MEMORANDUM

To: OSWRO Docket (EPA-HQ-OAR-2012-0360)

From: Paula Hirtz, Refining and Chemicals Group

Terri Hollingsworth, Air Toxics Assessment Group

Office of Air Quality Planning and Standards, 

U.S. Environmental Protection Agency 

CC: Penny Lassiter, Leader, Refining and Chemicals Group 

Kelly Rimer, Leader, Air Toxics Assessment Group

Date: January 9, 2015

Subject: Additional Facilities Identified During the OSWRO Comment Period

The EPA received information during the comment period on the proposed amendments to the OffSite Waste and Recovery Operations (OSWRO) National Emission Standards for Hazardous Air 

Pollutants (NESHAP) identifying four sources that are subject to the OSWRO NESHAP but were not 

included in the risk assessment supporting the proposal. These facilities are E. I. DuPont de Nemours 

and Company in Orange, Texas; E. I. DuPont de Nemours and Company in Axis, Alabama; Eastman 

Chemical Company in Longview, Texas; and Eastman Chemical Company in Kingsport, Tennessee.

Three of the facilities manufacture chemicals and chemical intermediates, and the fourth facility

located in Axis, Alabama manufactures pesticides. We also reviewed the Title V permits for these 

facilities, and we confirmed they are subject to OSWRO NESHAP and will therefore be affected by the 

new requirements of the OSWRO NESHAP amendments.

In evaluating and developing standards under section 112(f)(2), the EPA applies a two-step process to 

address residual risk. In the first step, we determine whether risks are acceptable, and in the second 

step of the process, we consider whether the emission standards provide an ample margin of safety. 

To determine whether to conduct additional risk modeling for the newly identified OSWRO facilities, 

we first considered whether risk acceptability and ample margin of safety for the OSWRO source 

category, including the four additional facilities, could be determined using existing information. The 

existing information available to the EPA includes previously conducted OSWRO source category 

modeling results, facility-wide modeling results conducted for these facilities in our evaluations of risks 

due to emissions from other source categories, Title V permits and information obtained through 

discussions with facility representatives. We determined that OSWRO source-category specific 

modeling would be conducted for these facilities if facility-wide risks were near levels considered 

unacceptable and OSWRO operations constituted a majority of those emissions. However, we also 

determined that if either the facility-wide risks were not near levels considered unacceptable or if 

OSWRO emissions did not constitute a majority of emissions causing risks near levels considered 

unacceptable, additional modeling would not be necessary.

The EPA contacted representatives at these companies who indicated that these facilities are primarily 

chemical and pesticide manufacturing plants. In addition to the manufacturing operations, the three 

chemical manufacturing plants also process limited volumes of company-generated off-spec or 

contaminated product as off-site waste. Company representatives stated that these facilities, as 

manufacturers, do not commercially accept or process off-site waste from other companies. The 
pesticide manufacturing plant processes a limited amount of off-site waste with a VOHAP 

concentration below the OSWRO 500ppmw threshold from a single adjacent company. Email 

correspondence with these company representatives is included in the docket for this rulemaking. 

Consistent with our findings at proposal, we expect emissions from the OSWRO source category to 

make only a small contribution to facility-wide risks at manufacturing facilities and to contribute more 

significantly to facility-wide risks at facilities that commercially accept off-site waste, such as hazardous 

waste treatment facilities and cement manufacturing facilities. The results of modeling conducted prior 

to the OSWRO proposal indicated that seven of the 38 modeled facilities had an OSWRO source 

category contribution of 50 percent or more to facility-wide risk. Five of these facilities were hazardous 

waste treatment facilities and two were cement manufacturing facilities. Considering these modeling 

results, we expect the OSWRO contribution to facility-wide risk to be less than 50 percent at the 

additional facilities, which do not commercially accept off-site waste.

These four facilities also contain sources that are subject to other NESHAP. As such, the EPA previously 

modeled the facility-wide risks for these four facilities as part of the risk reviews for the other NESHAP. 

The EPA modeled these facility-wide risks in the “Residual Risk Assessment for 7 Source Categories: 

Printing and Publishing, Marine Tank Vessel Loading Operations, Pharmaceuticals Production, 

Epichlorohydrin Elastomers, Polybutadiene Rubber, Styrene Butadiene, Nitrile Butadiene” promulgated 

in January 2011 and the “Residual Risk Assessment for 7 Source Categories: Pesticide Active Ingredient 

Production, Polyether Polyols Production, Polymers and Resins IV -- Styrene Acrylonitrile, Polymers and 

Resins IV – Polystyrene, Polymers and Resins IV – Polyethylene Terephthalate, Polymers and Resins IV -

- Methyl Methacrylate-Butadiene Styrene, Polymers and Resins IV -- Acrylic Butadiene Styrene” 

promulgated in January 2014. A review of the risk assessment results for these facilities indicate that 

the maximum facility-wide cancer risks due to emissions of hazardous air pollutants (HAP) range from 

6-in-1 million to 40-in-1 million. These risks are relatively low when compared to the upper end of the 

range of acceptability of 100-in-1 million. The maximum facility-wide non-cancer risks due to HAP 

emissions range from 0.08 to 1. In addition, the results show that the facility-wide cancer and noncancer risks are attributed to HAP emissions from non-OSWRO processes. As discussed above, OSWRO 

processes are minor operations at these facilities, and it is reasonable to conclude that risks due to

OSWRO processes at these facilities would be well below these facility-wide risk values and would 

likely be similar to or less than the previously modeled maximum risks for the OSWRO source category. 

See Table 1 below for the facility-wide risk results for each facility.

To further consider whether to conduct additional risk modeling for these facilities, we compared the 

previously modeled facility-wide emissions, which were based on the emissions and emissions release 

characteristics contained in the 2005 National Emissions Inventory (NEI), to current facility-wide 

emissions, which are based on the 2011 NEI, for the HAP driving both cancer and non-cancer risks. The 

results of this comparison show that all four facilities experienced a net decrease in risk-driving HAP 

emissions (see Table 2 below). Company representatives indicated that these decreases are 

attributable to new product raw material changes and reduction in HAP in a HAP-containing waste 

stream. We therefore expect the current facility-wide risks for these facilities to be lower than the 

previously modeled risk values presented in Table 1. This emissions comparison further supports our 

expectation that risks from the OSRWO source category at these facilities are well below the level that 

we generally deem acceptable.
As the facility-wide risks at these four additional facilities are relatively low, the OSWRO operations are 

not the predominant activity at the facilities and are not expected to contribute significantly to the 

facility-wide risk, and the current emissions for the HAP driving cancer and non-cancer risk at each of 

these facilities is lower than when previously modeled, we determined that additional modeling to 

include these facilities is not necessary. Based on this information, we have also concluded that the

risks from these four facilities do not change our decision regarding risk acceptability for the OSWRO 

source category. Further, it was determined at proposal that the amended NESHAP, including the 

proposed revisions to the tank and equipment leak standards, provides an ample margin of safety to 

protect public health. The modeling results for the OSWRO source category conducted prior to

proposal of the NESHAP amendments showed that maximum cancer risks were 9-in-1 million and the 

maximum non-cancer target organ-specific hazard index (TOSHI) was 0.6, based on actual emissions.1

The projected OSWRO source category risks for these facilities are similar to or less than these risk 

values, and the information regarding the risks from these four facilities does not change our 

conclusions, presented for comment in the July 2, 2014 federal register notice, regarding the ample 

margin of safety for the OSWRO source category. 

Table 1. Facility–wide Risk for Facilities Identified during the Comment Period

Facility Location Cancer MIR

1 in a 

million

NonCancer 

TOSHI

Source Categories Driving 

Cancer and Non-Cancer 

Risk

Source

DuPont Orange, TX 40a0.9 Boilers

Previous RTR modeling 

Marine Tank Vessel 

Loading2

DuPont Axis, AL 6 0.08 Pesticide Active Ingredient

Previous RTR modeling

Pesticide Active 

Ingredient3

Eastman 

Chemical 

Company

Longview, 

TX 30 0.7

Hazardous Organic 

NESHAP, Polyether Polyols, 

Hazardous Waste 

Incineration

Previous RTR modeling 

Polyether Polyols2

Eastman 

Chemical 

Company

Kingsport, 

TN 10 1

Hazardous Waste 

Incineration

Previous RTR modeling 

Polyethylene 

Terephthalate in Polymer 

& Resins IV2

a As shown in Table 2, the facility-wide nickel emissions modeled in the Marine Tank Vessel Loading RTR are more than 2 orders of 

magnitude higher than current nickel emissions from the facility, and both the cancer and non-cancer risks from nickel would be significantly 

lower if additional modeling were performed.

 

1 Draft Residual Risk Assessment for the Off-Site Waste and Recovery Operations Source Category (May 2014) available at 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2012-0360-0003

2 Residual Risk Assessment for 7 Source Categories: Printing and Publishing, Marine Tank Vessel Loading Operations, 

Pharmaceuticals Production, Epichlorohydrin Elastomers, Polybutadiene Rubber, Styrene Butadiene, Nitrile Butadiene 

(January 2011) available at http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2010-0600-0405

3 Residual Risk Assessment for 7 Source Categories: Pesticide Active Ingredient Production

Polyether Polyols Production, Polymers and Resins IV -- Styrene Acrylonitrile, Polymers and Resins IV – Polystyrene, 

Polymers and Resins IV – Polyethylene Terephthalate, Polymers and Resins IV -- Methyl Methacrylate-Butadiene Styrene, 

Polymers and Resins IV -- Acrylic Butadiene Styrene (January 2014) available at 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2011-0435-0073
Table 2. Comparison of Previously Modeled Emissions vs Current Emissions4

Facility, 

Location

HAP Driving 

Cancer Risk

Emissions

(tons per year) HAP Driving 

Non-Cancer 

Risk

Emissions

(tons per year)

Modeled Current

% 

change Modeled Current

% 

change

DuPont,

Orange, TX

nickel 1.95 0.0034 -100 nickel 1.95 0.0034 -100

DuPont, Axis

AL

hydrazine 0.009 0 -100 chlorine 0.13 0 -100

hydrogen 

chloride

65.8 20.1 -69

Eastman 

Chemical 

Company, 

Longview, TX

naphthalene 6.01 11.0 +45 chlorine 5.81 2.47 -57

ethylene 

oxide 

9.93 8.25 -17 maleic 

anhydride

4.02 0 -100

benzene 27.4 8.89 -68 propionalde

hyde

31.1 15.2 -51

1,3-

butadiene

4.20 5.25 +20

Eastman 

Chemical 

Company, 

Kingsport, TN

arsenic 0.359 0.331 -8 chlorine 19.5 11.2 -43

chromium

(VI)

0.0973 0.0156 -84 hydrogen 

chloride

1200 355 -70

acetaldehyde 32.5 38.5 +16 antimony 2.81 0.0154 -99

 

4 Modeled emissions were based on the EPA 2005 NEI and current emissions are based on the 2011 NEI

available at http://www.epa.gov/ttnchie1/net/2011inventory.html.