9/9/2010 

To: Docket – ID No. EPA-HQ-OAR-2010-0600 

From: Elaine Manning, Sector Based Assessment Group 

Subject: Post Proposal Revisions for Printing and Publishing Facilities Risk and 

Technology Assessment 

The attached minor revisions were made to the Printing and Publishing source 

category risk assessment which was included in the proposal for the Group I Polymers 

and Resins; Marine Vessel Loading Operation; Mineral Wool Production; 

Pharmaceuticals Production; and Printing and Publishing Industry rulemaking issued on 

October 10, 2008. The updated Table 3.2-1 Summary of Emissions from the Printing and 

Publishing Source Category, Table 3.2-2 Summary of Source Category Level Risk for 

Printing and Publishing, and Table 3.2-3 Summary of Acute Refined Results for Printing 

and Publishing reflecting the minor changes are attached. The most significant change 

from the October 10, 2008 proposal is the change in the maximum individual cancer risk 

(MIR). Based on a change to the unit risk estimate for cancer (URE) for the compound 

ethyl benzene, the MIR for this source category increased to 4. The noncancer hazard 

index (HI) as well as the noncancer acute hazard quotient did not change from the initial 

proposal value. Additionally, the Chemical Industry Institute of Toxicology (CIIT) unit 

risk estimate (URE) value for formaldehyde (used in the October 10, 2008 proposal) is no 

longer considered health protective, and in this updated risk analysis we used the 

Agency’s current formaldehyde Integrated Risk Information System (IRIS) value, which 

was last revised in 1991. The attached Appendices 1, 6, and 7 provide the supporting 

information for the changes. 

The MACT-allowable emissions from this source category could be up to five 

times greater than the actual emissions. Applying this scaling factor, results in a potential 

MIR of 20 and HI of 0.4. 

In addition to the risk presented by the source category alone as shown in the 

attached Summary of Source Category Level Risk table, additional analysis was 

performed to access the “facility-wide” risk. The results of the residual risk associated 

with all categories at the known facilities (facility-wide) are presented in Appendix 6 

“Detailed Risk Modeling Results”. We used the National Air Toxics Assessment 

(NATA) database for estimating facility-wide risks due to our lack of more recent 

facility-specific emissions data for some of the source categories included in the facilitywide analyses. Additionally, because we have not yet begun our thorough residual risk 

review for most source categories, we are unable at this time to estimate allowable 
facility-wide emissions. Thus, our facility-wide analysis is based solely on actual 

emissions. 

The facility-wide MIR and HI available in Appendix 6 are based on emissions, as 

identified in the NATA database, from all emissions sources at the identified facilities. 

The maximum facility-wide risks are estimated to be a cancer MIR of 20 in a million and 

a hazard index (HI) of 20, which occur at different facilities. The source category 

contribution to the facility-wide risk at both facilities is less than 1% for MIR and HI. 

Subsequently after the risk modeling was complete, we received data that indentified an 

error in emissions that caused the highest facility-wide HI value (20). After reviewing 

the updated emissions and assessing the risk, the HI dropped significantly. The next 

highest facility-wide HI is 2 associated with another facility. The source category 

contribution to the HI risk at this facility is less than 1%.

 
Table 3.2-1 Summary of Emissions from the Printing and Publishing Source Category 

Prioritized Inhalation Dose-Response Value Identified 

by OAQPS 

HAPa Emissions 

(tpy) 

Number of 

Facilities 

Reporting HAP 

(172 facilities in 

data set) 

Unit Risk 

Estimate for 

Cancer? 

Reference 

Concentration 

for Noncancer? 

Health Benchmark 

Values for Acute 

Noncancer? 

PBHAP? 

Toluene 6,605 97 Υ Υ

Glycol Ethers 172 44 Υ Υ

Xylenes (Mixture of o, m, and 

p Isomers) 145 55 Υ Υ

Methyl Isobutyl Ketone 140 32 Υ 

Methanol 114 56 Υ Υ

Hexane 84 25 Υ Υ

Ethyl Benzene 57 22 Υ Υ 

Methyl Chloroform 54 9 Υ Υ

Ethylene Glycol 41 28 Υ Υ

Diethylene Glycol Monobutyl 

Ether 15 6 Υ Υ

Diethylene Glycol Monoethyl 

Ether 11 7 Υ Υ

Vinyl Acetate 9 12 Υ Υ

Ethylene Glycol Methyl Ether 3 9 Υ Υ

N,N-Dimethylformamide 2 2 Υ Υ

Methylene Chloride 2 6 Υ Υ Υ

Diethanolamine 1 6 Υ 

Hydrochloric Acid 0.8 1 Υ Υ

Formaldehyde 0.7 16 Υ Υ Υ

Bis(2-Ethylhexyl)Phthalate 0.6 2 Υ Υ 

Hydroquinone 0.6 4 

Cumene 0.4 8 Υ Υ

m-Xylene 0.4 1 Υ

N-Hexyl Carbitol 0.3 1 Υ 

Isophorone 0.2 2 Υ Υ 

4,4'-Methylenediphenyl 

Diisocyanate 0.1 1 Υ Υ

Triethylamine 0.1 3 Υ Υ

Dimethyl Phthalate 0.06 2 

Methyl Methacrylate 0.05 1 Υ Υ

Benzene6 0.03 6 Υ Υ Υ

Naphthalene 0.03 4 Υ Υ 

Cellosolve Acetate 0.02 1 Υ Υ

Dibutyl Phthalate 0.02 1 

Phenyl Cellosolve 0.02 3 Υ Υ

Phenol 0.01 1 Υ Υ

Carbon Tetrachloride 0.01 1 Υ Υ Υ

Chlorobenzene 0.008 1 Υ Υ

Acrylic Acid 0.002 3 Υ Υ
Table 3.2-1 Summary of Emissions from the Printing and Publishing Source Category 

Prioritized Inhalation Dose-Response Value Identified 

by OAQPS 

HAPa Emissions 

(tpy) 

Number of 

Facilities 

Reporting HAP 

(172 facilities in 

data set) 

Unit Risk 

Estimate for 

Cancer? 

Reference 

Concentration 

for Noncancer? 

Health Benchmark 

Values for Acute 

Noncancer? 

PBHAP? 

2,4-Toluene Diisocyanate 0.001 3 Υ Υ Υ

Ethyl Acrylate 0.0004 1 Υ

Chromium (VI) Compounds 0.00004 2 Υ Υ 

Nickel & Compounds 0.00002 2 Υ Υ

Cadmium & Compounds 0.00001 2 Υ Υ Υ

1,4-Dichlorobenzene 0.00001 2 Υ Υ 

Lead Compounds (Inorganic) 0.000005 2 Υ Υ

Styrene 0.000004 1 Υ Υ

Manganese & Compounds 0.000004 2 Υ 

Mercury & Compounds 0.000003 2 Υ Υ Υ

Arsenic & Compounds 

(Inorganic Including Arsine) 0.000002 2 Υ Υ Υ

POM72002 0.0000003 2 Υ Υ
Table 3.2-2. Summary of Source Category Level Risks for Printing & Publishing 

Result HAP “Drivers” 

Facilities in Source Category 

Number of Major Source Facilities Estimated to 

be in Source Category 172 n/a 

Number of Facilities Identified in NEI and 

Modeled in post-NPRM Risk Assessment 172 n/a 

Cancer Risks 

Maximum Individual Lifetime Cancer Risk (in 1 

million) 4 ethyl benzene 

Number of Facilities with Maximum Individual Lifetime Cancer Risk: 

 Greater than or equal to 100 in 1 million 0 n/a 

 Greater than or equal to 10 in 1 million 0 n/a 

 Greater than or equal to 1 in 1 million 1 ethyl benzene 

Chronic Noncancer Risks 

Maximum Respiratory Hazard Index 0.08 ethylene glycol 

Number of Facilities with Maximum Respiratory Hazard Index: 

 Greater than 1 0 n/a 

Acute Noncancer Screening Results

Maximum Acute Hazard Quotient 

20 

1 

1 

toluene (REL) 

toluene (AEGL-1) 

toluene (ERPG-1) 

Number of Facilities With Potential for Acute 

Effects 7 toluene 

Acute Noncancer Refined Results

Maximum Acute Hazard Quotient 

10 

0.5 

0.5 

toluene (REL) 

toluene (AEGL-1) 

toluene (ERPG-1) 

Number of Facilities With Potential for Acute 

Effects 6 toluene 

Population Exposure 

Number of People Living Within 50 Kilometers 

of Facilities Modeled 118,000,000 n/a 

Number of People Exposed to Cancer Risk: 

 Greater than or equal to 100 in 1 million 0 n/a 

 Greater than or equal to 10 in 1 million 0 n/a 

 Greater than or equal to 1 in 1 million 300 n/a 

Number of People Exposed to Respiratory Hazard Index: 

 Greater than 1 0 n/a 

Estimated Cancer Incidence (excess cancer cases 

per year) 0.0006 n/a 

Contribution of HAP to Cancer Incidence 

 ethyl benzene 70% n/a 

 formaldehyde 28% 
Table 3.2-3. Summary of Acute Refined Results for Printing & Publishing Facilities 

Refined Results MAXIMUM ACUTE HAZARD 

QUOTIENTS ACUTE DOSE-RESPONSE VALUES 

HAP 

Max. 1-hr. 

Air Conc. 

(mg/m3

) 

Based on 

REL 

Based on 

AEGL-1/ 

ERPG-1 

Based on 

AEGL-2/ 

ERPG-2 

REL 

(mg/m3

) 

AEGL-1 

(1-hr) 

(mg/m3

) 

ERPG-1 

(mg/m3

) 

AEGL-2 

(1-hr) 

(mg/m3

) 

ERPG-2 

(mg/m3

) 

toluene 384 10 0.5/0.5 0.2/0.3 37 750 750 4500 1900 

Notes on Refined Process: 

1) The screening was performed for all emitted HAP with available acute dose-response values. Only those pollutants whose 

screening HQs were greater than 1 for at least one acute threshold value are shown in the table. 

2) HAP with available acute dose-response values which are not in the table do not carry any potential for posing acute health 

risks, based on an analysis of currently available emissions data. 

Notes on Acute Dose-Response Values: 

 REL – California EPA reference exposure level for no adverse effects. Most, but not all, RELs are for 1-hour exposures. 

 AEGL – Acute exposure guideline levels represent emergency exposure (1-hour) limits for the general public. 

AEGL-1 is the exposure level above which it is predicted that the general population, including susceptible individuals, 

could experience effects that are notable discomfort, but which are transient and reversible upon cessation of exposure. 

AEGL-2 is the exposure level above which it is predicted that the general population, including susceptible 

individuals, could experience irreversible or other serious, long-lasting adverse health effects of an impaired 

ability to escape. 

 EPRG – Emergency Removal Program guidelines represent emergency exposure (1-hour) limits for the general public. 

ERPG-1 is the maximum level below which it is believed that nearly all individuals could be exposed for up to 1 hour 

without experiencing other than mild, transient adverse health effects. 

ERPG-2 is the maximum exposure below which it is believed that nearly all individuals could be exposed for up 

to 1 hour without experiencing or developing irreversible or other serious health effects or symptoms which 

could impair an individual’s ability to take protective action.

Attachments: Appendix 1 Revised Emissions Inventory Support Memorandum 

 Appendix 6 Detailed Risk Modeling Results 

 Appendix 7 Acute Impacts Refined Analysis Figure