### 9/9/2010

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

From: Elaine Manning, Sect or Based Assessment Group

Subject: Post Proposal Revisions for Prin ting 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 Op eration; Mineral Wool Production; Pharmaceuticals Production; and Printing and Publishing Industry rulemaking issued on October 10, 2008. The updated Table 3.2-1 Summar y of Emissions from the Printing and Publishing Source Category, Table 3.2-2 Su mmary of Source Category Level Risk for Printing and Publishing, and Ta ble 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 cha nge in the maximum i ndividual 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 cat egory increased to 4. The noncancer hazard index (HI) as well as the noncan cer 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 prot ective, and in this updated risk analysis we used the Agency’s current formaldehyde Integrated Ri sk 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. Appl ying this scaling factor, results in a potential

MIR of 20 and HI of 0.4.

In addition to the risk presented by th e source category alone as shown in the attached Summary of Source Category Level Risk table, additional analysis was performed to access the “facility-w ide” risk. The results of the residual risk associated with all categories at the know n facilities (facility -wide) are presented in Appendix 6 “Detailed Risk Modeling Results”. We used the National Air Toxics Assessment (NATA) database for estimating facility-wid e risks due to our lack of more recent facility-specific emissions data for some of th e source categories included in the facilitywide analyses. Additionally, because we ha ve 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-w ide 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 emi ssions 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 di fferent 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 comple te, 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 ris k, 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

HAP a 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

Benzene 6 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

HAP a 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 Le vel 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 Maximu m 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 Result s for Printing & Publishing Facilities

Refined Results MAXIMUM ACUTE HAZARD QUOTIENTS ACUTE DOSE-RESPONSE VALUES

HAP Max. 1-hr.

Air Conc. (mg/m 3 ) Based on

REL Based on

AEGL-1/

ERPG-1 Based on

AEGL-2/

ERPG-2 REL (mg/m 3 ) AEGL-1 (1-hr) (mg/m 3 ) ERPG-1 (mg/m 3 ) AEGL-2 (1-hr) (mg/m 3 ) ERPG-2 (mg/m 3 )

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 availabl e 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 va lues which are not in the table do not ca rry any potential for posing acute health risks, based on an analysis of cu rrently 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 emer gency 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 wh ich are transient and reversible upon cessation of exposure. AEGL-2 is the exposure level above which it is predicte d that the general population, including susceptible individuals, could experience irreversib le or other serious, long-lasting adve rse health effects of an impaired ability to escape. EPRG – Emergency Removal Program gui delines 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 believe d that nearly all individuals could be exposed for up to 1 hour without experiencing or deve loping irreversible or other serious health effects or symptoms which could impair an individual’s ab ility to take protective action.



### Attachments: Appendix 1 Revised Em issions Inventory Support Memorandum Appendix 6 Detailed Risk Modeling Results Appendix 7 Acute Impacts Refined Analysis Figure