% W6MM and acrylic-nitrocellulose lacquers . MEK is also a sol- smft 20 VC M h "

:W#AN vent for alkyds and other resins often used to modify vow Comm 11" % 0 1 Wa . 13M nitrocellulose lacquers . Air-dried epoxy finishes with physical properties similar to those of baked finishes are obtained with the help of ME K 

# Applications as a Solvent This versatile solvent is also wad in surface coatings based on eftl cellulose . cellulose acetate-butyrate, MEK Js widely used as a cornpw*M of vinyl lacquer polyuretharm, and vinylidene chlorkle-acrylonitrile solvent systems. ft powerful active solvency for vinyl copollymer. Other ussis for MEK are in fabric coatings, acetate and vinyl chlofide-virryl acetate Copolymers and synthetic rubber coatings . makes it possible lo formuhft high-solids lacquer s containing large amoLrft of economical hydrocarbon In some arm, RLA9-66 type air pollution regulations . diluents . Spray. dip. knife . bnjsK or roller techniques wtich restrict ttle use of corWn solvents . are still in force . can be used to apply Own lacquers at room or 9 W vated temperatures . MEK is also used in vinyl type MEK is Mted n a non-restricted solvent by Rule 66- protective strippable coatings foir equipment in type regulations . Therefore, it is used in ft reformulastorage- tion of a wide variety of coatings, iinks . and adhesives to rephlice Rule Wtype restricted solvents . MEK is particMEK is a strong active solvent for nitrocellulose and Warty useful in the solvency of weaker exempt is extensively used in furniture and automotive lac- goWft ~ often moist be employed to replace quers. It has good blush resistance and helps .provide restricted solvents . such as aromatics. 4 jPWWW~ 0 140 &W "raw &"WMION Ty-M-11111116.p . 14

MEK is a major solvent for adhesives . The excellent aliphatic hydrocarsolvent properties and fast evaporation of MEK ac- bon Solvents which count for its wide use as a solvent in many com- are often used t o pounded polyurethane, nitrile rubber and neoprene- replace the restric- %ower based industrial cements . These include high- ted aromatics . ME K strength, oil-resistant, resilient adhesives ; hesit-acti- is also finding applivated adhesives for lamination ; low-temperature and Cation in fast dryheat-activated curing cements used as general pur- traffic paints tormupose adhesives : and a number of specialty cements lated with chlorinsuch as those used for bonding vinyl to fabrics . and ated rubber . paper coating cements . MEK also goes into viny l solution formulations used as heat-sealable, grease- Clean" Rukkresistant paper coatings and cellulose acetate lami- Many cleaning comnating adhesives . This versatile solvent is also used positions make use of Ar in bonding cements for polystyrei4e, polyvinyl chlo- the powerful solven t ride, and polyvinyl chloride-polyvinyl acetate copoly- action of MEK . It is mers . Good shelf life is an added advantage of using widely used in paint-, MEK in adhesive formulations . lacquer-, and vamish-removers . Industrial metal- and on- 111-6 Isis" as"1111,The strong solvency and last evaporation rate of MEK gine-cleaning solmake it an important component of gravure printing vents also incorpoinks, particularly in Type C and Type V inks . It also rate ME K finds some applications in silk screen printing . selvem aft*~ D"aWn Agents The selective solvency of MEK has promoted its use In mixtures with benzene or toluene, MEK is used in petroleum refineries for reducing the wax content of as an extraction medium for fats, oils, waxes, and lubricating oils . The ketone precipitates the wax while resins . Another use is in the concentration of fatty the aromatic solvent holds the oil in solution . This acids in aqueous solutions . MEK is used in ft re- process can be adapted to a great variety of lubricovery of acetic acid from dilute solutions . Pharma- cating oils by varying the p4rcentage of MEK in the coutical applications include use in the recovery and mixture

. concentration of penicillin . Spent absorption agents used in the refining of oil can be reactivated by an Opel$ MEK-benzene mixture . MEK is also used in a process Methyll ethyl ketone is used as a solvent for various for removing sulfur from oils . MEK does not hydrolyze dyes and for inks used in printing on cellulose-derivato form Corrosive products . This is an advantage over hve surfaces . Anthraquinone dyes for acetate fabric *slars in solveft mcovery syftme . are prepared in a proem which uses MEK Oil and Tram Mark" vs" fat are removed from wool prior to dyeing by washing in ME K Millions of gallon of traffic pail am used by city. county, and state governments every year . Much of this Nbeellam m paint is a solvent-baeW, oU modified, a" resin type . Combined with chemicals such as mercuric oxide Because of the soh*R portion of the formiulation consti- or with chliorinated hydrocarbons . MEK is used in Uift as much as 50% . w . concem about air pofiu- insecticides, fungicides, and germicides . MEK is also lion has bow shown . MEK is an important component used in the manufacture of smokeless powder, It is a in replacing air pollution regulation restricted solverits . solvent for various anti-oxidants . Photographic film, such as toluene, which are used in these alkyd formula- artificial leather . and many types ot plastics are manutions . ft enhances the solvency of the weaker, exempt facturod with the help of this excellent solvent.p . 15



# Applications as a Chemical Intermediat e Potentially, methyl ethyl ketone (MEK) can be as & UftGONS"00US Rose"" $ widely utilized as acetone for chemical synthesis . Oxidation of MEK with oxygen produces diacetyl, Reactivity centers around the carbonyl group and its a flavoring material . Chlorination yields mixtures of adjacent hydrogen alois . Condensation . afnrro- several monochloro and dichloro derivatives in pernolysis, halogenation, and oxidation can be carried centages depending on reaction conditions . The reout under the proper conditions . Some typical re- action of MEK with hydrogen peroxide gives a mixture actions are described below . of peroxides and hydro-peroxides which is used to cure polyester resins at room temperature .

0ON Aldol condensation of two moles of MEK yields a 6 1 hydroxy ketone which readily dehydrates to an un- CHICCHAC643 * 0441-WOUCCH10% saturated ketone . 601 4 This initial addition product is the unstable precursor of seven stable peroxides and hydroperoxides . Of these . 2 .2'-dihydroperoxy-2,2'-dibutyl peroxide, is CW4 C~b CH3C"4 0 CHCCHSCP % 2. Cenftm"m wfth ONW CON"MrAft 4 CWS Reiction with aldehydes gives higher ketones . as well present in largest amount (about 45 per cent) in the as ketals and cyclic compounds, depending on re- peroxide mixture . action conditions . 8-diketones are produced by the condensation of MEK with aliphatic esters . MEK con- MEK peroxides are widely used as catalysts for thedenses with glycols and organic oxides to give deriva- polymerization of polyester resins at room temperatives of dioxolane . ture . The condensation product of MEK and m-phenyIons diamine is an efficient curing agent for epoxy sec-Butylamine is formed by reacting MEK with resins . MEK and cobalt acetate function together as aqueous ammonia and hydrogen . a specific WOW for the single stage oxidation of p-xylene to terephthalic: acid. Aliphatic monoketones, 0 such as MEK also function as catalysts in the polyc" .1c" .0% merization of poly (ethylene terephthalate) where
. it is WHO claimed . they speed condensation times and cause 101 Wo P40 less yellowing of the polyrner than antimony trioxide
. MEK is also used in the preparation of complex cataAn ss of MEK in this reaction will also produce tysts used in the syndkftctic polymerization of &-olethe secondary wnft &wc4atihnsira fin such as polypropylene. Reacting MEK wNh acetylene gives methyl pentynol . a hypnotic compoun& Ptwnol . glywAl, tirmaldehyde, acetaldehyde, fur0 c"S furaldehyde, and other chemicals can be made to react with MEK to form resins useful for adhesives, coatings. molded products, and eleclifical insulation . MEK maM with acrylonitrile to produce a dinitrile, which upon hydro"nation produces arnines .p . 16

MINES PitorcXMS OF TH E PURE COMPOUNDS* (all valmlem am at 20"C' ezeept wbevv Dowd) AR*Wm MEN MISK Oxide bephorme Autoignotion Tentperaluts . Vapor . IF 1000 900 864 - no Amectrope with Water . D.P . . 'C - 73 .4 47.9 91 .8 " s

vn . % Katons, in Vapor - " .7 76 .0 65 .2 16 .1 Doiling Point T 133.0 176.3 241 .2 USA 419 .4

*C so .I 79.6 116.2 129.6 215.2 Cawicism of Cubic Expansion. per IC 0.00143 MOD119 0.00116 0.00109 0.0008s crobw Pressure. offl. 47 43 32 - 35 Critical Temperature . IC 235 ago 2" - 441 Deneft . 91frA 0.7907 CAW ism 0 .653 0 .920 owisanc Constant 21 .45 Iasi 13 .11 15.4 - cimamm miatios . Toiuww 4 .5 4.3 3 .6 3 .7 6 .2

Alonstic Months 0 .7 0 .9 1 .1 0 .9 1 .0 Depoft Molnent. Det" units 2.72 2 .74 2 .7 2 .7 4 .0 WC) Electrical Conductivity. x I" mho 5 .5 to - - - Expiown Linvits . in air. val. % upw 12 .9 10 .0 7 .5 8 .8 3 .8 L~ 2 .6 1 .8 1 .4 1 .3 0 .8 Plash Point. IF Ime open cup 34 74 96 205 Too CWW CUP as so 83 200 Fiest no PowwrC -54 .7 -a" _00.2 -53 -8. 1

OF -09 .5 -123 .3 -112.4 -63 17 .4 GeNom par 100 pound* 15,16 14.90 14 .07 14 .04 13-02 "wofCombustion . BTU11b. 1&2@0 14j" 15400 - 15 .630 "" Of Fusion . calig 2364 24 .7 - - - himmif of VapootmNom. BTU/Ib. a D .P . 219 .70 190AS 15547 157, 13 9 Wolont Sao$? 72.104 100 .156 U .14 138.2 Poulage per gemon 6.00 6 .71 ta 7 .12 7 .60 ftfnMkv Inclex no law 1 .3791 130516 1 .44" 1 .4781 ftiatille f go" -ion Rate (a4uto AcatsfiswIOD) 1140 572 In 90 3 Sako" . WL % -of lissam in NOW@ a" 1 .7 3.1 1 .2

- 40 wow in ketem Infinite Ila 1 .9 U 4 .3 assmew" ftmwalw 1" 0.4 9 .2 9 .7 opmm 01111110V 0 .7911 Ojai DAM GAM om spoeft 14ML ow/01 . or am Sim 6,490 GA20 0-426 samb"am""movem um 24.6 2m 2" 313 Town" OWAINIEft awoo m pw4m x W 491 m - - vaw Pfusum, same, me ism 8021 14A 7 .9 0 .2 VMS, NPP awm4mise GAS GA GAS *A 2.6 .7fase ails PmP"w of Pwif aftemom oow*oww& ww shftw Rw he ohm se spooKkabons fairsommumemill pmdwup . 17



# Vapor Pressures of Ketones vs. Temperature

7-T-T 

# SAO 4MO ACETONE M IRK no no I A I "0 (,OF I AT E E 400 '6ESITYL 

## P OF 30 M M



# hol 101 lnoiw7z ' 190

- AV I A' AN I I M- I Aff A I AFI ffl so 79

10 -20 -10 0 1# 40 N Of To 00 90 loo IN 140 100 1$$ OCp . 18



# Specific Gravities of Ketones vs . Temperature 0.96

0 .92 0 .90 - leophpfon
iftyl OxId 0.84 0 .82 -Methyl Ethyl Kotgne 

# GAO QC* 0.78 Aeptone ISK L76 - 0 5 10 is 20 25 30 $5 40 49

TOMPefetwe"ICP . 19



# Fim and physiological Properties of Ketone s

Acialiene Mar

. I Ul@K Isophorene M0'tJ Ketones will ignite at ambient temperatures and can be expected to form flammable mixtures upon Highly 

# '"'01 Flammable Flammable Combustible I Flammable release to the air . 

## PHYSIOLOGICAL PROPERTIE S Acetone MEK MIBK Isophorone M*sityl Oxide EYE Markedly Severely Moderately severely Severely CONTACT 'irritating irritating irritating irritating irritatin g May cause injury to 9" tissues if not removed promptly . Do not got in eyes. SKIN Low order of toxcity. Frequent or prolorqed Moderate irritation . CONTACT contact may irritate skin and cause derrhatitis . AbsoMed in toxic Avoid frequent or prolonged skin contact . amount on proiongied contact. in high Concentration . vapor Negligible huwd Highly i . i t ing . is irritating to @"a and at ambient *"I- Exposure to high INHALATION mucous membranes, and is persture because of vapor concentration anesthetic . low volistdity . resulits in loss of Avoid breathing Vapor& Anesthetic at high consciousneall . VAmp concentration billow TLV. concentration . THRESHOLD LIMIT VALUE* low 200 so S (TLV), ppm in ai r OSHA TimetWeighted 1000 200 100 25 25 Avera"- (TWA) . VW in ai r INGZSMN LOW older of toxie" Moderately "Ric 

# Pftcaudoow Keep away from heat. speft and flames . Avoid breathing vapom . Keep containers closed . Keep concentration in air below Threshold Limit Value . Do not got m syn. Note Special PrecMions . Avoid prolonged or repeated skin contact Iftfol"NL~WMMOWWW woewwwwolom *I giosomoo . will opoew" ONW"m ~~ of a aglow" got --Mip so Werliews OW so vognow iogneir aft em, lair w~ sowetio ~ . nre ow so tow-- -Sao 98"Oftwolia for a r or 0~ aw"W &W do~

clififtivesse of COMMOMMI "ausgrot ftwesews. riet . ftepw ftipaw W. SOL No. W. P. later, 8112,11p . 2 0



# First Aid Storage tanks should be located well away from other buildings . and away from all possible sources of igniEye Canted tion . Underground tanks may be necessary in some Immediately flush eyes with plenty of water for at cases . Aboveground tanks should be surrounded by least 15 minutes . Call a physician . firebanks sufficient to contain the tanks' contents . Tanks. pipeline systems. and all other equipment Skin Canted should be grounded to prevent the accumulation of Flush with water . use soap if available . static electricity. Inhalation Pressure buildup in tanks should be prevented by vent If overcome by vapor. remove immediately from exposure and call a physician . Administer artificial respira- lines equipped with flame arrestors . Such vent lines tion if breathing is irregular or has stopped . should not discharge near doors, windows, Chimneys, or any source of heat or sparks . The pipelines use d 11111901114101111 for filling and discharge should extend almost to the No hazard bythis route in normal, industrial use . Call a bottom . Centrifugal pumps can be used to draw liquid physician if swallowed . from the tank . Drip pans should be provided wherever solvents are transferred from drums or taps . Spffis and Leaks Adequate ventilation in storage and work areas is Eliminate all sources of ignition . Wam occupants of extremely important. Excess solvent vapor in the air downwind areas of fire and explosion hazard . Prevent constitutes a serious explosion and fire hazard . In adliquid from entering sewers, streams or low areas . dition, if the Threshold Limit Value is exceeded, disKeep people away. Contain spilled liquid with sand comfort to workers along with possible toxic effects or earth and recover by pumping or with a suitable may result . Publications of the National Board of Fire absorbent. Cleanup personnel should be equipped Underwriters contain much useful information on the with adequate protective equipment including chemi- design of ventilating systems . cal safety goggles . self-contained breathing apparatus and protective clothing . Proper education of employees as .to the dangers involved in handling volatile solvents is the comerstone.,of good safety pracbce . Workers should be 

# Waste Disposal trained to recognize and correct hazardous condiKetones may be disposed of by incineratitwO a man- tions . Fire extinguishers . masks, goggles, and other ner conforming to local regulations . sal*V equipment should be strategically located an d workers should be taught how to use them . Men enter

# F-i-m- Fi Ming ing vals or tanks for inspection or cleaning should be Alcohol-type ram is iscaninw-dii'd for fighting ke- provided veM the proper harness and should always tone liquid fires . Aftemafively~ dry chemical, carbon be obeFerved by someone outside the entrance . Fir* drills and safety inspections, should be carried out doxide, or wateir bg rnay be und . Use water spray to regularly . Safety precautions should be suitable for cool fir"xpowd c a mto and to protect personnel . the particular facilities . personnel, and operations of each plaf t 

# Rom& and Handlin g Ketonis solvents are flammable . volatile cternicals and must be handled cautiousty . Users should farnililarize themselves with the Underwritivirs' cgrisil for these malorials, and with applicable federal, state, and local regulatiom .p . 21



# Special PrecautionsKetones should not be used with certain active chlorine compounds without attention being directed to the possible formation of toxic chloroketones . 

# Shipping Information

powl"Perclevisti G"fftimat at am losselen, w OC TM GF Deewbet" NOW ACETONE 6 .60 0 .00137 0 Flammable Liquid METHYL ETHYL 6 .71 0 .00130 21 Flammable Liquid KETON E METHYL ISOBLITYL 6 .68 0 .00113 62 Flammable Liquid KETON E UESITYL OXIDE 7 .11 0 .00109 84 Flammable Liquid May form peroxides on long storage ISOPHORONE 7 .68 0 .00M 19D Combustible Liquid Freezes at irFp . 22



## Wes Offices Akma 3M W. Market Street Akron, Ohio "313 C216) 83&791 1 Ado" 390 Interstate North, Suits 375 Atlanta, Georgia 30W (4") 956-moo Chicap Arms suite 550 701 Lose Street Des Plaines, Illimis 60016 (312) 2W1000 Dobvit Area 23M Northwestern Highway Sou"eld , Michigan 4W75 (813)365-2000 Now York Am P .O. Sol 20 1 Florham Park, Now Jersey 07932 001) 765-0100 P.O . Box 3272 Houston, Texas 77001 (713) 8704W Lm Angdas Ain Suite 41 0 5199 East Pacific Coast Highway lmq Beach, California 90904 C213) W7-1020 NmOrleans "W Genuml DeGaulle summo NowOrleans, LAWsions, 70114 (UK) 561-M DL Leds A m TM Dombommmme Avme, Bults M clalltaffill Wissoull suas (914) TA&M Wh*41= 410 Wast NbM 9L W010*000, Debavare ISM 00 6564 M 

# E-ZFC%N EXXON CHEMICAL AMERICAS A7V P. M am 3M NM$ftr4 lrX 77001 %F IMICALS

### p . 23

APPENDIX C 

### REPORT OF THE ENSR AIR DISPERSION MODELING STUDYp . 24



# Chemical Manufacturer s Association (CMA) Ketones Pane l 

# E K-%T Dispersion Modeling to Estimate

Ambient Concentrations Associated with Sources of 31EK

November 199 6 Document Number 1410-016-100 LXp . 25



# Chemical Manufacturers Association (CMA) Ketones Panel
Dispersion Modeling to Estimate Ambient Concentrations Associated with Sources of -XIEK

November 1996 Document Number 1410-016-100p . 2 6 

# EM EXECUTIVE SUMMARY Title III of the 1990 Clean Air Act Amendments (CAAA) identified 189 Hazardous Air Pollutants (HAP) to be regulated under Section 112 of the Clean Air Act (CAA) . The CAAA contain provisions for the HAP list to be modified through a petition process . The Ketones Panel of the Chemical Manufacturers Association (CMA) is petitioning U .S . EPA to delete methyl ethyl ketone (MEK) from the HAP list . As part of this petition, CMA is seeking to develop information pertaining to ambient airborne concentrations in the vicinity of sources emitting MEK to the air
. ENSR, under contract to CMA, has estimated maximum off-site MEK concentrations through the application of U .S . EPA recommended air dispersion modeling procedures . The Toxic Release Inventory (TRI) database was used to identify the top emitters of MEK (annual emissions of 200 tons per year or more), as well as classes of other facilities with annual MEK emissions of more than 10 tons per year. Companies representing these top emitters were contacted by CMA and requested to provide site-specific information for atmospheric dispersion modeling . Dispersion modeling of facility MEK emissions from the top emitting facilities was conducted by application of the EPA!s recommended approach for CAA HAP petitions (Tiered Modeling- Arvroach for Assessing Risks Due to Sources of Hazardous Air Pollutants)
. This approach identifies three fiers of analysis that are progressively more agorous with each successive ter, resulting in more realistic modeled concentrations . Dispersion modeling analysis indicates that, with one exception not representative of human exposure, maximum annual off-site concentrations of MEK around the highest emitting facilities are below I Mg/M3 and maximum 24- hour concentrations are below 10 Mg/M3. Other MEK facilities (emitting 10 to 200 tons per year) were sorted by SIC code and a generalized modeling approach was applied . This generalized approach is based on dispersion modeling previously conducted by EPA in support of Section 112(g) of the Clean Air Act . Generalized dispersion modeling indicates that maximum annual off-site concentrations are below 1 Mg/M3 in the vicinity of these lesser emitting facilities and are likely to be well below 1 Mg/M3 in most cases . An analysig was also conducted to determine whether multiple sources of MEK emissions in the same area might result in significant air impacts . It was concluded that there is no significant overlap of emissions and that combined impacts from multiple facilities emitting MEK will not cause maximum annual concentrations greater than 1 .0 Mg/M3 or maximum 24-hour concentrations greater than 10 MgIM3.

RAPUMPROJECM1410016\100ALL November, 1996 11p . 2 7 

# EM CONTENT S
1 .0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 1 .1 Purpose . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 1 .2 Identification and Selection of Sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 1 .3 Dispersion Modeling Approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2 1 .4 Summary of Study Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2 1 .5 Report Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1- 3 2 .0 SOURCES SUBJECT TO SITE SPECIFIC MODELING . . . . . . . . . . . . . . . . . . . . . 2-1 2 .1 Identification of Top Emitters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 2 .2 Solicitation of Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 2 .3 Source Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2- 7 3 .0 DISPERSION MODELING METHODS FOR TOP EMITTERS OF MEK . . . . . . . . . . 3-1 3 .1 Tier I Modeling Approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1 3 .2 Tier 2 Modeling Approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2 3 .3 Tier 3 modeling approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4 4 .0 EVALUATION OF MAXIMUM OFF-SITE CONCENTRATIONS AT HIGHEST EMITTING FACILITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1 5 .0 EVALUATION OF LESSER MEK SOURCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1 5 .1 Generalized Modeling Approach . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1 5 .2 Estimated Receptor Concentrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5- 2 6 .0 COMBINED IMPACTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1 7 .0 CONCLUSIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7-1

RAPUMPROJECTS14100160000ALL November, 1996p . 28

Elm 

### LIST OF TABLE S 2-1 Listing of Top MEK Emitters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2 2-2 Basis for Modeling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-4 2-3 Alternative Modeling Parameters for Non-Participants of Survey . . . . . . . . . . . . . . 2-5 2-4 Generically Modeled Non-Participants of survey . . . . . . . . . . . . . . . . . . . . . . . . . 2-6 3-1 Normalized Maximum Annual Concentrations . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-3 4-1 MEK Dispersion Modeling Results for Top Emitters - Annual Average . . . . . . . . . . 4-2 4-2 MEK Dispersion Modeling Results for Top Emitters - 24-Hour Average . . . . . . . . . 4-3 4-3 MEK Dispersion Modeling Results for Top Emitters - Annual Average . . . . . . . . . . 4-4 4-4 MEK Dispersion Modeling Results for Top Emitters - 24-Hour Average . . . . . . . . . 4-5 5-1 MEK Facility Impacts for Lesser Emitters . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-3 5-2 Evaluation of Top Emitting SIC Codes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-5

R :\PU8MPR0JECTS\1 41001alOOALL November, 1996p . 29 

# On LIST OF FIGURE S 3-1 Sample Receptor Grid Used in Tier 3 Modeling . . . . . . . . . . . . . . . . . . . . . . . . . . 3-6 4-1 Refined MEK Modeling Estimates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-7 4-2 Refined MEK Modeling Estimates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-8

RAPUMPROJECTS\1410016\100ALL November, 1996p . 30

MR 

### 1 .0 INTRODUCTIO N 1 .1 Purpos e Title III of the 1990 Clean Air Act Amendments (CAAA) identified 189 Hazardous Air Pollutants (HAP) to be regulated under Section 112 of the Clean Air Act (CAA) . The CAAA contain provisions for the HAP list to be modified through a petition process . The Ketones Panel of the Chemical Manufacturers Association (CMA) is petitioning U .S .EPA to delete methyl ethyl ketone (MEK) from the HAP list . As part of this petition, CMA is seeking to develop information pertaining to ambient airborne concentrations in the vicinity of sources emitting MEK to the air
. ENSR is under contract to CMA to estimate maximum off-site MEK concentrations through the application of U .S .EPA recommended air dispersion modeling procedures
. 1 .2 Identification and Selection of Source s ENSR's analysis was divided into three parts . First, because airborne concentrations are likely to be highest in the vicinity of the top emitters of MEK, ENSR conducted refined modeling for a large number of major MEK emitters using site-specific information provided by the facilities or, in a few cases, obtained from publicly available sources . The Toxic Release Inventory (TRI) database was reviewed to identify all sources for which annual emissions equaled or exceeded 200 tons per year, since these facilities have the greatest potential for adverse off-site exposure
. Twenty-six manufacturing facilities identified from the TRI review were contacted by CMA and requested to provide detailed source information so that site-specific atmospheric dispersion modeling of MEK emissions could be conducted
. Second, ENSR developed a generalized approach for analyzing maximum airborne concentrations in the vicinity of lesser emitting facilities
. AJI facilities that reported more than 10tons of MEK emissions on the 1994 TRI were divided into source categories based on their twodigit SIC codes. ENSR developed parameters for each SIC code and then used a generalized EPA model to predict likely maximum airborne concentrations based on the annual emission rates for the highest and second highest emitting facilities in each SIC code . Third, an analysis was conducted to determine whether multiple sources of MEK emissions in the same area might result in significant air impacts
. All facilifies emitting greater than 10 tons of MEK were identified and sorted by postal ZIP code . Groups of sources were evaluated to determine the potential for overlapping emissions
.

RAPUBSPROJECTS\1 410016\1 WALL Navember, 1996p . 31
11111ILLSIS 

### 1 .3 Dispersion Modeling Approac h Dispersion modeling of entire facility MEK emissions from the top emitting facilities was conducted by application of the EPA's Tiered Modeling Approach for Assessing Risks Due to Sources of Hazardous Air Pollutants (EPA, 1992) . This approach identifies three fiers of analysis that are progressively more rigorous, with each successive tier resulting in more realistic modeled concentrations . The first tier tends toward the most overprediction, requires the least detailed input data and uses simple look-up tables . The second tier uses standardized EPA screening modeling techniques that more realistically include plume rise and building downwash but are still designed to be relatively conservative, i .e ., to overestimate air quality impacts . The third tier uses refined dispersion modeling following EPA's Guideline on Air Quality Models (Revised) (U .S . EPA, 1995) and provides the most realistic impacts . Facilities that were identified as "top emitters" were first modeled using both Tier 1 and Tier 2 methods . Selected facilities among those with higher Tier 2 modeled impacts were also modeled using the refined Tier 3 techniques . For facilities below the 400,000 lb annual MEK emissions threshold, ENSR used a generalized modeling approach based on the model developed by EPA as part of the Agency's rulemaking under Section 112(g) of the Clean Air Act (EPA, 1993) . The EPA model results in a dispersion coefficient, based on a small number of input parameters, that is applied to an emission rate
. ENSR adjusted the EPA model to incorporate worst-case meteorological conditions, and then used it to predict maximum airborne concentrations for model facilities . These facilities were selected to represent each SIC code, not otherwise represented by one or more of the top emitters, that had at least one facility reporting more than 10 tons of MEK emissions in 1994
. The generalized approach was also applied to the remaining top emitters for which sufficient site information could not be obtained
. 1 .4 Summary of Study Finding s 1 . Refined dispersion modeling estimates of emissions from all facilities reporting 400,000 pounds or more of MEK emissions in 1994 indicates that, with one exception, maximum annual off-site concentrations of IVIEK around these facilities are below 1 Mg/M3 and maximum 24-hour concentrations are below 10 Mg/M3
. For one facility, the maximum annual off-site concentration was 1 .18 MgIM3 and the maximum 24-hour concentration was 12 .82 Mg/M3 .- However, for this facility, the point of the highest predicted concentrations was not at a location where 24-hour or annual exposure could occur . 2 . Generalized dispersion modeling of lesser MEK emitters indicates that maximum annual offsite concentrations are likely to be below I Mg/M3 in all cases, and well below 1 MgIM3 in most cases .
R\PUMPROJECTS141001bA100ALL 1-2 November, 1996p . 3 2 

# E M I There is little or no potential for significant air quality impacts from multiple sources of MEK emissions in the same area . That is, combined emissions from multiple sources will not cause maximum annual MEK concentrations greater than 1 .0 Mg/M3 or maximum 24-hour concentrations greater than 10 Mg/M3 . 1 .5 Report Organization This report is organized as follows
. A description of the approach used to identify and collect pertinent modeling input data from sources is provided in Section 2 . Section 3 describes the dispersion modeling methods applied to the top emitters . Modeling results for top emitters are presented in Section 4 . Section 5 discusses the method used to model emissions from smaller sources and presents the results of this analysis . Section 6 then addresses the issue of collective emissions from multiple sources . Section 7 summarizes the study findings . Appendix A provides the forms that were used to solicit source information for modeling and Appendix B provides further information on the generic method used to model emissions from lesser MEK sources
.

RAPUBMPROJECTS\14100IM100ALL 1-3 November, 1996

### p . 33 1119116MIN 2 .0 SOURCES SUBJECT TO SITE SPECIFIC MODEUN G 

### 2 .1 Identification of Top Emitters The Ketones Panel has undertaken a program to gather data on the maximum airborne concentrations of MEK to which the public may be exposed . As part of this program, the Panel funded a study by ENSR to model the maximum off-site concentrations of MEK at the largest sources of MEK emissions in the country . To identify the facilities to be included in this study, the Ketones Panel used the methodology that EPA developed to set de minimis values for hazardous air pollutants under Section 11 2(g) of the Clean Air Act (EPA, 1993) . The de minimis value for a chemical is the amount that an EPA model facility could emit without posing more than a "trivial" risk to human health or the environment . EPA has proposed to "cap" de minimis levels at 10 tons per year, but EPA's methodology may also be used to calculate true "uncapped" de minimis values for different compounds . Using EPA's methodology, the uncapped value for MEK is 2,000 tons (or 4,000,000 pounds) per year, calculated using an inhalation reference concentration (RfC) of 1 .0 Mg/M3, which is the existing value in the IRIS database .' In order to establish a meaningful cutoff point for its modeling exercise, the Panel decided that it would seek to model all facilities with reported emissions that were 10 percent or more of the uncapped de minimis value . Thus, it sought to model the maximum off-site concentrations for all facilities reporting MEK emissions of 200 tons (400,000 pounds) or more per year . Based on 1993 TRI data, the Panel identified 30 such facilities . 2 .2 Solicitation of Data The Panel also worked with ENSR to develop a detailed questionnaire to gather the information that would be necessary to model the maximum off-site concentrations at each facility . This questionnaire, along with a cover letter explaining the Panel's modeling program and the protection of confidential information, was sent to the 30 facilities . Representatives from the Panel also contacted each of the facilities to encourage their participation
. By the time the Panel received the necessary data and ENSR began its modeling exercise, the TRI data for 1994 had become available . From 1993 to 1994, the number of facilities reporting MEK TRI emissions greater thah 200 tons had dropped from 30 to 26 . Table 2-1 lists each of the facilities that ' 'Since the RfC : was established in the IRIS database, EPA has issued new guidelines for setting RfCs . Based on the new guidelines, the Ketones Panel has calculated that the correct RfC for MEK is 3 .3 Mg/M3 .
R :XPUBSkPROJEC'rS*\141001b\IOOALL 2-1 November, 1996p . 34 Mrqft


## TABLE 2- 1 Listing of Top MEK Emitters FadHty :199K4 2 . Diet COMP2 Location --- Bus Obs.) SIC Code . Gencorp Coliunbus, MS 2,026,760 22 (Nonwoven Fabrics) O'Sullivan Winchester, VA 1,366,079 30 (Plastics) IPC Corinth, MS 1,256,755 30 (Plastics) Mobil Oil Beaumont TX 1,216,000 29 (Refining) 3M Specialties Hutchinson, MN 1,010,000 36 (Electronic) Columbus Fabrics Columbus, OH 867,838 22 (Coated Fabrics) Texas Recreation Corp Wichita Falls, TX 790,100 30 (Plastics) Uniroyal Stoughton, WI 714,199 22 (Nonwoven Fabrics ) Sun Refining Tulsa, OK 701,000* 29 (Refining) Alcoa Riverxiale, IA 694,000 33 (Aluminum) Resilitesports Northumberland . PA 648,757** 39 (Ivfisc . Wg .) 3M Specialties Kearneysville, W 626,360 35 (Ind. Machinery) R.J . Reynolds Tobacco Winston-Salem, NC 609,594 21 (Cigarettes) Reynolds Metals Sheffield, AL 578,000 34 (Metal Coating) Amoco Corp . Whiting, IN 558,000 29 (Refining) Plastene Supply Co . Portageville, MO 550,373 34 (Metal Coating) Sony Products Dothan, AL 540,291 36 (Electronic) Shell Oil Deer Park, TX 536,370 29 (Refining) Norandal USA Inc. Newport, AR 518,175 33 (Aluminum) 3M Specialties White City, OR 517,000 38 Qvleanwing hist .) Textileather Corp
. -Toledo, OH 510,000 22 (Nonwoven Fabrics ) Allied Tube and Conduit Harvey, IL 506,000 33 (Aluminum) Textrm Automotive Americus, GA 489,189 37 (Mot. Veh . Parts) Reynolds Metals Richmond, VA 405,000 33 (Aluminum) Boeing Everett, WA 400,000 37 (Airline) Sun Oil Co. Yabucoa, PR 400,000 29 (Refining) Athol Corp . Butqer~ NC 397,000 22 CNonwoven Fabrics ) Siti-Re tfi4 Co~ has inforniM : dieXi Rinal # iat I it recenW condik-ted. : to : ~'.-cmissiom
..tests)a&khin~that. :i.tsl994&MK .en3i~ the air were otmstated by a and w= actually well below ::400;WO pouad& The 1995 Form R for this facilfty more .ii*wiately SiVempissions.:4 241

M-ports : AMpounds . B~ on this information the: Panel :hkSlidt 11201wed: disOmiah modeling resultsIor this facility ~ F"i Resffit6 :pr*ykIedJ995. MEK-em2ssi . em.fwji-34. IW) :tI6:be-.u

RAPUMPROJECM1410016NI00ALL 2-2 November, 1996p . 35
VIIIIIJIMIN MR&M 

### reported MEK emissions of greater than 200 tons on the 1994 TRI, along with the SIC code for each facility. As noted in Table 2-1, three of the listed facilities have revised MEK emissions that are below the 200 ton criterion that is used to define the top-emitters . The rule of thumb applied is that such a facility would be included in the top-emifter assessment if the revised annual MEK emissions exceeded 90% of the 200 ton criterion . Thus , Resilite Sports was included in the analysis along
. with Athol Corporation, for which the MEK TRI emissions estimate dropped to just below 200 tons in 1994 . The SIC codes indicate that the top-emitting facilities represent a wide variety of industries
. Facility-specific data needed for modeling was received from 14 facilities, including the 4 highest emitters . In addition, one facility provided results of dispersion modeling for MEK emissions that had already been conducted independent of this study . Thus, facility specific information or preexisting dispersion modeling results were obtained from 15 of the 26 highest-emiffing MEK sources in the country, including 6 of the top 10. In order to conduct dispersion modeling for the other 11 facilities identified as top emitters, the Panel and ENSR attempted to obtain relevant facility data from public sources . For each facility, we conducted a search on EPA's Aerometric Information Retrieval System (AIRS) database . In addition, we contacted state and local regulatory officials to determine whether a Title V permit application or similar document had been submitted by any of the remaining facilities . Title V permit applications were obtained for 4 of the 11 remaining facilities . Based on the information available from the AIRS database and permit applications, ENSR was able to conduct refined dispersion modeling for 5 of the 11 facilities that did not provide information directly to ENSR. In situations where detailed information on specific data elements (such as stack height, building height, etc .) were not available from these sources, reasonable, conservative estimates of these elements were made . For the other 6 facilities, no facility-specific data was available . For each of these facilities, ENSR modeled maximum off-site concentrations using the generalized model described in Section 5 . Table 2-2 shows the basis for modeling each of the 26 top-emitting facilities . Table 2-3 shows specific data elements that were obtained from publicly available sources for facilities that were modeled b~sed on limited data, as well as the estimates that were made in the absence of such data . Listed in Table 2-4 are facilities for which a generalized modeling approach was applied because no relevant data were obtained .

RAPUMPROJECTS\14100M100ALL 2-3 November, 1996p . 36 

# ENR TABLE 2-2 Basis for Dispersion Modelin g Site $pecifiz Information Provided by the Following Companies :

Gencorp - Columbus, M S O'Suffivan - Winchester, VA IPC - Corinth, M S Mobil Oil - Beaumont, TX Columbus Fabrics - Columbus, OH Uniroyal - Stoughton, WI Resilite Sports - Northumberland, PA Reynolds Metals - Sheffield, AL Amoco Corp . - Whiting, I N Sony Products - Dothan, AL Shell Oil - Deer Park, TX Textileather Corp . - Toledo, OH Sun Oil Co . - Yabucoa, PR Athol Corp . - Butner, N C . . . . . . . . . . . . . . .. . . -MW6-.~,ReWts;Pi-oVW.ed:by- ;he FOkrwm-&C0mOq*s .



### R.J. Reynolds Tobacco - Winston-Salem, NC .9 :S~ M6&66 Biiiiea b 

### ecifio~ g:

. 66:Pu ii&. Data fbr. . 3M Specialties - Hutchinson, MN 3M Specialties - Kearneysvffle, WV 3M Specialties - White City, OR Alhed Tube and Condtnt - H IL Boeing - Everett, WA EPA 112(g)U, dXXIC40gy- pofmmed Texas Recreation Corp. - Wichita FaUs, TX Alcoa - Riverdale, IA Plastene Supply Co. - PortageviHe, MO Norandal USA Inc. - Newport, AZ Textron Automotive - Americus, GA Reynolds Metals - Richmond, VA

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## TABLE 2-4 Non -Participants for which Generalized Modeling was Conducted Gampmy . T .RI :1"4 fadIky .L*CatM- : .: : finktion Texas Recreation Corp

. 790,100 Wichita Falls, TX Alcoa 694,000 Riverdale, IA Plastene Supply Co. 550,373 Portageville, MO Norandal USA Inc. 518,175 Newport, AR Textron Automotive 489,100 Americus, GA R olds Metals 405,000 Richmond, VA

RAPUMPROJECTS\1410016MOO .ALL 2-6 November, 1996p . 3 9 

# E M Facilities participating in the CIVIA program provided site-specific data for modeling based on conditions of confidentiality . To this end, anonymity of modeling results was achieved by assigning a code to each participating facility . In addition, tables providing model input information which are normally provided in dispersion reports conducted, for example, in support of permit applications, have not been included
. 2 .3 Source Characterizatio n The questionnaire sent to participating companies requested the following information : General information : facility plot plan showing property boundary, fenceline, source locations, building and storage tank height, location indicated on a topographic ma p Point source information : emission rate, release height, temperature, flow rate, effective diameter, flow obstructio n Area source information : emission rate, height, site of the are a This information was used to develop input for dispersion modeling of MEK emissions . The actual annual emissions provided by the facilities were used to estimate annual average concentrations . In 4 cases, emissions data provided by the companies were slightly (less than 3%) lower than the emissions reported in the TRI . In one case, modeling was based on 1993 TRI emissions which exceeded 1994 TRI reported emissions by approximately 10% . For Reslite Sports modeled emissions were 43% less than the 1994 TRI data
. To model maximum 24-hour off-site concentrations, ENSR used maximum daily MEK emissions rates in the few instances where such information was provided by the facility . Otherwise, the maximum 24-hour concentrations were computed applying a daily emission rate based on the annual emissions divided by 260 days, (i .e ., assuming that the facilities operate on a five-day-perweek schedule)
.

RAPUMPROJECTS\1410016MOALL 2-7 November, 1996p . 40 W&XqI% Wdllmkft 

### 3 .0 DISPERSION MODELING METHODS FOR TOP EM17TERS OF ME K ENSR performed air quality modeling analyses for each of the top-emitting MEK facilities using EPA's "Tiered Modeling Approach for Assessing Risks Due to Sources of Hazardous Air Pollutants" (1992) . This approach uses three progressively more Hgorous modeling techniques
. Tier 1, which requires only limited source information and a look-up table, provides the most conservative predictions of maximum concentrations . Tier 2, which requires additional source information and uses an EPA screening-level computer program, generates predictions that are somewhat more realistic than Tier 1 predictions . Tier 3, which requires extensive data from the source and uses EPA's refined dispersion modeling techniques, provides the most realistic predicted concentrations . Because each successive tier provides a less conservative (and more realistic) prediction, Tier 3 modeling was generally performed for a facility only if Tier 2 modeling predicted maximum annual concentrations were above 2 MgIM3 . In all of these modeling methods, MEK is assumed to disperse in the atmosphere as a passive tracer, not subject to removal through deposition or chemical reaction duiring transport . This is a reasonable assumption given the typically short transport time (less than 10 minutes) f rom the source to the point of maximum impact
. 3.1 Tier 1 Modeling Approac h The Tiier 1 approach is based on a parameterization of EPA screening models . It is compirised of a set of look-up tables . Information required for Tier 1 modeling include : emission rate point source height size of area source distance to nearest property lin e The look-up tables provide emission-normalized 1-hour and annual concentrations for each source . These concentrations are multiplied by the corresponding source-specific emission rate to calculate the maximum off-site concentration . The maximum concentrations from individual sources are then added to estimate an overall maximum annual and 1-hour concentrations . To estimate maximum 24-hour MEK concentrations, the Tier 1 1 -hour concentrations were multiplied by a time averaging factor of 0 .4, as recommended in U .S . EPA's screening modeling guidance (U .S . EPA, 1992a) . The Tier 1 estimate is highly conservative because it does not account fo r

RAPUBSPROJECTS1 4 1 DOI 6\1 OOALL 3-1 November, 1996p . 4 1 

# E M plume rise or above ground area sources and assumes that maximum contributions from all sources are cumulative at a single receptor point . Tier 1 Exampl e The Tier 1 method is illustrated by the following example provided in the EPA guidance document. Consider the situation in which a toxic pollutant A is released at a rate of 14 .6 ton/yr from a vent-pipe that is 40 m tall, and which is attached to a building that is 4 m tall, 10 m long, and 5 m wide . The nearest boundary of the facility is located 65 m from the vent . Table 3-1 is EPA's look-up table for determining Tier 1 maximum annual concentrations
. A value of 35 m is selected for the emission height, because all larger entries in the table exceed the actual release height of 40 m . Concentrations are estimated for a distance -of 50 m, because once again, all greater entries in the table exceed the actual distance of 65 m . The appropriate normalized maximum annual concentration is 1 .13 (gg/M3)/(ton/yr) . Multiplying by the emission rate of 14.6 ton/yr results in a maximum annual concentration estimate for screening purposes equal to 16 .5 gg/M3. 

### 3 .2 Tier 2 Modeling Approac h Tier 2 uses a computerized U .S . EPA screening model, SCREEN3, to estimate maximum off-site concentrations . SCREEN3 predicts maximum 1 -hour concentrations which are then multiplied by a scaling factor of 0 .4 to estimate maximum 24-hour concentrations and 0.08 to estimate maximum annual concentrations (U .S . EPA, 1992a) . In addition to the information required for Tier I modeling, Tier 2 modeling requires : inner stack diameter stack gas exit velocity stack gas temperature worst-case building dimensions for aerodynamic downwash simulation rural/urban dispersion environment classificatio n U .S .G .S. topographic maps were examined to determine land use within a 3 krn radius of each of the top-emitting facilities
. If over 50% of the area has urban land use, then SCREEN3 was applied witfi urban dispersion coefficients . Otherwise, rural dispersion was specified
. If the classification of an area was ambiguous, the model was run in both modes and the greater of the two results was used in the assessment .

RAPUBSPROJECTSkI410016%100ALL 3-2 November, 1996p . 42

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RAPUSSPROJECTSA141001M100ALL 3-3 November, 1996 9/p . 43

E M 

### SCREEN3 simulates building downwash based on the dimensions of the structure, which result in the highest Good Engineering Practice stack height, determined by the formula : GEP = building height + 1 .5 x L (where L is the lesser of building height or width) . All buildings within a distance of 5L are considered . SCREEN3 modeling was performed separately for each point and area source with receptors placed at a distance closest to the nearest fenceline and at 100 m intervals to 2 krn assuming flat terrain . As was the case with the Tier 1 calculations, the maximum modeled impacts for multiple sources were assumed to completely overlap, such that the Tier 2 modeled estimate is highly conservative . Tier 2 Exampl e To illustrate the Tier 2 long-term analysis, consider the Tier I example . To consider downwash possibilities, the maximum horizontal dimension f(l OM)2 + (5m)j"2 = 11 .2m) is first compared to the 4 m building height . The dimension L is then the building height of 4m, such that the maximum stack height for which downwash is possible would be 4m + 1 .5 X 4m = 1 Orn . Since the actual stack height is 40 m, downwash need not be considered in the SCREEN3 simulation . The emission rate specified in the example of 14 .6 ton/yr is converted to grams per second (g1sec) to be used in the SCREEN3 simulation, resulting in an annual emission rate of 14.6/34 .73 = 0 .42 g/sec. In addition to the actual stack height (40m) and minimum fenceflne distance (65m), input parameters for the SCREEN3 simulation are : Inside stack diameter 0 .5m Stack gas exit velocity 5 .6 m/s Stack gas exit temperature 303 K Plant location urba n The results from the SCREEN3 simulation indicate that the maximum 1 -hour concentration (based on an annual emission rate) at or beyond 65m is 32 .5 4M3, occurring 165m downwind . After incorporating the recommended conversion factor of 0.08, the maximum annual concentration is estimated as 2 .6 gg/m3 - a value that is a factor of 6 lower than the Tier 1 estimate of 16 .5 RgIM3 . 3 .3 Tier 3 modeling approac h Tier I and 2 screening was used to predict maximum annual and maximum 24-hour concentrations for all top emitting facilities for which adequate data were available . Refined Tier 3 modeling was applied only to those few facilities with the highest modeled Tier 2 concentrations
.
RAPUMPROJECMI 41001V WALL 3-4 November, 1996p . 44 z&Xq% 

### Modeling was performed in accordance with the EPA tiered approach and Guidelines on Air Quality Models (EPA 1992, 1995) . The modeling applied the U .S . EPA's Industrial Source Complex Short Term Model (ISCST3), which is the guideline model for simulating point sources subject to aerodynamic building downwash and area sources
. ISCST3 incorporates information on the facility layout with respect to property boundary, source location and building dimensions and can compute concentrations for 24-hour and annual averaging periods . As shown in Figure 3-1, model receptors were placed along the property boundary and in a 100 m x 100 m square grid out to 2000 m . Given that all of the sources modeled were either area sources or point sources subject to building wake effects, maximum modeled off-site concentrations always occurred adjacent to the property boundary . As such, variation in terrain surrounding the facility was not considered in the assessment . Refined Tier 3 modeling used representative, National Weather Service (NWS) surface and mixing height data, obtained from U .S . EPA's SCRAMS Bulletin Board . Meteorological site selection was based on proximity and geographical setting
. Five years of meteorological data were modeled and the maximum annual and 24-hour concentrations among each of the five years of data were used in the impact assessment . That is, the annual concentration represents the highest average concentration occur7ing for any single year over the five years modeled, and the 24-hour concentration is the highest concentration that was modeled for any day over the entire 5 year period .

RAPUBSPROJECTSM410016MOALL 3-5 November, 1996p . 45 w2jrqwb


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3-6 November, 1996p . 4 6 

# EM 4 .0 EVALUATION OF MAXIMUM OFF-SITE CONCENTRATION S

AT HIGHEST EMITTING FACILITIE S Results of the tiered modeling for top MEK emission sources are provided in Tables 4-1 and 4-3 for maximum annual and 24-hour concentrations, respectively . Tables 4-2 and 4-4 present the same data sorted according to how the information for modeling was obtained . Facilities are ranked according to Tier 2 modeling results, in descending order . Of the top facilities, 19 had Tier 1 and 2 screening performed and 7 had additional Tier 3 refined modeling performed . One facility had already conducted screening or refined modeling independently of this study . For the 6 top emitting facilities for which site information was not obtained, the values listed on the tables are based on the generalized modeling approach discussed in Section 5. It is important to recognize that the health benchmarks for MEK are based on continuous exposure . The RfC (3 .3 mg/m3) is specifically designed to be protective for continuous exposure for a lifetime of 70 years, and the 24-hour benchmark (33 .0 Mg/M3) is designed to be protective for continuous exposure over a 24-hour period . The maximum off-site concentrations computed in this assessment, however, are not intended to represent actual population exposure . In many instances it is unlikely that locations where maximum off-site concentrations are modeled are places where continuous exposure can actually occur . In every case, modeled maximum off-site concentrations are located near the facility boundaries . The top MEK emitters are large facilities which are likely to be surrounded by industrial and commercial properties. As such, receptors close to the facility boundaries are areas where the exposure time is typically no more, and probably significantly less, than 8 hours per day, 5 days per week rather than continuous . It is also important to recognize that the off-site concentrations computed in this assessment are maximum annual and 24-hour concentrations . Even at the worst-case fenceline locations, actual off-site concentrations averaged over one-year and 24-hour periods are likely to be lower
. Table 4-1 shows that the highest modeled annual Tier 2 concentration, which occurs for facility E17, is about 12 MgIM3 and the corresponding Tier 3 concentration is 1 .2 Mg/M3
. The model receptor where the maximum concentration occurs is located across the roadway from facility El 7, near the vehicular entrance to an industrial area . As such, it does not represent a receptor where 24-hour exposure is possible . The modeled annual concentration at the second highest off-site receptor at this facility is 0 .81 MgIM3
. Annual Tier 3 concentrations at WI other facilities are Wso below I Mg/M3 . 

### Tier 3 modeling was conducted for each facility at which the Tier 2 predicted concentration was greater than 2 .0 mg/m' . The highest Tier 2 concentration for which refined modeling was not conducted is 1 .77 Mg/M3
. As anticipated, Tier 3 concentrabons are substantially lower than th e
RAPUBSPROJECTSM 410016\100ALL 4-1 November, 1996p . 47

IIIIIIWFI~ 

## TABLE 4- 1 MEK Dispersion Modeling Results for Top Emitters

Maximum Annual Averag e M 3.3 mg/nr~+ . ~Tiet I. .. 'r 2 Tw E17 29 .0 12 .33 1 .18 E9 33 .0 11 .2 0 .91 E28 13 .7 4 .75 0 .81 E7 14 .5 3 .97 0 .50 E25 38 .1 3 .37 0 .42 E4 17 .1 2 .99 0 .55 E3 12 .3 2 .65 0 .63 E20 19 .4 1 .77 - E33* 5 .5 1 .56 - E19* 8 .5 1 .42 - E21 14 .6 1 .37 - E14* 6 .9 1 .23 - E29 26 .5 1 .13 - E16* 6 .9 0 .69 - E23 9 .9 0.46 - E8 9 .7 0 .42 E32 6 .2 0 .18 El 9 .2 0 .12 Ell* 0.2 0. 1 E15 - - 0 .03** *Model input parameters for non-participating facilities have been estimated from available data sources (see Table 2-2)
. ** Based on dispersion modeling results provided by individual companies . + Based on RfC for MEK in EPA's IRIS database updated to reflect 1994 EPA guidance on deriving RfCs . Updated RfC provided by CMA Ketones Panel
.



### 4-2 November, 1996p . 48



## TABLE 4- 2 MEK Dispersion Modeling Results for Top Emitters

Maximum Annual Averag e nuaNSK: cmWentmtkit (mgfw) :Ow 3.3 mgfw) Site . Tier I rier 3 Tier 2 

### ~Site Specific Modeling Completed : E17 29 .0 12 .33 1 .18 E9 33 .0 11 .2 0.91 E28 13 .7 4 .75 0.81 E7 14 .5 3.97 0.50 E25 38 .1 3 .37 0 .42 E4 17.1 2 .99 0.55 E3 12 .3 2 .65 0 .63 E20 19 .4 1 .77 - E21 14 .6 1 .37 - E29 26 .5 1 .13 - E23 9.9 0 .46 - E8 9 .7 0 .42 - E32 1 6.2 1 0.18 1 El 9 .2 0 .12 ~site~:SpecifioModeling~~-C6mpk~ed ;Bgsod .. . PubliciData . : E33 5.5 1 .56 E19 8 .5 1 .42 E14 6.9 1 .23 E16 6.9 0.69 Ell 0 .2 0.1 Rists P m6ded . . .: E15 0 .03 ~~ :M~~ .ResWts: Table. 4TActor . DC x AnnuOlIN18K . Siw J.:994 TRI Emissiowfdbl per
. :0~6~(MgWY E12 790,100 0.91 M 0.72 E2 694,000 0.39 (M 0.27 ElO 550,373 0 .91 M 0.50 E18 518,175 0 .91 (M) 0 .47 E34 489,189 0 .39(14) 0 .19 E35 405,000 0.39(1-1) 0 .16 Dispersion Category
RAPUBSPROJECTS\14100M100ALL 4-3 November, 1996p . 4 9 

# EM TABLE 4- 3 MEK Dispersion Modeling Results for Top Emitters

Maximum 24-Hour Averag e ir Concentradon (mg/W) (Benichmark := 33.0 mgfm3,)+ site Tier I TierI T+ier 3 E17 186 .8 86 .3 12 .82 E9 196 .2 64 .0 7 .42 E28 137 .0 33 .3 5 .24 27 .8 4 .67 E7 81 .9 

# 17n- E3 58 .2 18 .5 2 .44 E25 232 .3 16 .85 2 .77 E4 73 .0 15 .63 7 .57 E20 108 .5 12 .39 - E19* 47 .6 9 .91 - E21 146.3 9 .57 - E14* 38 .3 8 .58 - E33* 35 .0 8 .27 - E29 144 .2 7 .9 1 E16* 38.5 4 .86 - E23 115 .2 3 .21 - E8 54 .4 2 .93 - E32 35 .0 1 .23 - Ell* 1 .2 0.72 - El 36 .7 0 .5 9 E15 - - LL*Lj 0 .35** *Model input parameters for non-participating facilities have been estimate d from available data sources (see Table 2-2)
. ** Based on dispersion modeling results provided by individual companies . + Based on updated RfC modified to eliminate uncertainty factor for extrapolating from chronic to subchronic exposures . Value provided by CMA Ketones Panel
.

RAPUBSAPROJECTSM 4100 1 M100ALL 4-4 November, 1996p . 5 0 

# EM TABLE 4-4 MEK Dispersion Modeling Results for Top Emitters

Maximum 24-Hour Averag e Max 24-hrCencelit!ttlLon,(VWM3)~ :(Bmchmw*~= 0- .Iftghn"~ . Tier. I Tier 2 . L Tw-r-3 Site Specificl&deling Completed E17 186 .8 86 .3 12 .82 E9 196 .2 64 .0 7. ~2- E28 13 33 .3 5 .24 E7 81 .9 27 .8 4 .67 E3 58 .2 18 .5 2 .44 E25 232 .3 16 .85 2 .77 E4 73 .0 15 .63 7 .57 E20 108 .5 12 .39 - E21 146.3 9 .57 - E29 144 .2 7 .91 - E23 115 .2 3 .21 - E8 5 .4 2 .93 - E32 35 .0 1 .23 - El 36 .7 0 .59 - site COmplOt6l : wPubh&Data ..:, . E33 35 .0 10.89

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R .\PUBSAPROJECTSA1410016\100ALL 4-5 November, 1996 ~~ 0p . 5 1 

# E M corresponding Tier 2 results . For the seven facilities for which Tier 3 modeling was performed, the Tier 3 value was between 76% and 92% lower than the corresponding Tier 2 value, with an average of 85%. Thus, it appears reasonable to anticipate that Tier 3 values will be lower than corresponding Tier 2 values by at least 76%. For illustrative purposes, this reduction factor has been applied to develop "adjusted Tier 2" values for all of the remaining sites for which Tier 2 modeling (but not Tier 3 modeling) has been conducted . The highest adjusted Tier 2 value is 0 .42 Mg/M3 (1 .77 x 0 .24) . The predicted maximum annual off-site concentrations for all the top emitting facilities are plotted on Figure 4-1, with adjusted Tier 2 values shown where Tier 3 values were not computed . As indicated on Figure 4-1, maximum off-site annual concentrations at all of the top emitting facilities are well below the RfC of 3 .3 Mg/M3 and, in most cases, are well below 1 mg/M3. The average of the maximum annual off-site concentrations at the top-emitting facilities (including adjusted Tier 2 values where Tier 3 values were not derived) is about 0 .3 Mg/M3 . Modeled maximum 24-hour average concentrations are provided in Table 4-3 . The highest offsite Tier 3 concentration of 13 MgIM3 (for facility El 7), occurs at the same isolated receptor as has been noted for the annual modeling and is not representative of public exposure . The second highest concentration among all other off-site receptors in the vicinity of that facility is 8.3 mg/m3 . All other Tier 3 modeling results are below 10 Mg/M3 . Where Tier 3 modeling was performed, the Tier 3 24-hour concentrations were between 51% and 91% lower than the corresponding Tier 2 value, with an average of 80%. Thus, it appears reasonable to anticipate that Tier 3 24-hour values will be lower than the corresponding Tier 2 values by at least 5 1 For facilities for which Tier 3 modeling was not performed, adjusted Tier 2 24-hour concentrations were estimated by reducing the Tier 2 value by 51% . This results in a maximum adjusted Tier 2 24-hour concentration of about 6 Mg/M3
. Figure 4-2 shows Tier 3 and adjusted Tier 2 maximum 24-hour off-site concentrations for all of the top-emitting MEK facilities . As indicated on Figure 4-2, maximum 24-hour concentrations at all of the top emitting facilities are well below the health benchmark of 33 Mg/M3 and, in most cases, are well below 10 Mg/M3
. 

### In evaluating the maximum 24-hour concentrations, it is again important to recognize that they are intended to represent maximum off-site concentrations, not actual human exposure . As noted above, these concentrations were predicted to occur at or near the facility fenceline, where continuous 24-hour human exposures are unlikely . The predicted maximum 24-hour concentrations are also based on the worst-case dispersion meteorology occurring in the area of the facility during any day over a 5 year period, and should therefore be viewed as being conservative .

R :XPUBSNPROJECTSkl4lOol6\100-A.LL 4-6 November, 19% 6p . 52

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# EM 5 .0 EVALUAT10N OF LESSER MEK SOURCE S The second part of this study was designed to estimate maximum airborne concentrations in the vicinity of lesser MEK emitting facilities . Because of the large number of facilities reporting more than 10 ton/yr MEK emissions on the TRI (over 2300), it is not feasible to conduct facility-specific modeling for even a significant portion of them
. ENSR therefore applied a generalized approach for estimating maximum off-site concentrations from lesser emitting facilities . As noted above in Section 2 .2, this generalized approach was also used to estimate maximum annual off-site concentrations for top-emitting facilities for which site-specified information was not obtained
. 5 .1 Generalized Modeling Approac h ENSR developed a generalized approach for estimating maximum off-site concentrations from smaller facilities with between 10 and 200 tons/yr of MEK emissions according to TRI data . First, the TRI database was used to sort all facilities that reported more than 10 tons of MEK emissions on the 1994 TRI into source categories based on their two-digit SIC codes . SIC codes for which Tier 1, 2, or 3 modeling had already been performed were not considered
. A generalized dispersion modeling approach was then used to conservatively estimate the maximum annual average concentrations in the vicinity of sources in each category . The annual MEK emissions for the two facilities with the highest and second-highest emissions in each of the identified SIC codes were used in the assessment . The U .S . EPA dispersion modeling approach used in support of the proposed 11 2(g) rulemaking was used in this categorical assessment (EPA, 1993) . EPA conducted dispersion modeling using the Human Exposure Model (HEM) to estimate maximum annual concentrations as a function of distance and source height . EPA's modeling assessment conservatively used the following assumptions: all facility emissions emanate from a single point source, negligible exit velocity (10 cm/sec) , emitted at ambient temperature , source subject to worst-case aerodynamic building downwash . HEM uses climatological data in the form of a joint frequency distribution of wind speed, wind direction and atmospheric stability. EPA applied HEM using 314 separate climatological data sets based on NWS stations located throughout the United States and a single stack heighttreceptor distance combination (10 m stack, 200 m receptor) . Annual concentrations associated with a 1 0

RAPUBMPROJECTS\1 410016\1 WALL 5-1 November, 1996p . 55 1111191116111!qb OW11HU M 

### ton/yr release varied widely among the 314 data sets with the highest annual concentration (15 .6 ug/m') being a factor of 3 .1 greater than the median concentration (5 .0 Ug/M3) . EPA then conducted an additional sensitivity analysis, using the median dispersion climatology, to determine how modeled annual concentrations would vary depending upon different combinations of source height and receptor distance . The results of this sensitivity analysis are summarized in Table 4 of the EPA document and provided in Appendix B (EPA, 1993) . For the MEK study, an upper limit concentration has been estimated for various combinations of stack height, and receptor distance by multiplying the EPA Table 4 dispersion coefficients by a factor of 3 .1 . This approximates the highest annual average concentration that would occur at the location (in the United States) that has the worst dispersion climatology
. This conservative method was used to estimate concentrations at nearby receptors for "model" facilities representing the largest emitters in each of the SIC codes . To simplify the analysis, a model facility (defined in terms of stack height and receptor distance) has been defined for the following three "Dispersion Categories" to which each of the SIC codes is assigned. Heavy : Major facilities typically located in highly industrialized areas with substantial building dimensions on relatively large sites (stack height = 15 m, receptor = 200 m ) Medium : Moderate size facilities typically located in industrially or commercially zoned areas on medium-sized properties (stack height = 10 m, receptor = 150 m ) Light : Smaller typically one-story facilities with roof vents and limited site acreage located in mixed use areas (stack height = 5 m, receptor = 100 m ) EPA Table 4 dispersion factors (Appendix B) were estimated for each category (using linear interpolation where necessary) and then multiplied by a factor of 3 .1 to adjust for worst-case dispersion climatology . This resulted in the following dispersion factors for each category, in units of mg/m3 per million pounds of MEK emissions : Light : 4 .1 Medium : 0 .91 Heavy :- 0 .39 5 .2 Estimated Receptor Concentration s Table 5-1 provides the applicable SIC codes, representative dispersion category, and corresponding dispersion factor . These dispersion factors were then multiplied by the emissio n
RAPUMPROJECTS\1410016\100ALL 5-2 November, 1996p . 5 6 

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### 5-3 November, 1996p . 57
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### rates of the highest and second-highest MEK emitting facilities in each SIC code . As indicated on Table 5-1, the resultant concentration estimates are all below 1 mg/M3 and well below 1 mg/M3 in most cases . The Tier 3 results for the top emitters indicate that maximum 24-hour concentrations are a factor of 4 to 14 times greater than the annual concentrations
. If the upper limit annual to 24-hour averaging time adjustment factor of 14 is applied, the highest estimated 24-hour concentration among the SIC code is about 7 Mg/M3, well below the 30 mg1m' benchmark. To verify the validity of this generalized approach, it has also been applied to the SIC codes of the top emitters, for which refined modelling was already conducted . The facility with the maximum emissions represented each SIC code and was modeled using the generalized methodology and the results were then compared with the maximum refined modeled concentration (both Tier 3 and adjusted Tier 2, as illustrated in Figure 4-1) among the sources belonging to that SIC . The results are shown on Table 5-2- . For all SIC codes, the generalized approach predicted higher concentrations than the refined assessment, thus demonstrating that the generalized approach is conservative . Generalized modeling results for several top MEK emitters provided in Table 4-2 also indicate annual concentrations well below 1 Mg/M3
. Given the demonstrated conservatism of the generalized approach, actual off-site impacts are likely to be substantially lower
.

Note that Table 5-2 shows the maximum annual emissions for the top-emitting facility in each SIC code, along with the genedc annual off-site concentration estimate for that facility . However, the column labeled "Maximum Refined Concentration (MgIM3) in SIC Codeu is not necessarily the refined modeling result for the same facility . Rather, it represents the highest annual off-site concentration modeled among all facilities in that SIC code, which may or may not correspond to the facility with the highest annual emissions. As noted above, the facilities provided sitespecific data for modeling based on conditions of confidentiality, and this approach was necessary to preserve the confidentiality of the refined modeling results
.

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RAPUBSPROJECTSA14100MI00ALL 5-5 November, 1996p . 59

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### 6 .0 COMBINED IMPACT S The dispersion analyses of both the top-emitting facilities and smaller sources have demonstrated that maximum off-site concentrations at potentially exposed receptor locations are less than about 30% of the annual and 24-hour benchmarks (3 .3 Mg/M3 for annual and 33 mg/M3 for 24-hour) .As such, there are no combinations of sources (unless three or more sources are virtually colocated) that could result in receptor concentrations exceeding the health protective benchmarks

. Hypothetically, for sources to contribute to off-site receptor concentrations above the RfC, at least 3 major MEK emitters would need to be side-by-side with a receptor located between them . As can be noted from Table 2-2, none of the top MEK emitting facilities are located in the same geographic area . Although the modeling analysis indicates that combined impacts are highly improbable, an investigation was made to identify clusters of MEK sources to review the potential for combined impacts . As a first step, the 1994 TRI database was used to identify all MEK sources reporting more than 10 tons of MEK emissions in 1994
. Of the 800 facilities identified, 709 facilities were the only MEK source within the (5 digit) zip code area. The other 91 facilities are distributed fairly evenly among 37 zip code areas . Of these areas, 34 had total annual MEK emissions of less than 200 tons . One zip code contained as many as 5 facilities, but with combined annual emissions of only about 100 tons . Refined dispersion modeling for top MEK emitters has demonstrated that single facilities emitting 200 tons per year or more result in ambient annual concentrations of less than 1 MgIM3
. For the 34 zip code areas, even if all the facilities in the area were co-located, refined modeling suggests that off-site concentrations are highly unlikely to exceed 1 .0 mg/m3 . One of the remaining 3 zip code areas had one facility among the top 26 emitters of MEK (modeling indicated concentrations in the vicinity are well below benchmark concentrations) and another facility emitting less than 15 tons per year. Because the smaller source represents only about 5% of the total emissions in the area, concentrations would not increase appreciably even if the 2 sources were co-located
. The remaining 2 zip code areas that had multiple sources collectively emitting more than 200 tons were examined according to the following distance criterion . The modeling analyses of the top emitting MEK sources were reviewed to determine the maximum separation distance for two sources to potentially have a combined impact greater than 1 .0 mglm3 . This distance was conservatively estimated by doubling the maximum modeled distance corresponding to an annual concentration of 0 .5 Mg/M3
. Refined modeling indicates that airborne concentrations fall of f
RAP UBSPROJECTS\1 4 100 1 MI WALL 6-1 November, 1996 1)p . 6 0 

# EM N rapidly with distance . Among the 7 top emitting facilities for which Tier 3 modeling was conducted, annual concentrations exceeded this value out to a maximum distance of 175 m (about one tenth of a mile) beyond the facility fenceline . Therefore, a receptor would have to be located between two large MEK emitting facilities, located 350 m (about two tenths of a mile) apart if there is to be a possibility of annual concentrations greater than 1 .0 mg/M3 . The 2 zip code areas evaluated with this criterion each contain two principal sources . Refined modeling has indicated that 2 major sources separated by more than 350 m would avoid significant overlapping impacts . The distance between sources within these 2 zip code areas exceeded this distance . Therefore, it is concluded that combined impacts from multiple sources of MEK will not result in ambient levels greater than either 1 .0 mg/M3 (annual average) or 10 Mg/M3 (24-hour average)
.

R :\PUESPROJECrS\1410016\100ALL 6-2 November, 1996

### p . 61

7 .0 CONCLUSIONS 

### A dispersion modeling analysis was conducted to evaluate maximum off-site concentrations of MEK in the vicinity of both large and small sources of MEK emissions . Site specific modeling was performed for 20 of the 26 facilities that reported MEK emissions of 400,000 pounds or more in 1994 . The remaining 6 facilities were modeled using a generalized air dispersion modeling approach used by EPA in its CAA Section 112(g) rulemaking . The same generalized approach was used to estimate maximum off-site concentrations that result from MEK emissions from smaller sources . For this analysis, all facilities that reported more than 10 tons of MEK emissions on the 1994 TRI were divided into source categodes based on their two-digit SIC codes. Parameters were developed for each SIC code and the generalized approach was then used to predict likely maximum airbome concentrations based on the emissions rates for the highest and second-highest emitting facilities in each SIC code . In evaluating this study, it is important to recognize that the modeling results are intended to represent maximum off-site concentrations (averaged over one year or 24 hours) and are not intended to represent actual human exposures . For each of the top-emitting facilities, the location of the maximum modeled concentration was at or near the facility fenceline, where there are unlikely to be continuous exposures for more than a few hours a day . On the other hand, the health benchmarks used in this study are designed to be protective for continuous exposures
. In addition, the modeling itself (even Tier 3 analysis) incorporates certain assumptions that are relatively conservative . Actual off-site concentrations are likely to be lower than maximum modeled concentrations, and actual exposures are likely to be much lower
. The modeling study demonstr*ates that (1) maximum annual off-site concentrations of MEK are expected to be less than 1 MgIM3 in all cases, and well below 1/Mg/M3 in most cases ; and (2) maximum 24-hour off-site concentrations of MEK are expected to be less than 10 Mg/M3 in all cases, and well below 10/Mg/M3 in most cases. The one exception is a major emitter for which the maximum annual off-site concentration was 1 .18 Mg/M3 and the maximum 24-hour concentration was 12 .82 Mg/M3
. At this facility, however, there were no receptors near the point of the highest predicted concentrations
.Finally, there is no group of MEK emitting facilities that collectively would result in maximum offsite concentrations greater than 1 MgIM3 (annual average) or 10 gIM3 (24-hour average) .

RAPUMPROJECTS\14100M100ALL 7-1 November, 1996p . 6 2 

# EM REFERENCE S EPA, 1992 . A Tiered Modeling Approach for Assessing the Risks Due to Sources of Hazardous Air Pollutants . EPA-450/4-92-001 . U .S. Environmental Protection Agency, Research Tringale Park, NC . EPA 1992a . Screening Procedures for Estimating the Air Quality Impact of Stationary Sources, (Revised . EPA 454/R-92-019 . U .S . Environmental Protection Agency, Research Triangle Park, NC. EPA, 1993. Documentation for DeMinimis Emission Rates for Proposed 40 CFR Part 63, Subpart B (EPA-453/R-93-035)
. EPA, 1995 . Guideline on Air Quality Models (Revised)
. EPA-450/2-78-027R, including Supplements A, B and C . U .S . Environmental Protection Agency, Research Triangle Park, NC .

RAPUBMPROJECTSM 4100 16\100ALL November, 1996p . 63

own



### APPENDIX A DATA REQUEST FORM S

RAPUMPR0JECTS\1410016'%100 .CVS NoveMber, 1996p . 64 

## CHEMICAL MANUFACTURERS ASSOCIATIO N

KETONE PANE L Data Request for Air Quality Modeling Your Name and rdJe : Your Company's Name : Your Voice Phone Number -Your FAX Number Please complete Parts 1, 11, and III for your facility
. Pan I - Gworall Faaffity kftrmano n Please provide the following information for your facility : 1 . A plot plan of the facility showing the property boundary, fenceline, source locations (by source names), building locations, and building heights (Hb) above ground level . Include significant storage tank locations and heights

. hints . . . . . * Multiple tiered buildings, Hb = height above ground of each tier
* Peaked roof, Hb = ground to the highest point of the roof
* Outdoor process equipment - • May disturb the wind like a buildin g • ApproArnate the area of this equipment on the plot pla n • Hb = height that would represent about 90% of the process equipment area. 2 . A U .S .G.S . topographic map of the area, showing the location of the facility, or UTM coordinates or latitude and longitude, and average ground-level elevation
. Pan 11 - Poiffl Soume hdornudo n Please complete Table 1 for your facility . Large number of (nearly) identical sources? List one representative source plui a footnote indicafing the number of such sources and their identification numbers which cross-reference their location on the plot plan
. Only know the total emissions for a group of sources? Do they have very similar release characteristics? If yes, list a representative source, number of sources, and identification for the plot plan
. Part 1111111 - Fugifte EnftWons llmmmtory Please complete Table 2 for the sources of fugitive emissions at your facility
.p . 65

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### p . 67

APPENDIX B 

### TABLE 4 OF THE 11 2(g) PROPOSED RULEMAKING SUPPORT DOCUMEN T

RAPUBSPROJECTS141001alGO .OVS November, 19%p . 68

i s Table 4 . Sensitivity of ambient fence-line concentration to stack height and fence-line distance for the "Model" Plant Stack height Distance to nearest Media n (meters) residence (meters) concentration (,Lg/M3) 200 16 S 1 3 JC 100 3 4 3 .500 3 .4 1 C 0 100 6 .7 0 200 5 .0 10 Soo 2 .8 is 200 2 .5 so 200 0 .1s 100 200 0 .026 These parameters are assumed in the model plant used t o calculate ami sion rates for the proposed rule

Note : The model plant has :

Emission Rate = 10 tons per year, Stack Hieght = 10 meters ; Stack Diameter = 1 meter; Exit Velocity = 0 .1 meters / second ; Stack Temperature = 295 Kelvin (ambient) Distance to Nearest exposed individual = 200 meters ; Worst case down-wash
.

### p . 69

APPENDIX D 

### MEK EMISSIONS BY ZIP CODEp . 70
MEK EMISSIONS BY ZIP CODE For the year 1994, there were 800 facilities that reported MEK releases to air of 20,000 pounds (10 tons) or more, including both point and non-point emissions
. Of this number, 709 facilities were located in ZIP codes in which there was no other facility reporting MEK emissions greater than 20,000 pounds during the year
.

The following chart shows the remaining 91 facilities . It is organized to show the MEK emissions by ZIP code for each ZIP code in which there were multiple facilities reporting MEK emissions greater than 20,000 pounds in 1994
. All data is from the 1994 Toxics Release Inventory
. LOCATION BY ZIP CODE FACILITY NAME TOTAL AIR RELEASE 07095 Gentek Building Prods . 26,627 Middlesex, NJ Russell-Stanley Corp . 36,62 3 Total Air Release for Zip Code : 63,250 17402 York Casket Co . 28,700 York, PA Harley-Davidson Motor Co
. 20,25 0 Total Air Release for Zip Code : 48,950 17847 Milton, PA ACF Ind . Inc . 28,740 Northumberland, PA Resilite Sports Prods . Inc . 648,75 7 Total Air Release For Zip Code : 677,497 19154 Allied Lube & Conduit Corp . 130,185 Philadelphia, PA Kurz-Hastings, Inc
. 376,000 Total Air Release For Zip Code : 506,185 24012 Tread Corp
. 25,200 Roanoke, VA Singer Furn . Co . Roan Plant 21,37 5 Total Air Release For Zip Code : 46,575 24055 JD Bassett Mfg . Co . 25,503 Bassett, VA Bassett Superior Lines 92,86 2 Bassett Table Co
. 57,739 Bassett Mirror Co . Philpott Plant 24,050 Total Air Release For Zip Code : 200,15 4 24112 American Furniture Co . Inc . 50,852 Martinsville, VA W .M . Bassett Furniture Co . 34,757 Total Air Release For Zip Code : 85,609p . 71

24311 Merillat Ind . Inc . 40,104 Atkins, VA Virginia House Furniture Corp . Plant 1 25,30 0 Virginia House Furniture Corp . Plant 2 26,300 Total Air Release For Zip Code : 91,704 24333 EC Dodson Plant 36,463 Galax, VA TG Vaughn Plant 50,22 0 BC Vaughn Plant 34,238 Vaughn-Bassett Furniture Co . 67,467 Webb Furn . Ents . Inc . Plant 1 22,80 0 Total Air Release For Zip Code : 211,188 24354 Marley Mouldings Inc
. 39,755 Marion, VA Marion Composites 71,95 0 Total Air Release For Zip Code : 111,705 27261 Lilly Ind . Inc . 27,720 HighPoint, NC Marsh Furniture Co
. 37,05 2 AKZO Nobel Coatings, Inc
. 23,957 Total Air Release For Zip Code : 88,729 27292 TI Industries 117,542 Lexington, NC Lexington Furniture Ind . Plant 4&5 22,90 0 Lexington Furniture Ind . Plant 7 57,664 Lexington Furniture Ind . Plant 12 33-834 Total Air Release For Zip Code : 174,276 28043 Crellin Inc . 50,000 Forest City, NC AG Ind . Inc . 44,250 Total Air Release For Zip Code : 94,25 0 28139 Broyhill Furniture Ind . Inc . 50,816 Rutherfordton, NC Reeves Intl . Grace Plant 30,135 Total Air Release For Zip Code : 109,09 0 28601 Century Furn . Ind . Plant 1 20,517 Hickory, NC Hickory White Co . Casegoods Div . 31,246 Siecor Telecom . Cable Plant 42,365 Total Air Release For Zip Code : 94,128 28613 Decor Originals Inc . 25,062 Conover, NC Lackawanna Leather Co . 112,21 1 Total Air Release For Zip Code : 137,273p . 72

28633 Broyhill Fum . Ind . Inc . Complex 195,801 Lenoir, NC Broyhill Fum . Inc . Inc . Lenoir 64,75 1 Total Air Release For Zip Code : 260,552 28645 P&xar Printed Label Group 179,264 Lenoir, NC Singer Furniture Co . 95,39 1 Thomasville Furniture Ind . 40,200 Broyhill Furniture Ind . Inc . Harper 55,402 Total Air Release For Zip Code : 370,25 7 28704 Crown Cork & Seal Co . Inc . 23,700 Arden, NC Day International 35,818 Phillips Consumer Electronics Co . 83,560 Total Air Release For Zip Code : 143,078 28777 Ethan Allen Inc . Spruce Pine Div . 20,436 Spruce Pine, NC Henredon Furniture Ind . Inc . 32,89 7 Total Air Release For Zip Code : 53,333 29150 Kom Ind . Inc . 136,004 Sumter, SC Vaugh-BassettfWilliams Fum . Co. Inc. 28,16 9 Total Air Release For Zip Code : 164,173 29202 Kline Iron & Steel Co . Inc . 26,000 Columbia, SC Consolidated Systems Inc . 41,10 0 Total Air Release For Zip Code : 67,100 29605 Lockheed Aeromond Centers Inc . 26,750 Greenville, SC Crown Metro Inc . 20,45 5 Total Air Release For Zip Code : 47,205 31709 Woodgrain Millwork Inc . 378,865 Americus, GA Textron Automobile Exteriors 489,18 9 Total Air Release For Zip Code : 868,054 37303 P-1 Inc . 31,700 Athens, TN Athens Furniture Ind . Inc . Bed Plant 20,66 0 Textron Automobile Interiors 126,400 Total Air Release For Zip Code : 178,760 37814 Lea Ind . Plant #4 23,333 Morristown, TN Universal Bedroom Furniture Ltd
. 53,850 Camelot, TN Rexam Metallising ; 95,44 1 Pollyfibron Techs . Inc . 29,500 Total Air Release For Zip Code : 202,124p . 73

38464, Ripley, TN Tennessee Electroplating Inc . 34,906 Lawrenceburg, TN Murray Ohio Mfg . Co . 25,60 0 Total Air Release For Zip Code : 60,506 44805 National Latex Prods Co . 33,331 Ashland, OH Hedstrorn Prods Co . 112,11 2 Total Air Release For Zip Code : 145,443 46041 Crellin Inc . 90,343 Frankfbrt~ IN Federal Mogul Corp . 36,95 0 Total Air Release For Zip Code: 127,293 47201 Arvin Ind . Inc . NAA Div . 17th St . 47,400 Columbus, IN Toyota Indl . Equipment Mfg . Inc
. 26,685 Total Air Release For Zip Code : 74,085 47546 Aristokraft Inc . Plant 2 22,250 Jasper, IN Aristokraft Plant 3 20,25 0 Total Air Release For Zip Code : 42,500 49508, Grand Rapids, MI Steelcase Inc
. 97,408 Kentwood, MI Steelcase Inc . 226,67 0 Total Air Release For Zip Code : 324,078 49512 Lacks Ind . Inc . Raleigh Plant 110,550 Kentwood, MI Plastics Plate Inc . Plant 2 61,10 0 Total Air Release For Zip Code : 171,650 60007 Clear Lam Packaging 25,162 Elk Grove village, iL Pre-Finish Metals Inc . 69,16 5 Pre Finish Metals Inc . 22039 Total Air Release For Zip Code : 116,366 70058 Sigma Coatings USA B .V . 28,024 Harvey, LA Evans Contianer Corp . 35,98 6 Total Air Release For Zip Code : 64,010 70805 Exxon Co . USA Baton Rouge Refg. 152,800 Baton Rouge, LA Exxon Chemical Baton Rouge Chemical 34,72 4 Total Air Release For Zip Code : 187,524 98055 Kenworth Truck Co
. 26,200 Renton, WA Boeing Commercial Airplane Group 167,000 Total Air Release For Zip Code : 193,200

### p . 74

APPENDIX F 

### TABLE OF AMBIENT AIR CONCENTRATION LEVELS OF MEK (TAKEN FROM A STUDY CONDUCTED BY THE NEW JERSEY DEPARTMENT OF

ENVIRONMENTAL PROTECTION IN 1978)p . 75

TABLE OF AMBIENT AIR CONCENTRATION LEVELS OF ME K

(TAKEN FROM A STUDY CONDUCTED BY THE STATE OF NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION IN 1978)p . 76

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APPENDIX F 

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### p . 87

APPENDIX G 

### NORTH BATON ROUGE VOLATILE ORGANIC SCREENING STUDYp . 88 

# RADIAN C 0 R P 0 R A T 1 0 H
DCN 88-203-085-0 2 RCN 203-085-DS-00

RESULTS OF A VOLATILE ORGANIC SCREENING STUDY CONDUCTED IN THE VICINITY OF THE NORTH BATON ROUGE INDUSTRIAL COMPLEX

DRAFT FINAL REPORT

Submitted to : Mr . Gordon B . Jolley Environmental Coordinator Exxon Chemical America s Baton Rouge Chemical Plant

P .O . Box 24 1 Baton Rouge, Louisiana 70821-0241

Prepared by : Radian Corporation 8501 Mo-Pac Boulevard P .O . Box 20108 8 Austin, Texas 7872D-1088

15 April 198 8 8501 Mo-Pac Blvd ./PO. Box 201088/Austin, TX 78720-1088/(512) 45"797p . 89



# !MIAN

ATIO N
2 .0 EXECUTIVE SMOLM

This report describes the results of an ambient screening study which was conducted for Exxon Chemical Americas by Radian Corporation . The study was conducted in the immediate vicinity of the Baton Rouge industrial complex and van aimed at measuring ambient concentrations of selecte d volatile organic compounds which are representative of emissions from both industrial stationary and area sources . The measurem t program was designed to gather simultaneous screening measurements for a list of 175 volatile organics Me) at four sites selected by Exxon Chemical Americas .

The sites were ropz~esentative of the following types of locations : 1 . Rural non-industrial .- 2 . An urban residential area situated near major transportation arteries ; 3 . Urban industrial ; and 4 . Rural industrial . The location of each of the four sampling sites are shown in Figure 2-1 . Site 1 was a rural non-industrial site located 26 miles east of the Baton Rouge industrial complex near the town of Livingston . Louisiana . Site 2 was located in an urban area near tb* intersoction of Highway 61 and Siegen Lane . This site . which was located 10 miles southeast of the Baton Rouge industrial complex, was -dcainated by mobile source emissions due to ite proximity to a major traffic intersection in Baton Rouge . Site 3 was situated in an urban industrial area adjacent to the North Baton Rouge refining and petrochemical complex . This site was situated approximately 1 mile east of the Exxon Chemical Americas plant on Evangeline Road . Site 4 was situated in a rural industrial setting in the town of Zachary .
2-1P . 90



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### 2-2P . 91

Louisiana . This site was located 5 miles north of the Exxon Chemical Co . plastics plant .



### Simultaneous 24-hour integrated whole air samples were collected at each of the four site locations on three,consecutive sampling days beginning 6 March 1988 and extending through 9 March 1988 . The samples were collected in evacuated stainless steel canisters . and analyzed using a multidetector San chromatography system . The first sampling period was performed on a weekend (a Sunday) to gather samples during periods of low vehicular traffic . The remainder of the samples were collected during periods of normal weekday vehicular traffic . This sampling strategy vas devised in an attempt to discriminate between impacts from stationary and mobile sources .

The meteorology during the measurement program van characterized by light winds which were predominately from a southeasterly direction . The first sampling period which began at 6 :00 AM on the morning of 6 March 1988 was typified by light persistent westerly winds which gradually shifted through north and stabilized as a southeasterly breeze in the early morning of hours oi 7 March . The winds were generally light and persistent from the southeast on 7-8 March ; gradually shifting to the northwest during the late evening hours of 8 March . These conditions prevailed until sampling was term .ziated on the morning of 9 March 1988 .

Based on the meteorology which existed during the measurement program . the urban and rural industrial sites (3 and 4) were positioned downwind of industrial sources for brief periods during the first and third sampling days . Sit* 2 (urban-rtsidential) which was situated near a major traffic interxection . was exposed to missions from mobile sources an each of the three sampling days . It should also be noted that light to moderate precipitation began at about noon of the second sampling day . and continued through the end of the third sampling day . The presence of precipitation any have influenced the concentration of volatile organics MOO which were present in the ambient environment at each site location . 2-3p . 92



# IAN GOUPORAVIO N

Table 2-1 represents the list of compounds which were detected at least once at each site during the screening study . The table shows the concentration range . mean concentration . and frequency of observation for each compound detected . These data can be used to make inferences about the ambient levels of VO which were observed during the screening study (6-9 March 1988) . Figures 2-2 through 2-7 provide a graphic comparison of the concentration levels which were observed at each site location for ethylene and acetylene . ethane* propane, benzene . toluene, and total non-methane hydrocarbons (TNMHC) . The following general observations can be made with regard to the VO screening data :

• The concentration of TNMHC observed at each site during the study was generally low . The TNMHC values ranged from 78 .8 to 239 .4 ppb-v .

• The urban sampling sites were characterized by TNMHC values which were only slightly higher than that which was observed at the rural sampling sites . This is not surprising given the meteorological conditions which prevailed during the screening study .

• Ethane, ethylene and acetylene . propane . toluene . and nheptane were present in at least 90% of all samples collected . • As expected . there were a number of compounds which weregenerally present in higher concentrations at the urbanresidential . and urban industrial sites as compared to the more isolated rural sites . These included benzene .'ethylene and acetylene . toluene and ethane . These trends would be expected given the proximity to and number of stationary and mobile sources in the urban areas .

2-4p . 93



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• ThOre were fifteen (15) compounds which were deitected at the urban and urban industrial site locations which were not present at detectable concentrations at the rural locations . Most notable were c-2-pentene . ethylbenzene . and 2-motbyl-2- butene .

• The imajority of compounds which were identified were present at concentrations of 5 ppb-v or less . Ethane . propane, nbutane . isopentane . and trichlorofluoromethane were observed in some samples at concentrations greater than 20 ppb-v .

• Precipitation during the sampling program may have been responsible for suppressing the VO concentration in the ambient environment . In general . the TNMHC levels were lower on days in which precipitation was measured .

• Given the limited number of samples collected and the meteorology which ezisted during the screening program, it is uncertain if the data collected are representative of the highest concentrations of VOt which could be present in the ambient air . The data . however are representative of short duration screening measurements observed at each site under similar sampling conditions .

• During the data validation process, it was discovered that acetaldebyd* . acetone . metbylene chloride . and 3-methyl hoptane were present in the field blanks . Measurement values for these compounds were at levels which would normally not be ezp*cted in the ambient air . For this reason . these data were ezcludod from the summary presentation . During the sampling program . two samplers failed to operate for the entire 24-hour smpling period . This included a sample collected at Site I an 6 March . and at Site 4 on the evening of 7 March . In the case of
2-14P . 99

the sample collected at Site 1 . it was discovered that both the designate d field and duplicate canisters had been tampered with and the valve on each canister was turned off approximately midway through the sampling period . The duplicate sample was repeated during the next sampling period . In the second cast . sample flow ceastd as a result of excessive moistur e accumulation in the vacuum flow delivery system during a time when moderate rainfall was occurring . In both instances . the samplers operated for periods of approximately 12 hours . It is difficult to assess if the aborted samples are representative of samples collected over a full 24-hour sampling period . Because the samples were collected in isolated areas . it could be argued that the concentration of VOs in the ambient air would be relatively constant over a 24-hour period . The data do provide useful information concerning the composition of volatile organic compounds which were observed at there sites . However . care should be exercised in interpreting there data . The ambient VO measurements made during this study provide a "quick screen look" at the distribution of volatile organics in the Baton Rouge industrial corridor over a limited time framt . These data are useful in contrasting the composition and relative concentrations of volatile organics which are present in urban/industrial settings to those found in rural and rural industrial settings . As previously stated, the measurement data presented in this report may not be representative of the highest concentration values which would be expected to occur under different meteorological scenarios . Therefor*, care should be taken in applying broad interpretations to this limited database . These data, however, do provide an indication of the general air quality which was observed at each measurement site under the conditions which prevailed during the measurement program . Additional data . however . are needed to accurately assess community exposure to a variety of volatile indicator compounds which are representative of missions from petroleum refining . petrochemical production . and mobile sources in the North Baton Rouge industrial complex .

2-15

### P . 100

APPENDIX H 

### IRIS DATABASE ENTRY FOR MEK