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MEMORANDUM

DATE: January 31, 2014

SUBJECT: Emissions Data Used in Residual Risk Modeling: Pesticide Active Ingredient 

Production, Polyether Polyols Production, and Group IV Polymers and Resins

FROM: Nick Parsons, US EPA

TO: Docket ID No. EPA-HQ-OAR-2011-0435

1.0 Introduction and Background

The purpose of this memorandum is to provide supplemental information to the October 

25, 2011, memorandum entitled, “Emissions Data and Acute Risk Factor Used in Residual Risk 

Modeling: Pesticide Active Ingredients, Polyether Polyols, and Group IV Polymers and Resins.” 

This memorandum provides information on the Environmental Protection Agency (EPA) Risk 

and Technology Review (RTR) database used in estimating residual risk for the Pesticide Active 

Ingredient Production (PAI), Polyether Polyols Production (PEPO), and Group IV Polymers and 

Resins (P&R IV) Maximum Achievable Control Technology (MACT) source categories. These 

MACT standards cover only major sources.

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

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

section 112(d) requires the EPA to develop technology-based standards for categories of 

industrial sources. In the second stage, known as the residual risk stage, section 112(f)(2) 

requires EPA to assess the health and environmental risks that remain after sources come into 

compliance with the MACT standards. If additional risk reductions are necessary to protect 

public health with an ample margin of safety or to prevent adverse environmental effects, EPA 

must develop standards to address these remaining risks.

2.0 Revisions to the Data Set Used in Residual Risk Modeling

Since the January 30, 2012, proposed rulemaking covering the RTR for the PAI, PEPO, 

and P&R IV MACT standards, the EPA has received additional information on several facilities 

in these source categories. This additional information is described in further detail below.

2.1 Proposal Comments

As a result of information received from commenters on the proposal that additional 

facilities should have been included in two of the Group IV Polymers and Resins datasets, we 

added one facility to the data set used in a revised risk assessment for the SAN source category 

(Zeon in Louisville, KY) and one facility to the data set used in a revised risk assessment for the 

ABS source category (INEOS ABS in Addyston, OH), using the 2005 National Emissions 

Inventory (NEI).
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2.2 NACAA and State Review

On February 4, 2013, the EPA asked the National Association of Clean Air Agencies 

(NACAA) to review the emissions data for PAI, PEPO, and P&R IV facilities in several states. 

The states of Texas and Louisiana were also asked to review emissions data for the PAI, PEPO, 

and P&R IV facilities in their state. The results of this review are discussed in further detail 

below. A list of all of the facilities subject to this review can be found in Appendix A.

2.2.1 PAI Source Category

There were nine facilities in the PAI source category that were part of this emissions data 

review. There are 18 total faculties in the PAI source category.

The state of Louisiana confirmed that the two PAI facilities in that state were still active 

and subject to the PAI MACT standards. There were no revisions to the emissions data.

The state of Michigan did not respond to the inquiry for review on the two PAI facilities 

in that state.

The state of South Carolina identified an additional facility (NEI41376) as being subject 

to the PAI MACT standards. The state provided 2005 NEI emissions data for this facility to 

confirm the data used by the EPA.

The state of Texas confirmed that the three PAI facilities in that state were still active and 

subject to the PAI MACT standards. There were no revisions to the emissions data.

The state of West Virginia confirmed that the two PAI facilities in that state were still 

active and subject to the PAI MACT standards. One facility (NEIWV0390007) indicated that 

numerous emission points previously assigned to the PAI source category were either no longer 

active due to process shutdown, or were subject to a different MACT standard. The other facility 

(NEIWV0390001) provided minor corrections to the description of several emission points.

The dataset for the PAI source category was revised to reflect the changes described 

above, and this revised dataset was used in a revised risk assessment for the source category.

2.2.2 PEPO Source Category

There were 20 facilities in the PEPO source category that were part of this emissions data 

review. There are 23 total faculties in the PEPO source category.

The state of Louisiana confirmed that the four PEPO facilities in that state were still 

active and subject to the PEPO MACT standards. There were no revisions to the emissions data.

The state of Michigan did not respond to the inquiry for review on the two PEPO 

facilities in that state.
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The state of North Carolina confirmed that the one PEPO facility in that state was still 

active and subject to the PEPO MACT standards. There were no revisions to the emissions data.

The state of South Carolina confirmed that the one PEPO facility in that state was still 

active and subject to the PEPO MACT standards. The state provided 2005 NEI emissions data 

for this facility to confirm the data used by the EPA.

The state of Texas confirmed that the eight PEPO facilities in that state were still active 

and subject to the PEPO MACT standards. There were no revisions to the emissions data.

The state of West Virginia confirmed that the four PEPO facilities in that state were still 

active and subject to the PEPO MACT standards. One facility (previously misidentified as 

NEIWV0138; now correctly identified as NEI43420) indicated that the location of their facility 

was incorrect and provided updated information. The other facility (NEIWV0390102) provided 

minor corrections to the description of several emission points.

The dataset for the PEPO source category was revised to reflect the changes described 

above, and this revised dataset was used in a revised risk assessment for the source category.

2.2.3 P&R IV Source Categories

There were 15 facilities in the P&R IV source categories that were part of this emissions 

data review. There are 31 total facilities in the P&R IV source categories.

The state of Louisiana confirmed that the one P&R IV facility in that state was still active 

and subject to the P&R IV MACT standards. There were no revisions to the emissions data.

The state of Michigan did not respond to the inquiry for review on the one P&R IV 

facility in that state.

The state of North Carolina confirmed that the two P&R IV facilities in that state were 

still active and subject to the P&R IV MACT standards. One facility (NEI8768) indicated that 

numerous emission points previously assigned to the P&R IV source category were subject to a 

different MACT standard and added additional emission points to the source category. The other 

facility (NEI44658) also indicated that numerous emission points previously assigned to the 

P&R IV source category were subject to a different MACT standard and added additional 

emission points to the source category. The state also identified an additional facility (NEI40319) 

as being subject to the P&R IV MACT standards.

The state of South Carolina confirmed that six P&R IV facilities in that state were still 

active and subject to the P&R IV MACT standards. The state indicated that one facility 

(NEISC0600-00) was not subject to the P&R IV MACT standards and that another facility 

(NEI43310) was closed. The state provided 2005 NEI emissions data for all of these facilities to 

confirm the data used by the EPA.
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The state of Texas confirmed that the one P&R IV facility in that state was still active 

and subject to the P&R IV MACT standards. There were no revisions to the emissions data.

The state of West Virginia confirmed that the two P&R IV facilities in that state were still 

active and subject to the P&R IV MACT standards. One facility (NEI43309) indicated that 

numerous emission points previously assigned to the P&R IV source category were subject to a 

different MACT standard.

The dataset for the P&R IV source category was revised to reflect the changes described 

above, and this revised dataset was used in a revised risk assessment for the source category.

2.3 Additional Data Revisions

In addition to the revisions discussed above, after reviewing the data set, several 

additional revisions were made. This information came from available emissions inventories, 

other regulatory entities, or industry. Parts of these changes reflect incorrect emission point 

locations or emissions values. Other information received reflected changes in the source 

category of certain emission points. This information is detailed below:

NEI43304

o The facility name was renamed from “Lanxess Corp Addyston Facility” to 

“Ineos ABS (USA)”

o Several release point types and stack characteristics were incorrect and revised 

to their correct values.

o Several emissions values were incorrect and were revised to their correct 

values.

NEILA13809

o Several emissions values were incorrect and were revised to their correct 

values.

o Several emission points were incorrectly located off-site and were relocated 

on-site.

NEI7211

o Several incorrect emission points and SCC codes were removed from the PAI 

source category.

o Several emissions values were incorrect and were revised to their correct 

values.

o Several emission points were incorrectly located off-site and were relocated 

on-site.
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Appendix A – List of Facilities Subject to NACAA Review

Facility Name NEI ID City State Source Category

ATOFINA PETROCHEM INC/CARVILLE POLYSTYRENE NEI43297 CARVILLE LA P&RIV-Polystyrene Production

BASF CORPORATION/GEISMAR SITE NEI6032 Geismer LA Polyether Polyols Production

OCCIDENTAL CHEMICAL CORP LULING NEILAT$10504 LULING LA Pesticide Active Ingredient Production

RUBICON, LLC NEI6155 GEISMAR LA Polyether Polyols Production

SHELL CHEMICAL LP/GEISMAR PLANT NEI6013 GEISMAR LA Polyether Polyols Production

SYNGENTA CROP PROTECTION INC/ST. GABRIEL 

PLANT/CIBA-Geigy Corporation NEI5992 St. Gabriel LA Pesticide Active Ingredient Production

UNION CARBIDE CORP/TAFT/STAR 

MANUFACTURING COMPLEX NEILA13809 HAHNVILLE LA Polyether Polyols Production

BASF CORP NEI11878 WYANDOTTE MI Polyether Polyols Production

DOW AGROSCIENCES LLC NEIMIB4942 HARBOR BEACH MI Pesticide Active Ingredient Production

THE DOW CHEMICAL COMPANY U.S.A., MIDLAND NEI11906 MIDLAND MI

P&RIV-Acrylonitrile-Butadiene-Styrene 

Production

Pesticide Active Ingredient Production

Polyether Polyols Production

P&RIV-Polystyrene Production

P&RIV-Styrene Acrylonitrile Production

Cognis Corporation NEI44055 Charlotte NC Polyether Polyols Production

DAK AMERICAS LLC CAPE FEAR SITE NEI8768 LELAND NC P&RIV-Polyethylene Terephthalate 

Production

Performance Fibers, Inc. NEI40319 Salisbury NC P&RIV-Polyethylene Terephthalate 

Production

Performance Fibers, Inc. NEI44658 Moncure NC P&RIV-Polyethylene Terephthalate 

Production

3M FILM PLANT NEI41317 GREENVILLE SC P&RIV-Polyethylene Terephthalate 

Production

CORE MOLDING TECH INC NEISC0600-00 GAFFNEY SC P&RIV-Polystyrene Production

DAK AMERICAS LLC COOPER RIVER PLANT NEI2SC0-0089 MONCKS CORNER SC P&RIV-Polyethylene Terephthalate 

Production

EASTMAN CHEMICAL CO SOUTH CAROLINA 

OPERATIONS NEI41393 COLUMBIA SC P&RIV-Polyethylene Terephthalate Production
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INVISTA S. A. R. L. SPARTANBURG FACILITY NEI41468 SPARTANBURG SC P&RIV-Polyethylene Terephthalate 

Production

MILLIKEN CHEMICAL DEWEY PLAN T NEISCT$3391 INMAN SC Polyether Polyols Production

MITSUBISHI POLYESTER FILM LLC NEISC1200-00 GREER SC P&RIV-Polyethylene Terephthalate 

Production

NAN YA PLASTICS NEI41309 LAKE CITY SC P&RIV-Polyethylene Terephthalate 

Production

WELLMAN, INC. - PALMETTO PLANT NEI43310 DARLINGTON SC P&RIV-Polyethylene Terephthalate 

Production

WeylChem US Inc. NEI41376 ELGIN SC Pesticide Active Ingredient Production

DOW CHEMICAL CO FREEPORT FACILITY NEI11295 Freeport TX

Pesticide Active Ingredient Production

Polyether Polyols Production

P&RIV-Styrene Acrylonitrile Production

Dow Seadrift Plant NEI8011 SEADRIFT TX Polyether Polyols Production

DU PONT LA PORTE PLANT NEI6578 LA PORTE TX Pesticide Active Ingredient Production

EASTMAN CHEMICAL CO TEXAS OPERATIONS NEI7296 LONGVIEW TX Polyether Polyols Production

GB BIOSCIENCES CORPORATIO NEI7211 HOUSTON TX Pesticide Active Ingredient Production

HOUSTON PLANT NEI7491 HOUSTON TX Polyether Polyols Production

HUNTSMAN PETROCHEMICAL CORP NEI8432 DAYTON TX Polyether Polyols Production

HUNTSMAN PETROCHEMICAL CORP/CONROE 

FACILITY NEI12066 CONROE TX Polyether Polyols Production

LYONDELL CHEMICAL CO - CHANNELVIEW PLANT NEI11319 CHANNELVIEW TX Polyether Polyols Production

ROGER W. POWELL PLANT NEI6834 PASADENA TX Polyether Polyols Production

BAYER NEW MARTINSVILLE NEI43420 NEW MARTINSVILLE WV Polyether Polyols Production

BAYER CROPSCIENCE LP NEIWV0390007 INSTITUTE WV Pesticide Active Ingredient Production

BAYER MATERIALSCIENCE - SOUTH CHARLESTON NEIWV0390102 SOUTH CHARLESTON WV Polyether Polyols Production

DUPONT - BELLE NEIWV0390001 BELLE WV Pesticide Active Ingredient Production

GENERAL ELECTRIC COMPANY, INC. NEI43298 WASHINGTON WV P&RIV-Acrylonitrile-Butadiene-Styrene 

Production

INSTITUTE PLANT UNION CARBIDE CORP NEIWV0390005 INSTITUTE WV Polyether Polyols Production

M&G POLYMERS USA, LLC NEI43309 APPLE GROVE WV P&RIV-Polyethylene Terephthalate 

Production

UNION CARBIDE CORP SOUTH CHARLESTON PLANT NEI45600 SOUTH CHARLESTON WV Polyether Polyols Production