1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Public Comment Draft - Do Not Cite or Quote v>EPA EPA Document# EPA-744-D-22-001 January 2022 DRAFT United States Office of Chemical Safety and Environmental Protection Agency Pollution Prevention Draft TSCA Screening Level Approach for Assessing Ambient Air and Water Exposures to Fenceline Communities Version 1.0 January 2022 ------- Public Comment Draft - Do Not Cite or Quote 37 TABLE OF CONTENTS 3 8 TABLE OF CONTENTS 2 39 LIST OF EXECUTIVE SUMMARY TABLES 5 40 LIST OF TABLES 5 41 LIST OF FIGURES 7 42 LIST OF APPENDIX TABLES 7 43 ACKNOWLEDGEMENTS 8 44 EXECUTIVE SUMMARY 9 45 1 INTRODUCTION 16 46 2 SCREENING METHODOLOGIES 21 47 2.1 Ambient Air Pathway 21 48 2.1,1 Environmental Air Releases 22 49 2.1.1.1 Step 1: Obtain 2019 TRI Data 22 50 2.1.1.2 Step 2: Map 2019 TRI to Occupational Exposure Scenarios 23 51 2.1.1.3 Step 3: Estimate Number of Release Days for Each OES 24 52 2.1.1.4 Step 4: Estimate Air Emissions for OES with No 2019 TRI Data 24 53 2.1.1.5 Step 5: Prepare Air Emission Summary for Ambient Air Exposure Modeling 25 54 2,1,2 Ambient Air Concentrations and Exposures 27 55 2.1.2.1 Ambient Air Pre-screening Methodology 28 56 2.1.2.2 Ambient Air Full-Screening Methodology 30 57 2.1.2.3 Ambient Air Co-resident Screening Methodology 40 58 2.2 Ambient Water Pathway 44 59 2.2,1 Environmental Water Releases 44 60 2.2.1.1 Step 1: Obtain TRI and DMR Data 45 61 2.2.1.2 Step 2: Map TRI and DMR to Occupational Exposure Scenarios 45 62 2.2.1.3 Step 3: Estimate Number of Release Days for Each OES 45 63 2.2.1.4 Step 4: Estimate Water Releases for OES with No TRI or DMR Data 46 64 2.2.1.5 Step 5: Prepare Water Release Summary for Ambient Water Exposure Modeling 46 65 2.2,2 Ambient Water Concentrations and Exposures 46 66 2.2.2.1 Step 1: Obtain Measured Drinking Water Concentrations 46 67 2.2.2.2 Step 2: Model Surface Water Concentrations from Facility Releases 47 68 2.2.2.3 Step 3: Estimate Drinking Water Exposure 48 69 2.2.2.4 Step 4: Estimate Incidental Oral Exposures from Swimming 49 70 2.2.2.5 Step 5: Estimate Incidental Dermal Exposure from Swimming 51 71 2.3 Risk Estimation Approach 53 72 2.3,1 Characterization of Non-cancer Risks 53 73 2.3,2 Characterization of Cancer Risks 54 74 2.4 Key Assumptions and Uncertainties 54 75 2.4.1 Assumptions and Uncertainties in Release Estimation 54 76 2.4,2 Assumptions and Uncertainties in Air Pathway Exposure Modeling 57 77 2.4.3 Assumption and Uncertainties in Drinking Water Monitoring Results 59 78 2,4,4 Assumptions and Uncertainties in Water Pathway Exposure Modeling 60 79 2.4,5 Assumptions and Uncertainties in Risk Characterization 61 80 3 CASE STUDY RESULTS 62 Page 2 of204 ------- 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 Public Comment Draft - Do Not Cite or Quote 3.1 1 -Bromopropane (Air Pathway) 62 3.1.1 Background for 1 -BP 62 3.1.2 Human Health Hazard Endpoints for 1 -BP 62 3.1.2.1 Assumptions and Uncertainties for 1 -BP Human Health Hazard 63 3.1.3 Environmental Releases for 1-BP 63 3.1.3.1 Step 1: Obtain 2019 TRI Data 63 3.1.3.2 Step 2: Map 2019 TRI to OES 63 3.1.3.3 Step 3: Estimate Number of Release Days for Each OES 64 3.1.3.4 Step 4: Estimate Air Emissions for OES with No TRI Data 65 3.1.3.5 Step 5: Prepare Air Emission Summary for Ambient Air Exposure Modeling 69 3.1.4 Exposures for 1 -BP 69 3.1.5 Risk Characterization for 1 -BP 82 3.1.5.1 Fenceline Inhalation Risk for 1-BP 82 3.1.5.1.1 Land Use Considerations 88 3.1.5.2 Co-resident Inhalation Risk 88 3.1.6 Confidence and Risk Conclusions for 1-BP Case Study Results 89 3.2 Methylene Chloride - Air and Water Pathways 89 3.2.1 Background forMC 89 3.2.2 Human Health Hazard Endpoints for MC 90 3.2.2.1 Assumptions and Uncertainties for MC Human Health Hazard 91 3.2.3 Environmental Releases for MC 91 3.2.3.1 Step 1: Obtain TRI Data and DMR 91 3.2.3.2 Step 2: Map TRI and DMR to OES 91 3.2.3.3 Step 3: Estimate Number of Release Days for Each OES 92 3.2.3.4 Step 4: Estimate Air Emissions for OES with No 2019 TRI Data and Water Releases for OES with No TRI or DMR Data 93 3.2.3.5 Step 5: Prepare Air Emission and Water Release Summary for Ambient Air and Water Exposure Modeling 98 3.2.4 Exposures for MC 99 3.2.4.1 Air Pathway 99 3.2.4.2 Water Pathway Ill 3.2.4.2.1 Ambient Water Monitoring Results Ill 3.2.4.2.2 Drinking Water Monitoring Results Ill 3.2.4.2.3 Modeled Drinking Water 116 3.2.4.2.4 Incidental Oral for MC 119 3.2.4.2.5 Incidental Dermal for MC 122 3.2.5 Risk Characterization for MC 125 3.2.5.1 Risk Characterization for the Air Pathway 125 3.2.5.1.1 Land Use Considerations 132 3.2.5.2 Risk Characterization for the Water Pathway 133 3.2.5.2.1 Drinking Water Risk for MC 133 3.2.5.2.2 Incidental Swimming Risk for MC 136 3.2.5.2.3 Ambient and Drinking Water Monitoring Information for MC 140 3.2.6 Confidence and Risk Conclusions for MC Case Study Results 141 3.3 n-Methylpyrrolidone (Water Pathway) 141 3.3.1 B ackground for NMP 141 3.3.2 Human Health Hazard Endpoints for NMP 141 3.3.2.1 Assumptions and Uncertainties for NMP Human Health Hazard 142 3.3.3 Environmental Releases for NMP 143 Page 3 of204 ------- Public Comment Draft - Do Not Cite or Quote 130 3,3,4 Exposures for NMP 145 131 3.3.4.1 Drinking Water for NMP 145 132 3.3.4.2 Incidental Oral for NMP 148 133 3.3.4.3 Incidental Dermal for NMP 151 134 3,3,5 Risk Characterization for NMP 154 135 3.3.5.1 Drinking Water Risk for NMP 154 136 3.3.5.2 Incidental Swimming Risk for NMP 155 137 3.3.5.2.1 Incidental Oral for NMP 155 138 3.3.5.2.2 Incidental Dermal for NMP 157 139 3.3,6 Confidence and Risk Conclusions for NMP Case Study Results 159 140 REFERENCES 160 141 Appendix A ABBREVIATIONS AND PHYSICAL-CHEMICAL PROPERTIES 164 142 A,1 Abbreviations 164 143 A.2 Select Physical-Chemical Properties of Case Study Chemicals 166 144 Appendix B LIST OF SUPPLEMENTAL FILES 168 145 Appendix C TRI-CDR CROSSWALK 169 146 Appendix D EXPOSURE - PRE-SCREENING ANALYSIS 188 147 Appendix E 1-BP, MC, AND NMP RISK EVALUATION COU TO OES MAPPING 192 148 149 Page 4 of 204 ------- 150 151 152 153 154 155 156 157 158 159 160 161 162 163 164 165 166 167 168 169 170 171 172 173 174 175 176 177 178 179 180 181 182 183 184 185 186 187 188 189 190 191 192 193 194 195 196 197 Public Comment Draft - Do Not Cite or Quote LIST OF EXECUTIVE SUMMARY TABLES TableES 1. EPA's Overall Approach for Assessing Exposures and Associated Risks for Fenceline Communities 12 Table ES 2. Seven of the First 10 Chemicals, and Associated Pathways, for Which EPA Intends to Conduct Screening Level Analyses 13 Table ES 3. Summary of Additional Risks Identified for the 1-BP Air Pathway 13 Table ES 4. Summary of Additional Risks Identified for the MC Air Pathway 14 Table ES 5. Summary of Additional Risks Identified for the MC Water Pathway 14 Table ES 6. Summary of Additional Risks Identified for the NMP Water Pathway 15 LIST OF TABLES Table 1-1. Seven of the First 10 Chemicals Undergoing Risk Evaluation and Associated Pathways for Which Supplemental Screening Level Analysis for Fenceline Communities Will Be Conducted 17 Table 2-1. Summary of Air Release Data Elements 27 Table 2-2. Assumptions for Intraday Emission-Release Duration 34 Table 2-3. Assumptions for Inter-day Emission-Release Pattern 35 Table 2-4. Description of Daily or Period Average and Air Concentration Statistics 39 Table 2-5. Summary of Two Building Configurations and Methods to Estimate Interzonal Flow Rate . 42 Table 2-6. Incidental Oral Exposure Factors for MC and NMP 50 Table 2-7. Incidental Dermal Exposure Factors for MC and NMP 53 Table 3-1. Hazard Values Used for Risk Estimation in the 1-BP Risk Evaluation 62 Table 3-2. Hazard Values for 1-BP Used in this Fenceline Analysis 63 Table 3-3. Number of Release Days for Each 1-BP OES 64 Table 3-4. Summary of Air Release Estimation Approaches for Each 1-BP OES 66 Table 3-5. Fenceline Community Exposure Scenarios for 1-BP 69 Table 3-6. 95th Percentile Exposure Concentration Summary across Facilities within Each OES for 1- BP 72 Table 3-7. Simulation Matrix for Evaluating Co-resident Exposures from Dry-Cleaning Operations (IECCU) for 1-BP 80 Table 3-8. Predicted 1-BP Concentrations for Co-resident Apartment 82 Table 3-9. 1-BP Inhalation Risk across OES at Various Distances from Releasing Facility (Based on 95th Percentile Exposure Concentrations) 83 Table 3-10. Summary of Fenceline Community Exposures Expected near Facilities Where Modeled Air Concentrations Indicated Risk for 1-BP 88 Table 3-11. 1-BP Inhalation Risk for Co-residents of Dry Cleaning Facilities 89 Table 3-12. Hazard Values Used for Risk Estimation in the Methylene Chloride Risk Evaluation 90 Table 3-13. Hazard Values for MC Used in this Fenceline Analysis 91 Table 3-14. Number of Release Days for Each MC OES 92 Table 3-15. Summary of Air Release Estimation Approaches for Each MC OES 94 Table 3-16. Summary of Water Release Estimation Approaches for Each Methylene Chloride OES .... 96 Table 3-17. Fenceline Community Exposure Scenarios for MC 99 Table 3-18. 95th Percentile Exposure Concentration Summary across Facilities within Each OES for MC 102 Table 3-19. Measured Concentrations of MC in Drinking Water Obtained from the Six-Year Review Data (2006 2011) 113 Table 3-20. Summary of MC Drinking Water Exposure by OES for 20 Days of Release Scenarios.... 117 Table 3-21. Summary of MC Drinking Water Exposure by OES for Maximum Days of Release Scenarios 118 Page 5 of204 ------- 198 199 200 201 202 203 204 205 206 207 208 209 210 211 212 213 214 215 216 217 218 219 220 221 222 223 224 225 226 227 228 229 230 231 232 233 234 235 236 237 238 239 240 241 242 243 244 245 246 Public Comment Draft - Do Not Cite or Quote Table 3-22. Summary of MC Incidental Oral Ingestion Exposure by OES for 20 Days of Release Scenarios 120 Table 3-23. Summary of MC Incidental Oral Ingestion Exposure by OES for Maximum Days of Release Scenarios 121 Table 3-24. Summary of MC Incidental Dermal Exposure by OES for 20 Days of Release Scenarios 123 Table 3-25. Summary of Methylene Chloride Incidental Dermal Exposure by OES for Maximum Days of Release Scenarios 124 Table 3-26. MC Inhalation Risk across OES at Various Distances from Releasing Facility (Based on 95th percentile exposure Concentrations) 126 Table 3-27. Summary of Fenceline Community Exposures Expected near Facilities Where Modeled Air Concentrations Indicated Risk for MC 132 Table 3-28. Summary of Non-cancer Risk Estimates for Drinking Water Exposures by OES under 20 Days of Release Scenarios for MC 133 Table 3-29. Summary of Cancer Risk Estimates from Drinking Water Exposure by OES under 20 Days of Release Scenarios for MC 134 Table 3-30. Summary of Risk Estimates for Drinking Water Exposures by OES under Maximum Days of Release Scenarios for MC 135 Table 3-31. Summary of Cancer Risk Estimates from Drinking Water Exposure by OES under Maximum Days of Release Scenarios for MC 136 Table 3-32. Summary of Non-cancer Risk Estimates for Incidental Oral Ingestion Exposures by OES under 20 Days of Release Scenarios for MC 137 Table 3-33. Summary of Non-cancer Risk Estimates for Incidental Oral Ingestion Exposures by OES under Maximum Days of Release Scenarios for MC 138 Table 3-34. Summary of Non-cancer Risk Estimates for Incidental Dermal Exposures by OES under 20 Days of Release Scenarios for MC 139 Table 3-35. Summary of Non-cancer Risk Estimates for Incidental Dermal Exposures by OES under Maximum Days of Release Scenarios for MC 140 Table 3-36. Hazard Values Used for Risk Estimation in the n-Methylpyrrolidone Risk Evaluation 142 Table 3-37. Hazard Values forNMP Used in this Fenceline Analysis 142 Table 3-38. Summary of Water Release Estimation Approaches for Each NMP OES 143 Table 3-39. Summary of NMP Drinking Water Exposure by OES for 12 Days of Release Scenarios . 146 Table 3-40. Summary of NMP Drinking Water Exposure by OES for Maximum Days of Release Scenarios 147 Table 3-41. Summary of NMP Incidental Oral Ingestion Exposure by OES for 12 Days of Release Scenarios 149 Table 3-42. Summary of NMP Incidental Oral Ingestion Exposure by OES for Maximum Days of Release Scenarios 150 Table 3-43. Summary of NMP Incidental Dermal Exposure by OES for 12 Days of Release Scenarios 152 Table 3-44. Summary of NMP Incidental Dermal Exposure by OES for Maximum Days of Release Scenarios 153 Table 3-45. Summary of Non-cancer Risk Estimates for Drinking Water Exposures by OES for Various Lifestages under 12 Days of Release Scenarios forNMP 154 Table 3-46. Summary of Non-cancer Risk Estimates for Drinking Water Exposures by OES for Various Lifestages under Maximum Days of Release Scenarios for NMP 155 Table 3-47. Summary of Non-cancer Incidental Oral Ingestion Risk by OES for Various Lifestages under 12 Days of Release Scenario forNMP 156 Table 3-48. Summary of Non-cancer Incidental Oral Ingestion Risk by OES for Various Lifestages under Maximum Days of Release Scenario forNMP 157 Page 6 of 204 ------- 247 248 249 250 251 252 253 254 255 256 257 258 259 260 261 262 263 264 265 266 267 268 269 270 271 272 273 274 275 276 277 278 Public Comment Draft - Do Not Cite or Quote Table 3-49. Summary of Non-cancer Risk Estimates for Incidental Dermal Exposure by OES for Various Lifestages under 12 Days of Release Scenario for NMP 158 Table 3-50. Summary of Non-cancer Risk Estimates for Incidental Dermal Exposure by OES for Various Lifestages under Maximum Days of Release Scenario for NMP 159 LIST OF FIGURES Figure 2-1. Overview of EPA's Screening Level Ambient Air Pathway Methodology 22 Figure 2-2. General Methodology for Estimating Air Emissions 22 Figure 2-3. Decision Tree for Estimating Air Releases 25 Figure 2-4. Brief Description of Methodologies Used to Estimate Ambient Air Concentrations and Exposures 28 Figure 2-5. Pre-screen Exposure Scenarios Modeled for Max and Mean Release Using IIOAC Model. 29 Figure 2-6. Receptor Locations around Each Distance Ring 36 Figure 2-7. Modeled Distances from Facility 37 Figure 2-8. Receptor Locations between 100 and 1,000 m 38 Figure 2-9. Schematic Representation of the Two-Zone Model for Co-resident Exposure 41 Figure 2-10. Overview of EPA's Screening Level Ambient Water Pathway Methodology 44 Figure 2-11. General Methodology for Estimating Water Releases 44 Figure 2-12. General Methodology for Estimating Ambient Water Exposures 46 LIST OF APPENDIX TABLES TableApx A-l. Select Physical-Chemical Properties of Case Study Chemicals 167 Table_Apx C-l. TRI-CDRUse Code Crosswalk 169 Table Apx D-l. Parameters Used for Point and Fugitive Source Type 188 Table Apx D-2. Average Air Concentrations and Particle Deposition for 14 IIOAC Climate Regions 188 Table Apx D-3. Maximum and Mean Releases by Chemical for Pre-screening Analysis 189 Table Apx D-4. Exposure Concentrations and Risk Calculations 191 TableApx E-l. 1-BP Risk Evaluation Conditions of Use to OES Mapping 192 Table Apx E-2. MC Risk Evaluation Conditions of Use to OES Mapping 195 Table_Apx E-3. NMP Risk Evaluation Conditions of Use to OES Mapping 201 Page 7 of204 ------- 279 280 281 282 283 284 285 286 287 288 289 290 291 292 293 294 295 Public Comment Draft - Do Not Cite or Quote ACKNOWLEDGEMENTS This report was developed by the United States Environmental Protection Agency (U.S. EPA), Office of Chemical Safety and Pollution Prevention (OCSPP), Office of Pollution Prevention and Toxics (OPPT). Acknowledgements The OPPT Assessment Team acknowledges assistance from the following EPA contractors: Eastern Research Group, Inc (ERG; Contract No. 68HERD20A0002), ICF (Contract No. EP-W-12-010), and Versar (Contract No. EP-W-17-006) Docket Supporting information can be found in public docket: https://www.regulations.gov/docket/ O- OPPT-2C Disclaimer Any mention of trade names or commercial products should not be interpreted as an endorsement by EPA. Page 8 of204 ------- 296 297 298 299 300 301 302 303 304 305 306 307 308 309 310 311 312 313 314 315 316 317 318 319 320 321 322 323 324 325 326 327 328 329 330 331 332 333 334 335 336 337 338 339 Public Comment Draft - Do Not Cite or Quote EXECUTIVE SUMMARY Background The United States Environmental Protection Agency (EPA) published 10 final risk evaluations between 2020 and 2021 under the Toxic Substances Control Act (TSCA) as amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act in June 2016. TSCA section 6(b)(4)(A) requires the Agency to "conduct risk evaluations.. .to determine whether a chemical substance presents an unreasonable risk of injury to health or the environment, without consideration of costs or other non-risk factors, including an unreasonable risk to a potentially exposed or susceptible subpopulation identified as relevant to the risk evaluation by the Administrator, under the conditions of use." However, during the course of finalizing many of these first 10 risk evaluations, a policy decision was made, at that time, for EPA's Office of Chemical Safety and Pollution Prevention (OCSPP) to not assess certain exposure pathways (including, but not limited to, ambient air, ambient water, and drinking water) that fall under the jurisdiction of other EPA-administered laws. As a result, there are instances where EPA did not evaluate potential exposures and associated potential risks to the general population or certain subsets of the general population. What Is EPA Doing in This Work? EPA developed a proposed screening level methodology to evaluate potential exposures and associated potential risks to human receptors in proximity to (1) facilities releasing chemicals undergoing risk evaluation under TSCA section 6 to the ambient air, and (2) waterbodies receiving facility releases (direct or indirect) of chemicals undergoing risk evaluation under TSCA section 6. EPA considers these receptors a subset of the general population and categorizes them as "fenceline communities" throughout this work. Additionally, one or more receptors comprising fenceline communities can be of any age, including reproductive age, health status, or other factors like chemical sensitivity and therefore may also be considered potentially exposed or susceptible subpopulations (PESS).1 For purposes of the proposed screening level methodology, EPA limits the proximity of receptors evaluated to those less than or equal to 10,000 meters from a facility releasing chemicals undergoing risk evaluation under TSCA section 6 to the ambient air. For evaluated aquatic exposure routes, proximity is limited to the extent of the identified waterbody receiving a facility discharge and therefore does not have a specific distance associated with the human receptor. Therefore, for purposes of this report, EPA is defining "fenceline communities" as follows: Members of the general population that are in proximity to air emitting facilities or a receiving waterbody, and who therefore may be disproportionately exposed to a chemical undergoing risk evaluation under TSCA section (6). For the air pathway, proximity goes out to 10,000 meters from an air emitting source. For the water pathway, proximity does not refer to a specific distance measuredform a receiving waterbody, but rather to those members of the general population that may interact with the receiving waterbody and thus may be exposed. The proposed screening level methodology, as presented in this work, will go through public and peer review (including review by the Scientific Advisory Committee on Chemicals [SACC]) for comments 1 TSCA section 3(12) states that "the term 'potentially exposed or susceptible subpopulation' means a group of individuals within the general population identified by the Administrator who, due to either greater susceptibility or greater exposure, may be at greater risk than the general population of adverse health effects from exposure to a chemical substance or mixture, such as infants, children, pregnant women, workers, or the elderly." (15 U.S.C. §2602). Page 9 of 204 ------- 340 341 342 343 344 345 346 347 348 349 350 351 352 353 354 355 356 357 358 359 360 361 362 363 364 365 366 367 368 369 370 371 372 373 374 375 376 377 378 379 380 381 382 383 384 385 386 387 388 Public Comment Draft - Do Not Cite or Quote on the proposed methodology as well as recommended revisions or improvements to the methodology. Following public and peer review, EPA will review comments, recommendations, and improvements; modify the proposed screening level methodology, as appropriate, and utilize the resulting final screening level methodology as a framework to conduct screening level analyses for seven of the first 10 chemicals for which EPA published risk evaluations between 2020 and 2021, and listed in Table ES 2, to help determine if there are potential risks to fenceline communities from the air and water pathways that were previously not assessed. Although the focus of this work is screening level analyses for seven of the first 10 chemicals for which EPA published risk evaluations between 2020 and 2021, the final screening level methodology framework can also be applied to future chemicals undergoing risk evaluation under TSCA section 6. EPA also provides three case study chemicals in this work to illustrate the application of the proposed screening level methodology described in this document. Two case studies are provided for the air pathway screening level methodology (1-bromopropane [1-BP] and methylene chloride [MC]) and two case studies are provided for the water pathway screening level methodology (MC and n-methyl-2- pyrrolidone [NMP]). The three case studies are carried through the processes of the environmental release assessment, exposure assessment, risk calculations, and associated risk characterizations based on the proposed screening level methodologies. While all three case study chemicals are chemicals for which EPA published risk evaluations between 2020 and 2021, the results as presented in this work are not final agency actions and will not be used as presented to support risk management actions or associated rulemaking activities resulting from the published risk evaluations at this time. Finally, EPA provides a brief description of how results from the screening level analysis may further inform or support the Agency's risk management actions and associated rulemaking outcomes under TSCA resulting from published risk evaluations for chemicals undergoing risk evaluation. The descriptions are presented as hypothetical examples in the Introduction (Section 1) only to provide insight into the next steps following completion of a screening level analysis. Although these examples describe potential risk management actions/rulemaking outcomes, neither the outcomes described in the examples, nor the results from screening level analysis, are final agency actions as presented in this work. All proposed risk management actions/rulemaking activities and supporting documentation for such actions, including any screening level analyses conducted, will go through public comment prior to finalization. What Is EPA Not Doing in This Work? EPA is not providing any risk conclusions related to fenceline communities for any chemical substance in this work. Similarly, EPA is not providing any risk management actions or rulemaking activities for any chemical substance in this work. This work is intended to present a proposed methodology for conducting screening level analyses for chemicals undergoing risk evaluation under TSCA section 6. All case study chemicals included in this work are presented for illustrative purposes only to demonstrate the applicability and efficacy of the proposed methodology and do not represent final agency actions in relation to environmental release assessments, exposure assessments, or risk characterizations. The proposed methodology presented in this work is limited to certain air and water pathways previously not assessed in published risk evaluations. This work does not include proposed methodology for other pathways previously not assessed (e.g., disposal, land use, groundwater-derived drinking water sources like wells, fish consumption) in published risk evaluations. Other components of published risk evaluations including, but not limited to, hazard identification, development of hazard endpoints, and Page 10 of 204 ------- 389 390 391 392 393 394 395 396 397 398 399 400 401 402 403 404 405 406 407 408 409 410 411 412 413 414 415 416 417 418 419 420 421 422 423 424 425 426 427 428 429 430 431 432 433 434 435 436 Public Comment Draft - Do Not Cite or Quote assessment of occupational exposure, ecological exposure, and consumer exposure will not be revisited as part of supplemental screening level analyses for fenceline communities. EPA is not providing a proposed methodology for conducting screening level analyses for aggregate/cumulative exposures in this work. However, EPA believes the design of the proposed methodology presented in this work is sufficiently flexible to allow addition of expanded capacities to evaluate concepts like aggregate/cumulative exposures. Additionally, the Agency invites suggestions as part of the charge for the SACC on what such expanded capacities could look like for future risk evaluations. EPA is not providing a proposed methodology for conducting screening level analyses to address potential environmental justice concerns in this work. Although the Agency is not conducting an environmental justice analysis of fenceline communities as part of this work, the Agency anticipates the proposed screening level methodology can serve as a baseline analysis which can identify potential environmental justice concerns and inform future environmental justice analyses that assess racial and economic disparities in risk exposure under baseline and policy scenarios. Additionally, EPA invites suggestions as part of the charge for the SACC on what such expanded capacities could look like for future risk evaluations. Overall Approach Summary The proposed screening level methodology presented in this work uses reasonably available data, information, and models to quantify environmental releases, evaluate exposures to fenceline communities and characterize risks associated with such releases and exposures for certain air and water pathways previously not evaluated in published risk evaluations. The overall approach for the screening level methodology is summarized in TableES 1 and is intended to be applied to 7 of the first 10 chemicals undergoing risk evaluation under TSCA section 6, as summarized in Table ES 2, as well as future chemicals undergoing risk evaluation under TSCA section 6, across the conditions of use considered in the associated risk evaluations. When assessing exposures for industrial/commercial conditions of use (COUs), EPA generally defines an occupational exposure scenario or scenarios (OES for both) to capture the basic, underlying source of exposure for a given COU. Although the proposed screening level methodology does not involve evaluation of occupational exposures, EPA carries the OES label through this work to allow categorization of multiple facilities which may be involved with a single COU. A mapping of OES to the conditions of use (COU) in published risk evaluations for the three case study chemicals is provided in Appendix E. Overall Results Summary EPA provides three case study chemicals (1-BP, MC, and NMP) in this work to illustrate the application of the proposed screening level methodology described in this document. The three case studies are carried through the processes of the environmental release assessment, exposure assessment, risk calculations, and associated risk characterizations based on the proposed screening level methodology. While all three case study chemicals are chemicals for which EPA published risk evaluations between 2020 and 2021, the results, as presented in this work, are not final agency actions and will not be used as presented to support risk management actions or associated rulemaking activities resulting from the published risk evaluations at this time. Page 11 of 204 ------- 437 438 439 440 441 442 443 444 445 446 447 448 449 450 451 452 453 454 455 456 457 458 459 Public Comment Draft - Do Not Cite or Quote The 1-BP case study presented in this work includes evaluation of 15 air pathway OES. Additional risks2 were identified for 14 of the 15 OES and are summarized in TableES 3. An analysis of the water pathway for 1-BP was conducted in the published problem formulation and discussed in the published risk evaluation. To summarize, the analysis found that exposure to 1-BP via the water pathway is not expected for 1-BP due to physical-chemical and fate properties of 1-BP, along with low reported releases to water (5 lbs total in a year for all facilities). Since exposure via the water pathway is not expected for 1-BP, EPA does not intend to conduct screening level analysis of the water pathway for fenceline communities. The MC case study presented in this work includes evaluation of 17 air pathway OES. Additional risks were identified for 8 of the 17 OES and are summarized in Table ES 4. EPA also evaluated 13 water pathway OES for MC. Additional risk was identified for one of the 13 OES evaluated for the drinking water pathway but none for the incidental oral/dermal pathways as summarized in Table ES 5. The NMP case study presented in this work includes evaluation of six water pathway OES. There were no additional risks identified for any of these OES as summarized in Table ES 6. Although this work currently does not include evaluation of the air pathway for NMP, as shown in Table_ES 2, NMP is included among the seven of the first 10 chemicals undergoing risk evaluation for which EPA will conduct a screening level analysis using the final screening level analysis framework for the air pathway. Table ES 1. EPA's Overall Approach for Assessing Exposures and Associated Risks for Fenceline Communities Assessment Step Air Pathway Water Pathway Release Assessment • Use 2019 Toxics Release Inventory (TRI) Data. • Where no 2019 TRI data are available, estimate releases based on past TRI data, estimation methods used in final risk evaluations, and TRI surrogate data (TRI data from other OES). • Use release scenarios from final risk evaluations, which incorporate direct and indirect release data from both TRI and Discharge Monitoring Report (DMR) information depending on chemical. Exposure Assessment • Use the American Meteorology Society/Environmental Protection Agency Regulatory Model (AERMOD) to estimate ambient air exposure concentrations for receptors at eight finite distances and one area distance out to 10,000 meters from a facility releasing the chemical evaluated to the ambient air. • When applicable, use the Indoor Environmental Concentrations in Buildings with Conditioned and • Use modeled surface water concentrations from final risk evaluations to evaluate drinking water and incidental oral/dermal exposure; surface water concentrations were estimated using the Exposure and Fate Assessment Tool (E-FAST) 2014. 2 Additional risks are indicated when the calculated margin of exposure (MOE) is less than the benchmark MOE for non- cancer effects or when calculated inhalation unit risks (IUR) are greater than the benchmark IUR of 1 x 10 06 for cancer effects. Page 12 of 204 ------- Public Comment Draft - Do Not Cite or Quote Assessment Step Air Pathway Water Pathway Unconditioned Zones (IECCU) to estimate indoor air exposure concentrations for residents that live above or adjacent to a releasing facility. Risk Characterization • Use human health hazard endpoints from the final risk evaluations applied to the above scenarios for a continuous-exposure basis. 460 461 TableES 2. Seven of the First 10 Chemicals, and Associated Pathways, for Which EPA Intends to 462 Conduct Screening Level Analyses Air Pathway Water Pathway Case study chemicals • 1-Bromopropane (1-BP) • Methylene chloride (MC) • n-Methylpyrrolidone (NMP) • Methylene chloride (MC) Additional chemicals subject to screening level analyses • n-Methylpyrrolidone (NMP) • Trichloroethylene (TCE) • Perchloroethylene (PCE) • C arb on tetrachl oride(CTC) • 1,4-Dioxane (1,4D) • Trichloroethylene (TCE) • Tetrachloroethylene (PCE) • C arb on tetrachl oride(CTC) • (1,4-Dioxane water pathways will be examined via a separate Supplement to the published Risk Evaluation) 463 464 Table ES 3. Summary of Additional Risks Identified for the 1-BP Air Pathway 1-BP Air Pathway OESs Additional Risk Identified? Manufacturing Yes Import Yes Processing-Formulation Yes Processing-Incorporate into Articles Yes Processing as Reactant Yes Repackaging Yes Degreasing Yes Aerosol Spray Degreaser/Cleaner Yes Dry-Cleaning Yes Spot-Cleaning/Stain Remover Yes Spray Adhesives No Other Uses - Cutting Oil Yes Asphalt Extraction Yes Page 13 of 204 ------- Public Comment Draft - Do Not Cite or Quote 1-BP Air Pathway OESs Additional Risk Identified? Recycling and Disposal Yes Co-Resident Receptors (Dry-Cleaning) Yes 465 466 Table ES 4. Summary of Additional Risks Identified for the MC Air Pathway MC Air Pathway OESs Additional Risk Identified? Manufacturing No Processing-Reactant Yes Processing-Incorporate into Formulation, Mixture, or Reaction Product Yes Repackaging No Batch Open-Top Degreasing No Cleaner/Degreaser-Unknown Yes Commercial Aerosol Products No Fabric Finishing No Spot Cleaning No Cellulose Triacetate Film Production Yes Flexible Polyurethane Foam Production Yes Laboratory Use No Plastic Product Manufacturing Yes Lithographic Printing Plate Cleaning No Miscellaneous Non-aerosol Industrial and Commercial Use Yes Waste Handling, Disposal, Treatment, Recycling No Paint Remover Yes 467 Table ES 5. Summary of Adt itional Risks Identified for the MC Water Pathway MC Water Pathway OESs Additional Risk Identified? Drinking Water Incidental Oral Incidental Dermal Manufacturing No No No Import and Repackaging No No No Page 14 of 204 ------- Public Comment Draft - Do Not Cite or Quote MC Water Pathway OESs Additional Risk Identified? Drinking Water Incidental Oral Incidental Dermal Processing as a Reactant No No No Processing: Formulation No No No Polyurethane Foam No No No Plastics Manufacturing No No No CTA Film Manufacturing No No No Lithographic Printer Cleaner No No No Spot Cleaner No No No Recycling and Disposal Yes No No Other No No No DOD No No No WWTP No No No 469 470 Table ES 6. Summary of Additional Risks Identified for the NMP Water Pathway NMP Water Pathway OESs Additional Risk Identified? Drinking Water Incidental Oral Incidental Dermal Chemical Processing, Excluding Formulation No No No Electronics Manufacturing No No No Formulation No No No Metal Finishing No No No Disposal and Recycling No No No Cleaning No No No 471 472 Page 15 of 204 ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Public Comment Draft - Do Not Cite of Quote 1 INTRODUCTION The United States Environmental Protection Agency (EPA) published 10 risk evaluations between 2020 and 2021 under the Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg Act). The Lautenberg Act amended the Toxic Substances Control Act (TSCA) in June 2016. Each of these TSCA section 6(b) risk evaluations underwent public comment and peer review (including review by the Scientific Advisory Committee on Chemicals, SACC) prior to publication. The published risk evaluations can be accessed online at Chemicals Undergoing Risk Evaluation under TSCA. During the course of finalizing many of these first 10 risk evaluations, a policy decision was made, at that time, for EPA's Office of Chemical Safety and Pollution Prevention (OCSPP) to not assess certain exposure pathways (including, but not limited to, ambient air, ambient water, and drinking water) that fall under the jurisdiction of other EPA-administered laws. As a result, there are instances where EPA did not evaluate potential exposures and associated potential risks to the general population or certain subsets of the general population. To examine whether the policy decision to exclude certain exposure pathways from the published risk evaluations may have caused EPA to miss potential exposures and associated potential risks from the air or water pathways, EPA developed this proposed screening level methodology to evaluate potential exposures and associated potential risks to human receptors in proximity to (1) facilities releasing chemicals undergoing risk evaluation under TSCA section 6 to the ambient air, and (2) waterbodies receiving facility releases (direct or indirect) of chemicals undergoing risk evaluation under TSCA section 6. EPA considers these receptors a subset of the general population and categorizes them as "fenceline communities" throughout this work. Additionally, one or more receptors making up fenceline communities can be of any age—including reproductive age, health status, or other factors like chemical sensitivity—therefore, they may also be considered potentially exposed or susceptible subpopulations (PESS).3 For purposes of the proposed screening level methodology, EPA limits the proximity of human receptors evaluated to those less than or equal to 10,000 meters from a facility releasing chemicals undergoing risk evaluation to the ambient air. This distance of 10,000 meters was selected to capture receptors nearer to releasing facilities than may otherwise be evaluated under other EPA administered laws. Additionally, professional knowledge and experience regarding exposures associated with the ambient air pathway found that typical risks frequently occur out to approximately 1,000 meters from a releasing facility and quickly decrease farther out. Although 10,000 meters is an order of magnitude farther out than where risks are expected to decrease, it provides an opportunity to verify expectations and also characterize how quickly risks decrease. For evaluated aquatic exposure routes, proximity is limited to the extent of the identified waterbody receiving a facility discharge and therefore does not have a specific distance associated with the human receptor. Therefore, for purposes of this report, EPA is defining "fenceline communities" as follows: Members of the general population that are in proximity to air emitting facilities or a receiving waterbody, and who therefore may be disproportionately exposed to a chemical undergoing risk evaluation under TSCA section (6). For the air pathway, proximity goes out to 10,000 meters from an air emitting source. For the water pathway, proximity does 3 TSCA section 3(12) states that "the term 'potentially exposed or susceptible subpopulation' means a group of individuals within the general population identified by the Administrator who, due to either greater susceptibility or greater exposure, may be at greater risk than the general population of adverse health effects from exposure to a chemical substance or mixture, such as infants, children, pregnant women, workers, or the elderly." (15 U.S.C. §2602). Page 16 of 204 ------- 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 Public Comment Draft - Do Not Cite of Quote not refer to a specific distance measuredform a receiving waterbody, but rather to those members of the general population that may interact with the receiving waterbody and thus may be exposed. The Agency believes the screening level methodology presented in this work can be used to ensure potential risks to fenceline communities will not go unidentified and unaddressed for the first chemicals that underwent risk evaluations under TSCA. The Agency also believes, given the extensive unreasonable risks already identified for all of these first substances, that it is imperative the Agency address these risks via protective and expeditiously promulgated risk management rules. It is for these reasons that the Agency quickly moved to develop and release this proposed screening level methodology for public comment and peer review—the Agency believes that the law requires, and the public is entitled to, protections from the identified risks as quickly as those protections can be finalized and implemented. The proposed screening level methodology, as presented in this work, will go through public and peer review (including review by the SACC) for comments on the proposed methodology as well as recommended revisions or improvements to the methodology. Following public and peer review, EPA will review comments, recommendations, and improvements; modify the proposed screening level methodology, as appropriate, and finalize the screening level methodology as a framework to conduct screening level analyses. The final screening level analysis methodology framework will be used to conduct screening level analyses for seven of the first 10 chemicals for which EPA published risk evaluations between 2020 and 2021, as listed in Table 1-1, to help determine if there are potential exposures and associated potential risks to fenceline communities from the air and water pathways that were previously not assessed. The final screening level analysis methodology framework can also be used for future chemicals undergoing risk evaluation under TSCA section 6. Table 1-1. Seven of the First 10 Chemicals Undergoing Risk Evaluation and Associated Pathways for Which Supplemental Screening Level Analysis for Fenceline Communities Will Be Conducted Chemical Air Pathway Water Pathway 1-Bromopropane (1-BP) Yes No Methylene chloride (MC) Yes Yes n-Methyl-2-pyrrolidone (NMP) Yes Yes Carbon tetrachloride (CTC) Yes Yes Trichloroethylene (TCE) Yes Yes Tetrachloroethylene (PCE) Yes Yes 1,4-Dioxane (1,4D) [Yesf [Yesf a EPA is currently pursuing a full supplemental risk evaluation for 1,4-dioxane and the components of the screening level analysis for fenceline communities may be considered for part of that full supplemental risk evaluation. Other components of published risk evaluations including, but not limited to, hazard identification, development of hazard endpoints, and assessment of occupational exposure, ecological exposure, and consumer exposure will not be revisited as part of screening level analyses for fenceline communities. A Page 17 of 204 ------- 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 Public Comment Draft - Do Not Cite of Quote screening level analysis for fenceline communities via the water pathway will not be conducted for 1-BP since analysis conducted during Problem Formulation indicated that exposures via drinking water and surface water are unlikely to cause human or ecological risk. This was based on a combination of 1-BP's physical-chemical and fate properties (relatively high volatility and biodegradability), minimal releases to water or wastewater treatment plants according to Toxics Release Inventory data, and a lack of reported detections in drinking water ( 20b). Lastly, this work does not include proposed methodology for other pathways previously not assessed in published risk evaluations (e.g., disposal, land use, groundwater derived drinking water sources like wells, or fish consumption), aggregate/cumulative exposures, or potential environmental justice concerns to inform future environmental justice analyses that assess racial and economic disparities in exposure and associated risks. However, EPA believes the design of the proposed methodology presented in this work is flexible enough to allow addition of expanded capacities to evaluate all three of these concepts and invites suggestions as part of the charge for the SACC on what such expanded capacities could look like for future risk evaluations. In this report, EPA proposes a screening level methodology for assessing chemical exposures to fenceline communities via the ambient air and water pathways. These methodologies are described in Section 2 and include developing release assessments, exposure assessments, risk calculations, and risk characterizations. EPA then presents three case study chemicals as illustrative examples of applying the screening level methodology. These are presented in Section 3. EPA presents two case study chemicals for the air pathway (1-BP and MC) and two case study chemicals for the water pathway (MC and NMP). While all three case study chemicals are chemicals for which EPA published risk evaluations between 2020 and 2021, the results as presented in this work are not final agency actions and will not be used as presented to support risk management actions or associated rulemaking activities resulting from the published risk evaluations at this time. The purpose of these case study chemicals is to show the application and efficacy of the proposed screening level methodology and not to support risk management actions or rulemaking. Looking Ahead In this sub-section, EPA provides a brief description of how results from the screening level analysis may be used to further inform or support the Agency's risk management actions and associated rulemaking outcomes under TSCA resulting from published risk evaluations for chemicals undergoing risk evaluation. The descriptions are presented as simplified hypothetical examples only to provide insight into the next steps following completion of a screening level analysis. Although these examples describe potential risk management actions/rulemaking outcomes, neither the outcomes described in these examples nor the results from screening level analysis are final agency actions as presented in this work. All proposed risk management actions/rulemaking activities and supporting documentation for such actions, including any screening level analyses conducted, will go through public comment prior to finalization. Setting Up the Example: EPA finalizes the screening level methodology and uses the framework to conduct a screening level analysis for chemical XYZ, which is a chemical undergoing risk evaluation under TSCA. The published risk evaluation for Chemical XYZ includes four conditions of use (COU1, COU2, COU3, and COU4) but as published did not include the ambient air pathway or ambient water pathways in the evaluation. Preliminary risk findings indicate there is unreasonable risk for COU1 (worker exposure) and COU3 (worker and consumer exposure), but not for COU2 or COU4. Risk management actions are considering an existing chemical exposure limit for COU1 and a ban on use of chemical XYZ for COU3. Since no unreasonable risk was identified for COU2 or COU4, there is no risk management action proposed for COU2 or COU4. Page 18 of 204 ------- 126 127 128 129 130 131 132 133 134 135 136 137 138 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 157 158 159 160 161 162 163 164 165 166 167 168 169 170 171 172 Public Comment Draft - Do Not Cite of Quote Actions Taken: Since the published risk evaluation for Chemical XYZ did not include the ambient air or ambient water pathways, EPA conducts a screening level analysis for fenceline communities using the final screening level methodology framework and preliminary risk findings indicate there is additional unreasonable risk to fenceline communities for three of the four COUs. Unreasonable risk for COU1 occurs via the ambient air pathway only (primarily fugitive releases), unreasonable risk for COU2 occurs via the ambient water pathway only with some additional uncertainties requiring consideration, unreasonable risk for COU3 occurs via the air and water pathways based on the screening level analysis results. COU4 still has no unreasonable risk identified. How the Screening Level Analysis Results May Be Used to Further Inform Risk Management Actions: Combining the risk findings from the published risk evaluation and screening level analysis findings the Agency has identified unreasonable risks for three of the four COUs, the Agency now has a statutory obligation to craft risk management rules to address those identified risks. Considering the risks identified for the three COUs, and the information supporting such risk findings, EPA may develop and pursue one or more of the following outcomes: • OUTCOME ONE: No unreasonable risk was identified for COU4 in the published risk evaluation and the additional screening level analysis did not identify any unreasonable risk to fenceline communities for COU4. The Agency expeditiously proposes no restrictions on the chemical being used for COU4 as no unreasonable risk is identified or expected. The published risk evaluation and associated screening level analysis results and documentation demonstrating the findings are placed in the docket and the Agency publishes a proposed rule which will undergo public comment prior to finalization. • OUTCOME TWO: Unreasonable risk was identified for COU3 in the published risk evaluation and the additional screening level analysis for COU3. The Agency considers the additional unreasonable risks found to fenceline communities through the screening level analysis and determines the initial thought to ban use of chemical XYZ for COU3 is further substantiated by these additional risks to fenceline communities. The Agency expeditiously proposes a ban on the chemical from use with COU3 since the proposed prohibition(s) would be expected to address all identified risks. The published risk evaluation and associated screening level analysis results and documentation demonstrating the findings are placed in the docket and the Agency publishes a proposed rule which will undergo public comment prior to finalization. • OUTCOME THREE: Unreasonable risk was identified for COU1 (worker exposure) in the published risk evaluation and the additional screening level analysis for COU1 (fenceline communities primarily as a result of uncontrolled fugitive emissions within a workplace which may enter the ambient air through uncontrolled roof vents, open windows, or similar exit points). The Agency considers the additional unreasonable risks found through the screening level analysis as well as the fugitive nature of those releases and determines the initial thought to propose an existing chemical exposure limit within the workplace to protect the workers from the unreasonable risk may also reduce the amount of fugitive emissions available for escaping into the ambient air. The Agency expeditiously proposes a risk management rule which establishes an existing chemical exposure limit which can be met by utilizing local controls to capture releases and direct them away from the worker. This risk management rule is also expected to reduce fugitive releases to levels below which an unreasonable risk is expected. The published risk evaluation and associated screening level analysis results and documentation demonstrating the findings are placed in the docket and the Agency publishes a proposed rule which will undergo public comment prior to finalization. Page 19 of 204 ------- 173 174 175 176 111 178 179 180 181 182 183 184 185 186 187 188 189 190 191 192 193 194 195 196 197 198 199 200 201 Public Comment Draft - Do Not Cite of Quote • OUTCOME FOUR: As an alternative to outcome three, if the Agency concludes that the unreasonable risks identified for COU1 would be more effectively addressed by another EPA administered Federal law (the Clean Air Act [CAA] in this case), the Agency may comply with the requirements of section 9 of TSCA, which sets forth a process for referring such risk findings to be managed under another EPA administered Federal law. In the example described for outcome three, this may be a more effective outcome to pursue if COU1 tends to involve area sources (non-major sources) where the CAA has expertise with area source regulations which requires specific localized controls on certain emission sources within a source category as best management practices to minimize emissions released to the ambient air. Although such standards are not set up to address worker exposures directly, requirements like total enclosures or high capture and control efficiency requirements can reduce both worker exposures as well as total fugitive emissions released to the ambient air and therefore directly reduce both worker exposures and fenceline community exposures to levels below which unreasonable risk is expected. • OUTCOME FIVE: Unreasonable risk was not identified for COU2 in the published risk evaluation, however, the additional screening level analysis for fenceline communities for COU2 did identify unreasonable risk to fenceline communities. The Agency recognizes the additional screening level analysis has some COU2-specific uncertainties which should be considered prior to proposing a risk management rule. The Agency determines that rather than expeditiously propose and risk management rule, additional analysis beyond the screening level analysis for fenceline communities is warranted to further substantiate the unreasonable risk finding for COU2. The Agency then undertakes additional analysis beyond the screening level analysis for fenceline communities, supplements the published risk evaluation and, depending on the outcome of the additional analysis, either retains the no unreasonable risk determination or revises the determination to unreasonable risk and then proposes a risk management rule appropriate for the final risk determination that will undergo public comment prior to finalization. Page 20 of 204 ------- 202 203 204 205 206 207 208 209 210 211 212 213 214 215 216 217 218 219 220 221 222 223 224 225 226 227 228 229 230 231 232 233 234 Public Comment Draft - Do Not Cite of Quote 2 SCREENING METHODOLOGIES 2.1 Ambient Air Pathway Figure 2-1 provides an overview of EPA's screening level methodology for the ambient air pathway. Where reasonably available, fugitive and stack air release data from the 2019 Toxic Release Inventory (TRI) are used to quantify environmental releases. The 2019 TRI dataset is used for the proposed screening level analysis because it is not limited to criteria pollutants or chemicals listed as Hazardous Air Pollutants like the National Emissions Inventory (NEI) and is a more recent dataset than the latest NEI (2017). While the 2019 TRI dataset is used for the proposed screening level analysis, there are uncertainties associated with the 2019 TRI dataset which may warrant use of other, or additional, datasets for more detailed analyses under TSCA or other statutory programs administered by EPA. These are discussed in the assumptions and uncertainties section for environmental releases (Section 2.4.1) and include not capturing smaller releasing facilities, location coordinates of source specific release points, or source specific stack parameters/plume characteristics. Lastly, although the 2019 TRI dataset is used for the proposed screening level analysis in this work, the proposed methodology can use one or more datasets, like TRI and NEI, or multiple years of one or more datasets, if there is added benefit to the intended outcome of the screening level analysis. AERMOD (EPA's regulatory model for air dispersion modeling) is used to estimate ambient air concentrations and exposures to receptors at various distances from the emission source. Distances of up to 10,000 meters are evaluated to capture potential exposures and associated risks to fenceline communities. A distance of 10,000 meters is used for this screening level analysis methodology to capture receptors nearer to releasing facilities than may otherwise be evaluated under other EPA administered laws. Additionally, professional knowledge and experience regarding exposures associated with the ambient air pathway find risks frequently occur out to approximately 1,000 meters from a releasing facility and quickly decrease farther out. Although 10,000 meters is an order of magnitude farther out than where risks are expected to occur, 10,000 meters provides an opportunity to capture other factors related to potential exposure and associated potential risks via the ambient air pathway (like multiple facilities impacting a single receptor) providing flexibility for screening level analyses for future risk evaluations. Although 10,000 meters is used for the outer distance in the screening level analysis, the methodology is not limited to 10,000 meters. If risks are identified out to 10,000 meters, then additional analysis using the screening level methodology can be extended to farther distances for purposes of identifying where risks may fall below levels of concern. Page 21 of 204 ------- 235 236 237 238 239 240 241 242 243 244 245 246 247 248 249 250 251 252 253 Public Comment Draft - Do Not Cite of Quote Air Pathway Overv iew 1 Stack and fugitive aii- releases 1 Ambient air concentrations from modeling Inhalation • Fenceline Community Distance from Source Distance from Source Figure 2-1. Overview of EPA's Screening Level Ambient Air Pathway Methodology 2.1.1 Environmental Air Releases This section describes the general methodology (Figure 2-2) that was used to develop estimates of air emissions from facilities as part of EPA's screening level ambient air pathway methodology. The results of applying this methodology to 1-BP and MC are presented in Section 3 (Case Study Results). Figure 2-2. General Methodology for Estimating Air Emissions 2.1.1.1 Step 1: Obtain 2019 TRI Data The first step in the methodology for estimating air emissions was to obtain 2019 TRI data for the chemical from EPA's Basic Plus Data Files (U.S. EPA. 2021). EPA included both TRI reporting Form R and TRI reporting Form A submissions in the fenceline analysis. Facilities may submit a Form A instead of a Form R if the amount of chemical manufactured, processed, or otherwise used does not exceed 1,000,000 pounds per year (lb/year) and the total annual reportable releases do not exceed 500 lb/year. Facilities do not need to report release quantities or uses/sub-uses on Form A. For Form A, the methodology to estimate emissions differs slightly from what is described below. Specifically, in Step 2, EPA does not have use/sub-use information for Form A submissions, so instead relies on North American Industry Classification System (NAICS) codes and facility information from internet searches Page 22 of 204 ------- 254 255 256 257 258 259 260 261 262 263 264 265 266 267 268 269 270 271 272 273 274 275 276 277 278 279 280 281 282 283 284 285 286 287 288 289 290 291 292 293 294 295 296 297 298 299 300 Public Comment Draft - Do Not Cite of Quote to map these facilities to an OES. Additionally, for Step 5, EPA used the Form A threshold of 500 lb/year for total releases for sites that reported using a Form A. These differences are highlighted in the sections below. 2.1.1.2 Step 2: Map 2019 TRI to Occupational Exposure Scenarios In the next step of fenceline analysis development, EPA mapped the chemical's 2019 TRI data to the OES that were in the published risk evaluation for the chemical. EPA used the following procedure to map 2019 TRI data to OES: 1. Compile TRI uses/sub-uses: EPA first compiled all the reported TRI uses/sub-uses for each facility into one column. 2. Map TRI uses/sub-uses to Chemical Data Reporting fCDR) IFC codes: EPA then mapped the TRI uses/sub-uses for each facility to one or more 2016 CDR Industrial Function Category (IFC) codes using the TRI-to-CDR Use Mapping crosswalk (see Appendix C). 3. Map OES to CDR IFC codes: EPA then mapped each Condition of Use (COU)/OES combination from the published risk evaluation to a 2016 CDR IFC code and description. The basis for this mapping was generally the COU category and subcategory from the published risk evaluation. 4. Map TRI facilities to an OES: Using the CDR IFC codes from Step 2 and the COU-CDR Mapping from Step 3, EPA mapped each TRI facility to an OES. EPA's rationale for the OES determination is generally described below. o In some cases, the facility mapped to only one OES and the mapping appeared to be correct given the facility name and NAICS code. For these, the OES as mapped from Steps 2 and 3 was used without adjustment. o In many cases, the facility mapped to multiple OES, and EPA decided which was the primary OES. To make this determination, EPA considered • Industry and NAICS codes; • Internet research of the types of products made at the facility; • Which OES was most likely to result in releases (e.g., for a facility that reported both importation and formulation, EPA assigned the formulation COU because, in such cases, importation itself is likely to have lower releases; and • Grouping of like OES (e.g., for facilities that reported the sub-use of cleaner or degreaser, EPA may assign the facility a grouped OES that covers both cleaning and degreasing because the specific cleaning/degreasing operation cannot be determined from the TRI data). o In some cases, EPA determined that the OES mapping from the TRI use/sub-use - CDR IFC code was incorrect. This incorrect mapping is a result of limitations of the TRI-to- CDR Use Mapping crosswalk. For example, the crosswalk maps the TRI use/sub-use of "Otherwise Use as Manufacturing Aid (Other)" to only CDR IFC codes U013 (closed- system functional fluids) and U023 (plating agents and surface treating agents); however, this TRI use/sub-use may encompass multiple other uses that are not captured in these CDR IFC codes. In these cases, EPA reviewed the reported NAICS codes and researched the facility to determine the likely OES. o Additionally, EPA reviewed 2016 CDR ( 16b) for sites that reported manufacturing (including importing) of the chemical. If the sites that reported to 2016 CDR also reported in 2019 TRI, EPA assigned the OES according to 2016 CDR. 5. Form A's: For Form A submissions, there were no reported TRI uses/sub-uses. To determine the COU for these facilities, EPA used 2016 CDR as described above, the NAICS codes, and internet searches to determine the type of products and operations at the facility. Page 23 of 204 ------- 301 302 303 304 305 306 307 308 309 310 311 312 313 314 315 316 317 318 319 320 321 322 323 324 325 326 327 328 329 330 331 332 333 334 335 336 337 338 339 340 341 342 343 344 345 346 Public Comment Draft - Do Not Cite of Quote The specific rationale for the OES mapping for each facility is broadly described in the supplemental fenceline analysis spreadsheets, SFFLA Environmental Releases to Ambient Air for 1-BP and SFFLA Environmental Releases to Ambient Air for MC (See Appendix B). 2.1.1.3 Step 3: Estimate Number of Release Days for Each OES TRI air emissions data are provided on an annual basis, in pounds of chemical released per year via fugitive or stack emissions. However, for the exposure modeling described in Section 2.1.2, releases are needed on a daily basis. To estimate daily releases, EPA needs the number of release days for each facility. Because the number of release days is not reported in TRI, EPA used the general approach from the number of operating days in the published risk evaluations for the first 10 chemicals that were based on the following logic: • Manufacture of solvents: 350 days/year (assumes the plant runs 7 days/week and 50 weeks/year, with two weeks down for turnaround, and assumes that the plant is always producing the chemical). • Processing as reactant: 350 days/year (assumes chemical plant setting like manufacture of solvents and that the chemical of interest is used consistently throughout the year). • Other Chemical Plant Scenarios: 300 days/year (based on a European Solvents Industry Group Specific Environmental Release Category factsheet that uses a default of 300 days/year for release frequency for the chemical industry, since it is unreasonable to assume the chemical of interest is always in use at the facility) (European Solvents Industry Group. 2012). • All Other Scenarios: 250 days/year or the value cited in any relevant generic scenarios (GS) or emission scenario documents (ESD) (e.g., a risk evaluation may use 260 days/year for degreasing operations per the Vapor Degreasing ESD (Organization for Economic and Development. 2017)). This approach assumes the number of release days for a facility is equal to the estimated number of operating days for its assigned OES. 2.1.1.4 Step 4: Estimate Air Emissions for OES with No 2019 TRI Data 2019 TRI data were not available for every OES for 1-BP or MC. The hierarchy that was followed to estimate air emissions for facilities with no 2019 TRI data is presented in the decision tree diagram in Figure 2-3. As shown in the hierarchy, the first alternative approach considered was using TRI data from prior reporting years that map to the OES (only prior reporting years 2016 through 2018 were considered for this Version 1.0 screening-level approach). If no past years' TRI data were available, the next approach considered was modeling, including using any modeling already completed in the published risk evaluation or performing modeling with existing models. No new models were developed or researched for this screening-level fenceline analysis. After modeling, existing literature sources used in the published risk evaluation were considered. For example, the 1-BP fenceline analysis uses a Trinity Consultants report containing air emissions data for dry cleaning and spray adhesives, which is referenced in the systematic review supplemental file for releases and occupational exposures (Trinity Con sul ta ). If the published risk evaluation did not contain any literature sources with air release data, the use of 2019 TRI data for a different OES was considered as surrogate for the OES being assessed. For example, the MC fenceline analysis uses 2019 TRI data for Miscellaneous Non-aerosol Industrial and Commercial Uses as surrogate for the Adhesives and Sealants OES because these OES are expected to be similar and potentially overlap (see Section 3.2.3). Where none of the above approaches were sufficient to develop an air release assessment for an OES, additional approaches or refinements were Page 24 of 204 ------- 347 348 349 350 351 352 353 354 355 356 357 358 359 360 361 362 363 364 365 366 367 368 369 370 371 Public Comment Draft - Do Not Cite of Quote considered, such as the use of Generic Scenarios and Emission Scenario Documents. The specific approaches used to estimate releases for each chemical's OES are discussed in the chemical-specific case studies in Section 3. Figure 2-3. Decision Tree for Estimating Air Releases 2.1.1.5 Step 5: Prepare Air Emission Summary for Ambient Air Exposure Modeling The final step was to prepare a summary of the fugitive and stack releases. See the supplemental files S F_F L AJOi vironmental Releases to Ambient Air for 1-BP and S F_F LAI'Jivironmental Releases to Ambient Air for MC (See Appendix B) for the summaries developed for 1-BP and MC. The content of the summaries was developed to connect with the next stage of the analysis, which was the exposure modeling described in Section 2.1.2. The parameters included were selected with this next step in mind. Key parameters and their description and purpose for the exposure modeling are provided below and summarized in Table 2-1. For each OES, EPA summarized air releases in a table containing the data elements shown in Table 2-1, with one row per site. EPA summarized site information, including site identity, city, state, zip code, TRI facility ID, and Facility Registry Service (FRS) ID because the exposure modeling is site and location specific. The summary includes the NAICS code and description and comparison to the assigned OES for the site. Next, the summary includes annual releases to stack and fugitive air. These annual releases are from 2019 TRI or from the alternative approaches discussed in Section 2.1.1.4. For these alternative approaches, where sufficient data (modeled or otherwise) were available, EPA presented the 50th and 95th percentile air emissions. Additionally, where sites reported to 2019 TRI with a Form A, EPA used the Form A threshold for total releases of 500 lb/year. EPA used the entire 500 lb/year for both the fugitive and stack air release estimates; however, since this threshold is for total Page 25 of 204 ------- 372 373 374 375 376 377 378 379 380 381 382 383 384 385 386 387 388 389 390 391 392 Public Comment Draft - Do Not Cite of Quote site releases, these 500 lb/year are attributed either to fugitive air or stack air for this analysis, not both (since that would double count the releases and exceed the total release threshold for Form A). As discussed in Section 2.1.1.3, the exposure modeling requires daily releases. Therefore, the summary for each site includes the estimated number of release days according to the methodology in Section 2.1.1.3 and the calculated daily fugitive and stack air releases. These daily releases were calculated by dividing the annual releases by the number of release days. To accompany the summary table for each OES, EPA also provided any reasonably available information on the release duration and pattern, which are needed for the exposure modeling. Release duration is the expected amount of time per day during which the air releases may occur. Release pattern is the temporal variation of the air release, such as over consecutive days throughout the year, over cycles that occur intermittently throughout the year, or in a puff/instantaneous release that occurs over a short duration. The TRI dataset does not include release pattern or duration, so EPA used information from models or literature. For example, EPA presented the mean release duration from the Open-Top Vapor Degreasing Near-Field/Far-Field Inhalation Exposure Model for the cleaning/degreasing OES for both 1 -BP (U.S. EPA. 2020b) and MC ( 020c). For release pattern, EPA provided the number of release days with the associated basis as described in Step 3. However, for most OES, no information was found on release duration and pattern and EPA listed these as "unknown." Page 26 of 204 ------- Public Comment Draft - Do Not Cite of Quote 393 Table 2-1. Summary of Air Release Data Elements Data Element Data Element Description Site Identity Name of the facility where release occurred City Name of the city where the facility is located State State abbreviation for the state where the facility is located Zip Zip code for the location of the facility TRIFID TRI facility identification number NAICS/SIC Primary NAICS code for the facility NAICS/SIC Description Description of the industry associated with the reported primary NAICS code Annual Fugitive Air Release (kg/site-year) Reported or estimated annual fugitive air release from the facility Annual Stack Air Release (kg/site-year) Reported or estimated annual stack air release from the facility Annual Release Days (day/year) Estimated number of days per year the fugitive and/or stack air release occurs. Daily Fugitive Air Release (kg/site-day) Estimated average daily fugitive air release from the facility Daily Stack Air Release (kg/site-day) Estimated average daily stack air release from the facility FRS Facility Registry Service identification number for the facility Sources & Notes Identifies source of air release estimates and other key notes related to the estimates 394 2.1.2 Ambient Air Concentrations and Exposures 395 This section describes the tiered methodologies utilized to estimate ambient air concentrations and 396 exposures for members of the general population that are in proximity (between 5 to 10,000 meters) to 397 emissions sources emitting the chemicals being evaluated to the ambient air. All exposures were 398 assessed for the inhalation route only. These methodologies are briefly described in Figure 2-4. 399 Page 27 of 204 ------- 400 401 402 403 404 405 406 407 408 409 410 411 412 413 414 415 416 417 418 419 420 421 422 423 424 425 426 Public Comment Draft - Do Not Cite of Quote Figure 2-4. Brief Description of Methodologies Used to Estimate Ambient Air Concentrations and Exposures 2.1.2.1 Ambient Air Pre-screening Methodology The pre-screening analysis methodology was developed to identify, at a high level, if there are inhalation exposures to select receptors from a chemical undergoing risk evaluation which indicates a potential risk. Findings from the pre-screening analysis are intended to inform the need for a full- screening level analysis. If findings from the pre-screening analysis suggest there is any indication of risk (acute non-cancer, chronic non-cancer, or cancer) for a given chemical, EPA conducts a full- screening level analysis of exposures and associated risks for that chemical. If findings from the pre- screening analysis suggest there is no indication of risk for a given chemical, EPA does not expect to identify risks from a full-screening level analysis and therefore does not conduct further analysis for that chemical. Model The pre-screening methodology utilizes EPA's Integrated Indoor/Outdoor Air Calculator (IIOAC) model4 to estimate high-end and central tendency (mean) exposures to select receptors at three pre- defined distances from a facility releasing a chemical to the ambient air (100, 100 to 1,000, and 1,000 meters). IIOAC is an Excel-based tool that estimates indoor and outdoor air concentrations using pre-run results from a suite of dispersion scenarios run in a variety of meteorological and land-use settings within EPA's American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD). As such, IIOAC is limited by the parameterizations utilized for the pre-run scenarios within AERMOD (meteorologic data, stack heights, distances, receptors, etc.) and any additional or new parameterization would require revisions to the model itself. Readers can learn more about the IIOAC model, equations within the model, detailed input and output parameters, pre-defined scenarios, default values used, and supporting documentation by reviewing the IIOAC users guide (U.S. EPA 2019c). 4 IIOAC page: https://www.epa.gov/tsca-screening-tools/iioac-integrated-indoor-outdoor-air-calculator. Page 28 of 204 ------- 427 428 429 430 431 432 433 434 435 436 437 438 439 440 441 442 443 444 445 446 447 448 449 450 451 452 Public Comment Draft - Do Not Cite of Quote Releases EPA modeled exposures from two categorical release values for each chemical undergoing risk evaluation under TSCA section (6). These values were extracted from 2019 TRI5 data as follows: 1. The maximum individual facility release value for the chemical of concern among all facilities reporting to TRI. 2. The average (mean) release value for the chemical of concern across all facilities reporting to TRI. Exposure Scenarios EPA developed and evaluated a series of exposure scenarios for each categorical release value (max and mean) designed to capture a variety of release types, topography, meteorological conditions, and release scenarios as presented in Figure 2-5. Figure 2-5 includes a total of 16 different exposure scenarios, each of which is applied to both the maximum and mean release data resulting in a total of 32 exposure scenarios modeled for each chemical. Release Type Topography Meteorological Data Release Scenario 365 days, 24/7 — South Coastal 260 days, 8/5 Urban — Stack 365 days, 24/7 — West North Central 260 days, 8/5 365 days, 24/7 South Coastal Rural —1 260 days, 8/5 365 days, 24/7 — West North Central 260 days, 8/5 365 days, 24/7 South Coastal Urban 260 days, 8/5 Fugitive 365 days, 24/7 West North Central 260 days, 8/5 365 days, 24/7 Rural 260 days, 8/5 West North Central 365 days, 24/7 260 days, 8/5 Figure 2-5. Pre-screen Exposure Scenarios Modeled for Max and Mean Release Using IIOAC Model EPA modeled pre-screening exposure scenarios for two source types: stack (point source) and fugitive (area source) releases. These source types have different plume and dispersion characteristics accounted for differently within the IIOAC model. The topography represents an urban or rural population density and certain boundary layer effects (like heat islands in an urban setting) that can affect turbulence and resulting concentration estimates at certain times of the day. 5 TRI page: https://www.epa.gov/toxics-releasE-inventory-tri-program. Page 29 of 204 ------- 453 454 455 456 457 458 459 460 461 462 463 464 465 466 467 468 469 470 471 472 473 474 475 476 477 478 479 480 481 482 483 484 485 486 487 488 489 490 491 492 493 494 495 496 497 498 499 500 Public Comment Draft - Do Not Cite of Quote IIOAC includes 14 pre-defined climate regions (each with a surface station and upper-air station). Since release data used for the pre-screening analysis was not facility location specific, EPA selected 2 of the 14 climate regions to represent a central tendency (West North Central) and high-end (South [Coastal]) climate region based on a sensitivity analysis of the average concentration and deposition predictions (further described in Appendix D). The meteorological stations associated with these two climate regions represent meteorological data sets that tended to provide high-end and central tendency concentration estimates relative to the other stations within IIOAC. Use of these two stations, therefore, provides high end and central tendency exposure concentrations utilized for risk calculation purposes to identify potential risks. The meteorological data within the IIOAC model are from years 2011 to 2015 as that is the meteorological data utilized in the suite of pre-run exposure scenarios during development of the IIOAC model (see IIOAC users guide (U.S. EPA. 2019c)). While this is older meteorological data, sensitivity analyses related to different years of meteorological data found that although the data does vary, the variation is minimal across years so the impacts to the model outcomes remain relatively unaffected. The release scenarios consider two potential facility operating conditions. The first represents a facility that operates year-round (365 days per year), 24/7. The second represents a facility that operates generally on a Monday through Friday schedule (260 days per year) for 8 hours per day, 5 days per week. The difference between the two release scenarios is the resulting total daily release, frequency of release, and duration of release. These conditions result in a different exposure pattern that is captured by modeling both release scenarios. As an example, if a facility has a total annual release of 10,000 lb/year, then the daily release from a facility operating 365 days/year, 7 days per week, and 24 hours per day would be 27.4 lb per day for every day of the year over a 24-hour period. If the facility operates 260 days per year, 5 days per week, for 8 hours per day, the daily release would be 38.5 lb per day, but only Monday through Friday and over an 8-hour period. Exposure Results and Risks Modeled exposure concentration results from the pre-screening modeling effort were reviewed and summarized for each scenario modeled. To ensure potential risks were not missed, EPA maintained a conservative approach for the pre-screening analysis by selecting the highest estimated exposure concentrations from the 32 scenarios modeled for each chemical. These values were used for the risk calculations to estimate the Margin of Exposure (MOE) and excess cancer risk for comparison to the equivalent human health endpoints and benchmark values within the respective published final risk evaluations. The calculated risks were then compared to the benchmark values for the respective chemical to identify if there was an indication of potential added risk for either or both acute and chronic non-cancer effects (calculated MOE below the benchmark MOE for the specific chemical) or if there was an indication of potential excess risk for cancer (calculated values greater than the benchmark of 1 x 106 for general population). Chemical specific details and associated results of the pre-screening effort are provided in Appendix D. 2.1.2.2 Ambient Air Full-Screening Methodology The full-screening methodology was developed to allow EPA to conduct a full-screening level analysis of releases, exposures, and associated risks to fenceline communities for chemicals undergoing risk evaluation when the pre-screening analysis identifies potential exposure and associated risk(s) to the select receptors. The full-screening methodology can be performed independent of the pre-screening analysis, provides a more thorough analysis, and allows EPA to fully characterize identified risks for chemicals undergoing risk evaluation. Page 30 of 204 ------- 501 502 503 504 505 506 507 508 509 510 511 512 513 514 515 516 517 518 519 520 521 522 523 524 525 526 527 528 529 530 531 532 533 534 535 536 537 538 539 540 541 542 543 544 545 546 Public Comment Draft - Do Not Cite of Quote Model The full-screening methodology utilizes AERMOD6 to estimate exposures to fenceline communities at user defined distances from a facility releasing a chemical undergoing risk evaluation. AERMOD is a steady-state Gaussian plume dispersion model that incorporates air dispersion based on planetary boundary layer turbulence structure and scaling concepts, including treatment of both surface and elevated sources and both simple and complex terrain. AERMOD can incorporate a variety of emission source characteristics, chemical deposition properties, complex terrain, and site-specific hourly meteorology to estimate air concentrations and deposition amounts at user-specified receptor distances and at a variety of averaging times. Readers can learn more about AERMOD, equations within the model, detailed input and output parameters, and supporting documentation by reviewing the AERMOD users guide (U.S. EPA. 2018). Releases EPA modeled exposures using the release data developed as described in Section 2.1.1 and summarized below. Release data was provided (and modeled) on a facility-by-facility basis: 1. Facility specific chemical releases (fugitive and stack releases) as reported to the 2019 TRI, where available. 2. Alternative release estimates as described in the decision tree for estimating air releases (Figure 2-3), where facility specific 2019 TRI data were not available. Alternative release estimates may include facility specific releases reported in previous TRI reporting years (2016 to 2018) or modeled release estimates using existing EPA models or other surrogate data. Exposure Scenarios EPA modeled exposure concentrations on a facility-by-facility basis, building out a series of facility specific exposure scenarios based on the release data provided as described in Section 2.1.1. EPA modeled exposure concentrations at 8 finite distances from a releasing facility (5, 10, 30, 60, 100, 2,500, 5,000 and 10,000 meters) and one area distance from a releasing facility (100-1,000 meters) in a series of concentric rings around the facility. Since these are radial distances from a releasing facility, the resulting diameter of distances evaluated is two times the distances evaluated. For TRI reporting facilities, EPA used facility specific information extracted from TRI or provided as part of the release assessment to inform the exposure scenario(s) for a given facility including, but not limited to: facility names, locations, identifier codes, annual air releases (stratified by fugitive and stack), and descriptions of intraday and inter-day air-release patterns. Where surrogate data or estimated releases were provided, EPA followed a similar scenario development scheme as used for the pre-screen work described in Section 2.1.2.1. One difference, however, is EPA modeled a single facility specific operating condition, based on assumptions used in the release assessment, to estimate exposures in the full-screening level analysis rather than the two operating conditions presented in Section 2.1.2.1 (24/7 and 8/5). Facility coordinates, in the form of latitude/longitude coordinates, were used to match the facility to the closest available meteorological station. For facilities reporting to the 2019 TRI, latitude/longitude coordinates were provided as part of the release assessment as extracted from TRI. For a limited number of facilities where earlier TRI reporting years were used to estimate releases, the TRI system7 was queried to obtain latitude/longitude coordinates for the surrogate data. Where data were not in the TRI, but EPA estimated releases from a surrogate facility with a city location, the latitude/longitude coordinates were set near the center of the city in which the facility was located. Where data were not in 6 See AERMOD for further information. 7 Toxics Release Inventory search page: https://www.epa.gov/enviro/tri-search. Page 31 of 204 ------- 547 548 549 550 551 552 553 554 555 556 557 558 559 560 561 562 563 564 565 566 567 568 569 570 571 572 573 574 575 576 577 578 579 580 581 582 583 584 585 586 587 588 Public Comment Draft - Do Not Cite of Quote TRI or based on a city location, EPA was unable to identify and apply latitude/longitude coordinates and instead used the meteorological data applied for the pre-screen work (West North Central and South (Coastal) regional meteorologic stations from IIOAC) and described in Section 2.1.2.1. Meteorological data for TRI reporting facilities was obtained using the same AERMOD-ready meteorological data that EPA's Risk and Technology Review (RTR) program uses for multimedia, multipathway-risk modeling in review of National Emission Standards for Hazardous Air Pollutants (NESHAP).8 These data cover 824 hourly stations in the 50 states, District of Columbia, and Puerto Rico. The data are for year 2016. While this is older meteorologic data, sensitivity analyses related to different years of meteorological data found that although the data does vary, the variation is minimal across years so the impacts to the model outcomes remain relatively unaffected. All meteorologic data was processed with version 16216 of AERMOD's meteorological preprocessor (AERMET).9 10 Following EPA guidance,11 all processing utilized sub-hourly wind measurements (to calculate hourly-averaged wind speed and wind direction; see Section 8.4.2 of that guidance). The processing for the 2016 data also used the "ADJU*" option for mitigating modeling issues during light- wind, stable conditions. All processing also used automatic substitutions for small gaps in data for cloud cover and temperature. Meteorological data for EPA estimated releases (where TRI or city data were not available) were modeled with the two meteorological stations utilized in the pre-screen methodology (Sioux Falls, SD, and Lake Charles, LA). These two meteorological stations represent meteorological data sets that tended to provide high-end and central tendency concentration estimates relative to the other stations within IIO AC based on a sensitivity analysis of the average concentration and deposition predictions (further described in Appendix D) conducted in support of IIO AC development. Use of these two stations, therefore, provides high end and central tendency exposure concentrations utilized for risk calculation purposes to identify potential risks. The "ADJ U*" option was not used for the 2011 to 2015 data, which could lead to model overpredictions of ambient concentrations during those particular conditions. Urban/rural designations of the area around a facility are relevant when considering possible boundary layer effects on concentrations. Air emissions taking place in an urbanized area are subject to the effects of urban heat islands, particularly at night. When sources are set as urban in AERMOD, the model will modify the boundary layer to enhance nighttime turbulence, often leading to higher nighttime air concentrations. AERMOD uses urban-area population as a proxy for the intensity of this effect. EPA utilized a population density analysis to identify facilities warranting an urban designation for the AERMOD runs. Specifically, EPA considered a facility to be in an urban area if it had a population density greater than 750 people per square kilometer (km2) within a 3-km radius of the facility (see Section 7.2.1.1 of the guidance referenced in footnote 11) and set the relevant inputs to urban within AERMOD. However, as noted in the EPA guidance referenced in footnote 11, the population-density analysis can be misleading for facilities in an industrial park within a city, facilities that border a water body or some other unpopulated area, etc. Recognizing this limitation can result in situations where the 8 RTR page: https://www.epa.gov/statlonare-sonrces-air-poHntloti/risk-and-techiiology-review-national-eniissions-standards- hazardous. 9 See \! I' MET for further information. 10 Note: The RTR program's inhalation-risk modeling now uses data mostly from year 2019 and a more updated version of AERMET (see the HEM4 User's Guide). However, EPA does not anticipate the modeling used here to be sensitive to these differences. 11 See ideline on Air Quality Models. Page 32 of 204 ------- 589 590 591 592 593 594 595 596 597 598 599 600 601 602 603 604 605 606 607 608 609 610 611 612 613 614 615 616 617 618 619 620 621 622 623 624 625 626 627 628 629 630 Public Comment Draft - Do Not Cite of Quote facility site likely is influenced by urban heat island effects but the population density within 3 km is below 750 people per km2, EPA conducted a brief visual examination of the region around the facility, using aerial imagery, to identify any facility within or on the edge of an urban domain but where a substantial portion of the 3-km radius around the facility had low population counts. Facilities meeting these visual conditions were also given an urban designation for modeling purposes. For facilities set for urban modeling, AERMOD requires an estimate of the urban population count. EPA estimated the urban-area population by identifying a proxy for the area of urbanization. The urban-area proxy was the largest radius around the facility (out to a limit of 15 km) having a population density greater than 750 people per km2 and identified the population within that radius and applied it for modeling purposes. EPA used U.S. Census data at the level of block groups for these analyses (with geographies from the 2019 census TIGER/Line shapefiles12 and population counts from the American Community Survey13 2015 to 2019 5-year estimates-detailed tables (table B01003)). Where TRI or city data were not available for a facility requiring modeling, there was no way for EPA to determine an appropriate urban or rural designation. Instead, EPA modeled each such facility once as urban and once as not urban.14 There is no recommended default urban population for AERMOD modeling, so for these facilities EPA assumed an urban population of 1 million people, which is consistent with the estimated populations used with IIOAC. Although slightly higher, the assumed urban population is close to the average of all the urban populations used for the TRI reporting facilities (which was 847,906 people). Source-specific physical characteristics like actual release location, stack height, exit gas temperature, etc. are generally not reported as part of the TRI dataset but can affect the plume characteristics and associated dispersion of the plume. For the release location, EPA used a local-coordinate system. EPA centered a facility's emissions on one location which was assigned the local coordinate of (0,0) and concentrations were estimated at modeled distances in concentric rings from that one location. EPA used physical stack parameters and plume characteristics consistent with those used in IIO AC, including, but not limited to: stack emissions released from a point source at 10 meters above ground from a 2-m inside diameter stack, with an exit gas temperature of 300 °Kelvin and an exit gas velocity of 5 m per second (see Table 6 of the IIOAC User Guide). EPA acknowledges these stack parameters represent conservative plume characteristics which resemble a slow-moving, low-to-the-ground plume with limited dispersion but believe are appropriate for screening level purposes. Fugitive emissions were modeled using a release height of 3.05 m above ground from a square area source 10 m on a side (see Table 7 of the IIOAC User Guide). These parameters are also conservative in that they represent fugitive sources relatively low to the ground with no buoyancy or momentum to the emissions. Additionally, because we modeled fugitive sources centered at (0,0) and 10 m on a side {i.e., extending out 5 m to the north, south, east, and west from the facility center point, and extending out about 7.1 m to the northeast, southeast, southwest, and northwest), all of the modeled exposure concentrations at the 5-m ring distance will be either directly on the edge of the fugitive source or "on 12 2019 census TIGER/Line shapefiles page: https://www.census.gov/geographies/mapping~files/timE~~~series/geo/tiger~ 1 i nE-fi te. 20.1.9. htm 1. 13 American Community Survey page: https://www.censiis.gov/programs~survevs/acs. 14 While this may be viewed as a potential double counting of these releases, EPA only utilized the highest estimated releases from a single exposure scenario from the suite of exposure scenarios modeled for surrogate/estimated facility releases as exposure estimates and for associated risk calculations. Page 33 of 204 ------- 631 632 633 634 635 636 637 638 639 640 641 642 643 644 645 646 647 648 649 650 651 652 653 654 655 656 Public Comment Draft - Do Not Cite of Quote top of' the fugitive source. All other modeled concentrations for fugitive sources will be well outside the fugitive source. Temporal emission patterns are another factor that can affect the overall modeled concentration estimates. The release assessments for this work included information on temporal emission patterns— release duration (across the hours of a day, or intraday) and release pattern (across the days of a year, or inter-day)—stratified by OES. When release duration was "unknown," EPA assumed releases occurred each hour of the day. When release duration or release pattern was described as a distribution, EPA used the stated mean of that distribution, and when they were fractional values EPA rounded to the nearest integer. EPA's assumptions for intraday release duration are provided in Table 2-2. The hours shown conform to AERMOD's notation scheme of using hours 1 to 24, where hour 1 is the hour ending at 1 a.m. and hour 24 is the final hour of the same day ending at midnight. Table 2-2. Assumptions for Intraday Emission-Release Duration Hours per Day of Emissions Assumed Hours of the Day Emitting (Inclusive) Unknown All (hours 1-24) 1 Hour 13 (hour ending at 1 p.m.; i.e., 12 to 1 p.m.) 3 Hours 13-15 (hour ending at 1 p.m. through hour ending at 3 p.m.; i.e., 12 to 3 p.m.) 4 Hours 13-16 (hour ending at 1 p.m. through hour ending at 4 p.m.; i.e., 12 to 4 p.m.) 8 Hours 9-16 (hour ending at 9 a.m. through hour ending at 4 p.m.; i.e., 8 a.m.to 4 p.m.) 12 Hours 9-20 (hour ending at 9 a.m. through hour ending at 8 p.m.; i.e., 8 a.m.to 8 p.m.) 14 Hours 7-20 (hour ending at 7 a.m. through hour ending at 8 p.m.; i.e., 6 a.m.to 8 p.m.) EPA's assumptions for inter-day release pattern are provided in Table 2-3. EPA started with the assumption that emissions took place every day of the year. Next, EPA turned emissions off for certain days of the year as needed to achieve the desired number of emission days: assumptions such as no emissions on Saturday and Sunday, no emissions on the days around New Year's Day, no emissions at regular patterns like the first Monday of every month, and so on. EPA developed these patterns for the TRI reporting facilities, and then adjusted the patterns as needed for facilities where no TRI or city data were available (years 2011 to 2015), since the number of Mondays, Saturdays, etc., in the year varies year-by-year. Page 34 of 204 ------- Public Comment Draft - Do Not Cite of Quote 1 Table 2-3. Assumptions for Inter-day Emission-Release Pattern Provided Language for Release Pattern Implemented Release Pattern: Days When Emissions Arc on (Format of Month Number/Day Number) Real Facilities (Year 2016) Generic Facilities (Years 2011-2015) Release pattern: unknown; 350 davs/vr is based on the assumption of operations over 7 days/wk and 50 wk/yr. All days except 1/1-1/5 and 12/21-12/31 Not applicable Release pattern: unknown; 300 davs/vr is based on the assumption of operations over 7 days/wk over some portion of the year since the chemical may not be processed throughout the entire year. All days except 12/26-12/31 and the first 5 days of each month Not applicable Release pattern: unknown; The Brake Servicing Model estimates 260 to 364 days/yr with a mean of 291 days/yr; Use of aerosol degreasers is expected to be intermittent throughout the year; Aerosol degreasing is expected to be intermittent throughout the day, week, and year. Not applicable All Mon.-Sat. except 1/1-1/5, 12/21- 12/31, the first Mon. of Feb.-Sep. (and Oct. but only for 2012 and 2014) Release pattern: unknown; The Dry Cleaning Model calculates a mean of 287 days/yr using a triangular distribution of low-end 250 days/yr (5 day/wk and 50 wk/yr), high-end 312 days/yr (6 day/wk and 52 wk/yr), and mode 300 days/yr (6 day/wk and 50 wk/yr) All Mon.-Sat. except 1/1-1/5, 12/21-12/31, the first Mon. of Feb.-Dec., and the first Tue. of Feb.-Mar. All Mon.-Sat. except 1/1-1/5, 12/21- 12/31, the first Mon. of Feb.-Dec., and the first Tue. of Feb. (and Mar. but only for 2012 and 2014) Release pattern: unknown; The Spot Cleaning Model calculates a mean of 287 days/yr using a triangular distribution of low-end 250 days/yr (5 day/wk and 50 wk/yr), high-end 312 days/yr (6 day/wk and 52 wk/yr), and mode 300 days/yr (6 day/wk and 50 wk/yr); Spot cleaning is expected to be intermittent throughout the day, week, and year Not applicable All Mon.-Sat. except 1/1-1/5, 12/21- 12/31, the first Mon. of Feb.-Dec., and the first Tue. of Feb. (and Mar. but only for 2012 and 2014) Release pattern: unknown; 260 davs/vr is from the Vapor Degreasing ESD. which is based on 2011 NEI data, and is the median for OTVDs All Mon.-Fri. except 1/1 Not applicable Release pattern: unknown; 260 davs/vr based on 5 davs/wk and 52 wk/vr All Mon.-Fri. except 1/1 Not applicable Release pattern: unknown; 250 davs/vr is based on the assumption of operations over 5 days/wk and 50 wk/yr. All Mon.-Fri. except 1/1-1/5 and 12/21-12/31 Not applicable Note: Some of the "Provided Language for Release Pattern" is specific to an OES. yr = year; wk = week; Mon. = Monday; Sat. = Saturday; Feb. = February; Sep. = September; Oct. = October; Dec. = December; Tue. = Tuesday; Mar. = March. 2 Page 35 of 204 ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Public Comment Draft - Do Not Cite of Quote The release assessments included emission rates for each facility in kilograms per site per year, for fugitive and stack sources as appropriate. In most cases, one emission rate was included per source type per facility (i.e., one rate for fugitive emissions, one rate for stack emissions), though in some cases, where releases were estimated, releases were provided as a range of values. The ranges of values typically were a central tendency and a 95th percentile or higher-end value. In some cases, both a mean and a 50th percentile value was provided (mean being an arithmetic mean value and the 50th percentile being a median value). Typically, the mean and 50th percentile releases were similar, so EPA used the 50th-percentile value and excluded the mean value for modeling purposes. Central tendency and high- end emission scenarios were modeled separately. Some TRI reporting facilities had emissions lower than the required reporting thresholds for TRI and reported emissions using TRI's "Form A." These forms have a reporting threshold of 500 lb/year of total facility releases and were included in the release assessments as the release rate for both fugitive and stack sources. Since fugitive and stack releases are modeled differently within AERMOD (point source vs area source), and there was no way to parse out the total release across fugitive and stack releases, Form A reported releases were modeled as two different scenarios, one where the 500 lb of total releases were all fugitive releases (with no stack emissions) and another where the 500 lb of the total releases were all stack releases (with no fugitive emissions).15 Emission rates included in the release assessments were converted to units needed by AERMOD (grams per second for stack sources; grams per second per square meter (m2) for fugitive sources). The conversion from per-hour to per-second utilized the number of emitting hours per year based on the assumed temporal release patterns. The area of fugitive sources was 100 m2 All modeling scenarios utilized a region of gridded receptors placed around a ring/radial at varying distances from the facility being modeled. Receptors were placed every 22.5 degrees (starting due north of the facility) around each ring resulting in 16 receptors around each ring as shown in Figure 2-6. Emitting Facility Figure 2-6. Receptor Locations around Each Distance Ring 15 Although this may be viewed as a potential double counting of these releases, EPA utilized only the highest estimated releases from a single exposure scenario from the suite of exposure scenarios modeled for surrogate/estimated facility releases as exposure estimates and for associated risk calculations. Page 36 of 204 ------- 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 Public Comment Draft - Do Not Cite of Quote Rings were placed at eight finite distances from a facility (5, 10, 30, 60, 100, 2,500, 5,000, and 10,000 meters) forming concentric circles around a modeled facility. One additional distance was modeled to cover an "area" of receptors between 100 and 1,000 meters from a facility. These can be seen in Figure 2-7. Figure 2-7. Modeled Distances from Facility For the "area" of receptors, receptors were regularly spaced at 100-m intervals every 22.5 degrees in all directions within the area between 100 m and 1,000 m from the facility, which is necessary to average the modeled concentrations across the area. This can be seen in Figure 2-8. All receptors were set at 1.8 m above ground, as a proxy for breathing height of an average receptor. EPA assumed flat terrain for all modeling scenarios and used a local-coordinate system centered at (0, 0) for the source of the release. Although AERMOD is capable of modeling elevations for source locations and receptor locations, a flat terrain was modeled for simplicity and the absence of reasonably available information on elevation data for sources and receptors modeled for purposes the screening level analysis. Page 37 of 204 ------- 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 Public Comment Draft - Do Not Cite of Quote Figure 2-8. Receptor Locations between 100 and 1,000 m Exposure Concentration Outputs Daily- and period-average outputs were provided for every run for each receptor around the ring (each of 16 receptors around a ring or within the 100 to 1,000 meters area distance scenario). Period averages were 1 year for TRI reporting facilities and 5 years for facilities where releases were estimated. Outputs were stratified by different source scenarios, such as urban/not urban setting or emission-strengths where needed. Outputs from AERMOD are provided in units of micrograms per cubic meter (|ig/m3) requiring conversion to parts per million (ppm) for purposes of risk calculations and comparison to applicable health endpoints for this work. The following formula was used for this conversion: Cppm = (24.45 *(Caermod)/1,000)/MW Where: Cppm = Concentration (ppm), 24.45 = molar volume of a gas at 25 °C and 1 atmosphere pressure, Caermod = Concentration from AERMOD (|ig/m3), and MW = Molecular weight of the chemical of interest (g/mole). Post-processing scripts were used to extract and summarize the output concentrations at each facility and for each meteorological or source scenario. The following statistics for daily- and period-average concentrations at each of the receptor groups (i.e., each ring and grid of receptors) were extracted or calculated from the results (also see Table 2-4): • Minimum • Maximum • Average • Standard deviation • 10th, 25th, 50th, 75th, and 95th percentiles AERMOD provides daily-average concentrations for each day of the modeled year for each receptor around a ring at each distance modeled. For TRI reporting facilities (which used 2016 calendar year meteorological data), this results in one daily average concentration for each of 366 days for a total of Page 38 of 204 ------- 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 115 Public Comment Draft - Do Not Cite of Quote 366 values at each receptor. For EPA estimated releases (which used 2011 to 2015 meteorological data), this results in 5 daily average concentrations (for each year of meteorological data) for each of 365 (or 366) days for a total of 1,826 values at each receptor. AERMOD also provides a period-average concentration at each of the 16 receptors placed around the ring of a given modeled distance. This results in a total of 16 values for each ring derived from either averaging the daily averages across the single year of meteorological data used (2016) for TRI reporting facilities or across the multi-year meteorological data used (2011 to 2015) for EPA estimated releases. Table 2-4. Description of Daily or Period Average and Air Concentration Statistics Statistic Description Minimum The minimum daily or period average concentration estimated at any receptor location on any day at the modeled distance. Maximum The maximum daily or period average concentration estimated at any receptor location on any day at the modeled distance. Average Arithmetic mean of all daily or period average concentrations estimated at all receptor locations on all days at the modeled distance. This incorporates lower values (from days when the receptor location largely was upwind from the facility) and higher values (from days when the receptor location largely was downwind from the facility). Percentiles The daily or period average concentration estimate representing the numerical percentile value across the entire distribution of all concentrations at all receptor locations on any day at the modeled distance. The 50th percentile represents the median of the daily or period average concentration across all concentration values for all receptor locations on any day at the modeled distance. Exposure Results and Risks Modeled exposure concentration results from the full-screening level analysis were reviewed and summarized on a facility-by-facility basis (and each alternative release estimate) for each scenario modeled. EPA used the 10th, 50th, and 95th percentile estimated concentrations for each facility (and each alternative release estimate) at each distance evaluated for risk calculation purposes. Risk calculations were used to estimate the MOE and excess cancer risk for comparison to the equivalent human health endpoints and benchmark values presented within the respective published final risk evaluations. Land Use Considerations EPA conducted a review of land use patterns around facilities where there was an indication of risk. This review was limited to those facilities with real Global Information System (GIS) locations that showed risk and did not include alternative release estimates showing risk. The purpose of this review was to determine if EPA can reasonably expect an exposure to fenceline communities to occur within the modeled distances where there was an indication of risk. This detailed review consisted of visual analysis using aerial imagery and interpreting land use/zoning practices around the facility. More specifically, EPA used ESRI ArcGIS (Version 10.8) and Google maps to characterize land use patterns within the radial distances evaluated in this work where there was an indication of risk. For locations where residential or industrial/commercial businesses or other public spaces are present within those radial distances indicating risk, EPA includes those receptors within the fenceline communities category and reasonably expects an exposure and therefore an associated potential risk. Where the radial Page 39 of 204 ------- 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 133 134 135 136 137 138 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 157 158 159 160 161 162 163 Public Comment Draft - Do Not Cite of Quote distances showing an indication of risk occur within the boundaries of the facility or is limited to uninhabited areas, EPA does not reasonably expect an exposure to fenceline communities to occur and therefore does not expect an associated risk. Case Studies Chemical specific details and associated results of EPA's application of this full screening methodology for 1-BP and MC are provided in Sections 3.1.4 and 3.2.4. Risk calculations and associated risk findings for 1-BP and MC are provided in Sections 3.1.5 and 3.2.5. 2.1.2.3 Ambient Air Co-resident Screening Methodology The co-resident screening methodology was developed to allow EPA to evaluate exposures and associated risks to a specific subset of receptors falling under the fenceline community category living above or directly adjacent to a facility releasing a chemical undergoing risk evaluation under case- specific exposure scenarios and are referred to as co-resident receptors. Although this methodology can be applied for any chemical falling under an appropriate case-specific exposure scenario, in this report it is only applied to 1-BP. The exposure scenarios addressed in this report are chemical-specific releases from dry-cleaning facilities and effects on co-resident receptors. For purposes of this report, co-resident receptors are defined as a person who lives above or directly adjacent to a dry-cleaning facility utilizing the chemical undergoing risk evaluation. The objectives of this co-resident screening methodology are to (1) develop an approach to estimate air concentrations and exposures to co-resident receptors for the dry-cleaning condition of use; (2) estimate the interzonal air flow—a key parameter for contaminant transport from the source zone to the living spaces—by using the value calibrated against field monitoring data from the literature and other methods applicable to the co-resident exposure scenarios; and (3) develop high-end and central tendency estimates of air concentrations and exposures to co-resident receptors for acute and chronic scenarios. A deterministic indoor air quality model was used to predict chemical transport from the dry-cleaning facilities to the co-resident spaces followed by calculation of the 8-hr, 24-hr, 7-day, and annual time- weighted average (TWA) concentrations in the living space. The unadjusted and adjusted TWA concentrations were then used to calculate potential acute, chronic, and lifetime doses, and potential risks. Model The co-resident screening methodology uses EPA's Indoor Environment Concentration in Buildings with Conditioned and Unconditioned Zones (IECCU) model. IECCU is a deterministic model which can be used as (1) a general-purpose indoor exposure model in buildings with multiple zones, multiple chemicals and multiple sources and sinks or (2) as a special-purpose concentration model for simulating the effects of sources in unconditioned zones on the indoor environmental concentrations in conditioned zones. Readers can learn more about the IECCU model, equations within the model, detailed input and output parameters, and supporting documentation by reviewing the IIOAC users guide (U.S. EPA. 2019aY Releases The emission rates for dry-cleaning operations were generated using EPA's dry-cleaning model (sections 2.3.1.16 and 4.3.1.6 of th q Risk Evaluation for 1-Bromopropane). The data set contains nine emission scenarios, representing a variety of operational scales and conditions. The co-resident screening methodology for this work considered both dry-cleaning and spot cleaning operations, as applicable for the chemical undergoing risk evaluation. Page 40 of 204 ------- 164 165 166 167 168 169 170 171 172 173 174 175 176 111 178 179 180 181 182 183 184 185 186 187 188 189 190 191 192 193 194 195 196 197 198 199 200 201 202 203 204 205 206 Public Comment Draft - Do Not Cite of Quote Exposure Scenarios IECCU was used to predict the concentrations in the co-resident space, as illustrated in Figure 2-9. The model assumes the dry-cleaning shop and the co-resident space are two air zones, the air is well mixed within each zone, and the contaminated indoor air in the dry-cleaning facility can be transported to the co-resident space by the interzonal air flow Q12. Qo2 C2 Zone 2 (Apartment) V2 Q01 Ql2 Q21 Ci Zone 1 (Dry-cleaning facility) Vi Emission rate = R(t) Q20 Q10 Q represents air flows Qij represents the air flow from zone i to zone j. Zone 0 represents the ambient air Figure 2-9. Schematic Representation of the Two-Zone Model for Co-resident Exposure The mass balance equations for the chemical of concern are given by Equations 1 and 2. Vi ^ = R(t) + Q01 Co - Q10 C! - q12 cx + q21 c2 (1) ^2 ^ = Q02 Co - Q20 C2 + Q12 cx - Q21 C2 (2) Where: Vi and V2 are volumes of zone 1 and zone 2 (m3), Page 41 of 204 ------- 207 208 209 210 211 212 213 214 215 216 217 218 219 220 221 222 223 224 225 226 227 228 229 230 231 232 233 234 235 236 237 238 239 Public Comment Draft - Do Not Cite of Quote Ci and C2 are the concentrations of the chemical of concern in zone 1 and zone 2 ([j,g/m3), t is the elapsed time (h), R(t) is the time-varying emission rate ((J-g/h), Co is the concentration of the chemical being evaluated in ambient air (|ig/m3), and Qij is the air flow rate from zone i to zone j. In this model, the interzonal air flow Q12 is considered a major contaminant transport route and, thus, assume Co = 0. Given a set of initial conditions (typically Ci = 0 and Ci = 0 at t = 0), Equations 1 and 2 can be solved numerically to give chemical concentrations in the two zones (Ci and C2) as a function of time. This model requires six input parameters, listed below. IECCU does not provide default values for input parameters at this time, therefore, model inputs are derived from empirical data or modeled estimates. • Zone volumes, Vi and V2 • Ventilation air flow rates, Q10 and Q20 • Chemical emission rate, R(t) • Interzonal air flows, Q12/Q21 The zone volume and ventilation rate (Ni and N2) for the dry-cleaning facility are those utilized in the dry-cleaning model. The zone volume and ventilation rate for the co-resident apartment are based on values from EPA's Exposure Factors Handbook ( '1 la). The ventilation air flow rate is the product of the zone volume and ventilation rate of the respective zone (e.g., Q10 = Vi x Ni). Chemical emission rates are from the results of the dry-cleaning model runs. Emission rates were provided as 10-minute averages and converted to 1-hour averages for use as an input for IECCU. The interzonal air flow (Q12) plays a key role in determining the rate of contaminant transfer from the dry-cleaning shop to the co-resident space. To estimate this parameter, the co-resident exposure scenarios considered two building configurations (B1 and B2) and four methods to estimate the interzonal flow rate as described in Table 2-5. Table 2-5. Summary of Two Building Configurations and Methods to Estimate Interzonal Flow Rate Building Configuration Description of Configuration Method for Estimating Interzonal Flow Rate Description of Method B1 The two zones are architecturally separated as two building units. Such co-resident spaces can be commonly found in mixed-use buildings where the dry-cleaning shop is located on the first floor and the co-resident apartment is above the shop on the second floor. Air convection can occur between the two zones through the cracks and crevices along the Method 1 Uses a literature value in which the Q12 was calibrated against field monitoring data for perchloroethylene from dry-cleaning shops based on a study from McDermott et al. (McDemiott et al., 2005). Method 2 Estimates Q12 based on the stack effect. (Khoukhi and Al-Maabali. 2011) In general, this concept assumes when the air in the dry- Page 42 of 204 ------- 240 241 242 243 244 245 246 247 248 249 250 251 252 253 254 255 Public Comment Draft - Do Not Cite of Quote Building Configuration Description of Configuration Method for Estimating Interzonal Flow Rate Description of Method wall joints due to the pressure difference. cleaning shop is warmer than in the second-floor apartment, the rising air draft serves as a driving force for air flow Q12. For purposes of the co- resident effort, EPA assumes a 2° C temperature difference between the dry-cleaning shop and co-resident apartment, although this is a rough estimate due to the potential influence of ambient temperature in different locations across the country. B2 The two zones are architecturally interconnected. This is a more uncommon case, where the owner uses part of a building unit (e.g., the first floor of a two-story condominium) as a small dry- cleaning shop and the rest space (e.g., second floor) as living quarters. In such cases, the opening along the stairways allows the air to move between the two zones. Method 3 Calculates the Q12 based on a recommended interzonal air exchange rate of 0.7 hr1 from a study by Javiock and Havics (Javiock and Havics. 2018). Method 4 Assumes the two zones share the same HVAC system and calculates the Q12 based on an assumed residential HVAC system re- circulation rate of 5 per hour or hr 1. Exposure Results and Risks Modeled exposure concentration results from the co-resident screening effort were reviewed and summarized for each scenario modeled. EPA used the unadjusted 24-hour TWA and adjusted annual TWA exposure concentrations for risk calculations to estimate the MOE and excess cancer risk for comparison to the equivalent human health endpoints and benchmark values within the respective published final risk evaluations. The calculated risks were then compared to the benchmark values for the respective chemical of interest to determine if there was an indication of potential added risk for either or both acute and chronic non-cancer effects (calculated MOE below the benchmark MOE for the specific chemical) or if there was an indication of potential excess risk for cancer (calculated values greater than the benchmark of 1 x 106 for fenceline communities). Chemical specific details and associated exposure results of the co-resident effort are provided in Section 3.1.4. Risk calculations and associated risk findings are provided in Section 3.1.5.2. Page 43 of 204 ------- 256 257 258 259 260 261 262 263 264 265 266 267 268 269 270 271 272 273 274 275 Public Comment Draft - Do Not Cite of Quote 2.2 Ambient Water Pathway Figure 2-10 provides an overview of EPA's screening level methodology for the ambient water pathway. EPA modeled water releases from facilities and POTWs in its final risk evaluations to estimate waterbody concentrations for environmental exposure assessment. As part of this screening level ambient water analysis, EPA used the same release scenarios along with results of previous E-FAST modeling runs to estimate drinking water and incidental oral/dermal exposures to fenceline communities to the receiving water body. Explication of what constitutes these fenceline communities is given in the EXECUTIVE SUMMARY and INTRODUCTION. Water Pathway Overview Source Pathway 1 Industrial facility and WWTP releases # frl Route 1 Ambient waterbody concentrations from mode line 1 Dermal ¦ Ingestion-both incidental and drinking water Receptors 1 Fenceline Community Receiving Waterbody Figure 2-10. Overview of EPA's Screening Level Ambient Water Pathway Methodology 2.2.1 Environmental Water Releases This section describes the general methodology (Figure 2-11) that was used to develop estimates of water releases from facilities as part of EPA's screening level ambient water pathway methodology. The results of applying this methodology to NMP and MC are presented in Section 3 (Case Study Results). Figure 2-11. General Methodology for Estimating Water Releases Page 44 of 204 ------- 276 277 278 279 280 281 282 283 284 285 286 287 288 289 290 291 292 293 294 295 296 297 298 299 300 301 302 303 304 305 306 307 308 309 310 311 312 313 314 315 316 317 318 319 Public Comment Draft - Do Not Cite of Quote 2.2.1.1 Step 1: Obtain TRI and DMR Data The first step in the methodology for estimating water releases was to obtain TRI data for the chemical from EPA's Basic Plus Data Files (U.S. EPA. 2021) and DMR data from EPA's Water Pollutant Loadi >1 within EPA's Enforcement and Compliance History Online (ECHO) ( 2016a) to query all point source water discharges for the chemical of interest. Where water releases were assessed in the final risk evaluation report, EPA used the same TRI and DMR data as used in the risk evaluation report. TRI data included both Form R and Form A submissions in the fenceline analysis. Facilities may submit a Form A instead of a Form R if the amount of chemical manufactured, processed, or otherwise used do not exceed 1,000,000 lb/year and the total annual reportable releases do not exceed 500 lb/year. Facilities do not need to report release quantities or uses/sub-uses on Form A. For Form A submissions, the methodology to estimate emissions differs slightly from what is described below. Specifically, in Step 2, EPA does not have use/sub-use information for Form A submissions, so instead relies on North American Industry Classification System (NAICS) codes and facility information from internet searches to map these facilities to an OES. For DMR data, the only use information reported is the facility's Standard Industrial Classification (SIC) code. Therefore, EPA relied solely on these codes to map DMR facilities to an OES. These differences are highlighted in the sections below. 2.2.1.2 Step 2: Map TRI and DMR to Occupational Exposure Scenarios In the next step of fenceline analysis development, EPA mapped the chemical's TRI and DMR data to the OES that were in the published risk evaluation for the chemical. Where water releases were assessed in the risk evaluation, the OES mapping did not change. During risk evaluation, EPA used the following procedure to map TRI and DMR data to OES: 1. Review TRI uses and NAICS code: EPA reviewed TRI uses (note: sub-use data not available in TRI until 2018) and NAICS codes for each facility and assigned an OES based on this information 2. Form A's: For Form A submissions, there were no reported TRI uses. To determine the OES for these facilities, EPA used the NAICS codes, market data, public comments, industry meetings and internet searches to determine the type of products and operations at the facility. 3. DMR: For DMR data, there are no reported use information. To determine the OES for these facilities, EPA first cross walked the facilities to TRI facilities and applied the same OES as TRI if the facility reported in both. If the facility did not report in TRI, EPA used the SIC codes, market data, public comments, industry meetings and internet searches to make a reasonable determination regarding the type of products and operations at the facility. If water releases were not assessed in the final risk evaluation, EPA followed the same methodology as described for air releases in Section 2.1.1.2 but with the added step of mapping DMR data as described in Step #3 above. 2.2.1.3 Step 3: Estimate Number of Release Days for Each OES TRI and DMR water release data are provided on an annual basis, in pounds of chemical released per year. However, for the exposure modeling described in Section 2.2.2, releases are needed on a daily basis. To estimate daily releases, EPA needs the number of release days for each facility. Because number of release days is not reported in TRI or DMR, EPA used general guidance to estimate the number of operating days for each OES. In general, the number of operating days in the published risk evaluations for the first round of chemicals were based on the same logic as described in Section 2.1.1.3 for air emissions. This approach assumes the number of release days for a facility is equal to the estimated number of operating days for its assigned OES. Page 45 of 204 ------- 320 321 322 323 324 325 326 327 328 329 330 331 332 333 334 335 336 337 338 339 340 341 342 343 344 345 346 347 348 349 350 351 352 353 354 Public Comment Draft - Do Not Cite of Quote 2.2.1.4 Step 4: Estimate Water Releases for OES with No TRI or DMR Data TRI and DMR data were not available for every OES. In such cases, the risk evaluations assessed releases using data from literature, relevant Emission Scenario Documents (ESDs) or Generic Scenarios (GSs), existing EPA models (e.g., EPA Water Saturation Loss Model), and/or relevant Effluent Limitation Guidelines (ELG). ELG are national regulatory standards set forth by EPA for wastewater discharges to surface water and municipal sewage treatment plants. In some cases, there were insufficient information to estimate water releases from an OES. For these instances, EPA did a qualitative assessment. 2.2.1.5 Step 5: Prepare Water Release Summary for Ambient Water Exposure Modeling The final step was to prepare a summary of the water releases. Water releases assessed in the risk evaluations were summarized and used in the fenceline analysis. 2.2.2 Ambient Water Concentrations and Exposures This section describes the methodologies utilized to assess exposures for members of the fenceline communities to waterbodies receiving MC or NMP discharges. These exposures were evaluated by first reviewing available monitored drinking water information for both MC and NMP, and then by using modeling to estimate drinking water exposure and incidental oral and dermal exposures from swimming (see Figure 2-12). Ambient surface water data was evaluated for both MC and NMP as part of their original REs (U.S. EPA 2020c; U.S. EPA 2020d) with no ambient surface water information found for NMP and data for MC described in Section 3.2.4.2.1. Figure 2-12. General Methodology for Estimating Ambient Water Exposures 2.2.2.1 Step 1: Obtain Measured Drinking Water Concentrations Where possible, reasonably available data for monitored drinking water concentrations for both MC and NMP were evaluated. No monitoring data for NMP were found, but MC data were found via EPA's six- year review process of drinking water standards as required under the Safe Drinking Water Act (SDWA). As part of this process, EPA analyzes compliance monitoring data from public water supplies for regulated drinking water contaminants. A full description and purpose of the six-year review process can be found at the Six-Year Review of Drinking Water Standards. Methylene chloride was evaluated under this program during the third six-year review cycle covering January 2006 through December 2011. During this time period, public water systems (PWSs) compliance monitoring data were provided by states and primacy agencies to EPA via their voluntary Information Collection Request (ICR). This dataset is referred to as the National Compliance Page 46 of 204 ------- 355 356 357 358 359 360 361 362 363 364 365 366 367 368 369 370 371 372 373 374 375 376 377 378 379 380 381 382 383 384 385 386 387 388 389 390 391 392 393 394 395 396 397 398 399 400 401 Public Comment Draft - Do Not Cite of Quote Monitoring ICR Dataset for the third six-year review (or "SYR3 ICR Dataset"). The SYR3 data and User Guide for Downloading the data can be found at Sj\ \ ^ tr Review ' t ,< »mpliance Monitoring Data (2006-20 Data for MC was obtained to characterize potential exposures found in drinking water. The SYR3 data for MC was located under the Organic and Inorganic Chemicals category Phase 3 chemical set and downloaded as a zip file on September 8, 2021. The zip file (SYR3_PhaseChem_3.zip) contained a tab delimited text file specific for MC. The text file was imported into Microsoft Excel using the procedure outlined in the User Guide. Once in the spreadsheet, the dataset was filtered to identify non-detect (ND) samples and their reported detection limits. For all ND samples, one-half the reported detection limit was used for summary calculation purposes. If a detection limit was not provided, calculations were performed using one-half the average of the reported detection limits in all samples (calculated as 0.28 (j,g/L). Reported detection limits without units were assumed to be (J,g/L. When applying the one-half detection limits or one-half the average detection limits as needed, this can create a range, average, and standard deviation based only on detection limit data rather than sampled data when detected sample concentrations fall inside the range of one-half detection limits. Similar discrepancies may appear in the data when considering the concentrations in all samples against the concentrations only in the samples above the detection limit. As an example, when considering the 2011 ground water data set, there were 52,124 samples total and of those samples there were 207 samples with detected values which were used for the statistical analysis. For these samples, the detection limits were between 0.5 to 2 [j,g/L with detected concentrations ranged from 0.1 to 88 (J,g/L. For the non-detect samples, the detection limits were between 5.Ox 10~04 to 1,000 (J,g/L. Since samples that did not have a detection were provided with a value of one-half of its detection limit, the values applied to these samples for the purpose of the statistical analysis ranged between 2.5 x 10~04 to 500 (J,g/L. 2.2.2.2 Step 2: Model Surface Water Concentrations from Facility Releases Exposure via drinking water, incidental oral ingestion and incidental dermal contact were evaluated based off modeled stream and water body concentrations using E-FAST 2014 (U.S. EPA. 2014) as described and documented in the risk evaluations for both chemicals (MC and NMP, ( 320c; 2020d)). These E-FAST 2014 outputs were based on model runs for the release activities identified for the chemical(s) of interest and acted as the input surface water concentrations. No additional modeling using E-FAST 2014 for instream surface water concentrations was conducted For complete description on the approach and methodology behind initial surface water modeling and results of those efforts, see the MC and NMP risk evaluations ( )20c; 2020dY Data for both MC and NMP from the previous E-FAST 2014 model results were extracted and organized using the following data elements: • Release activity names • Chemical IDs • Facility names and locations • NPDES and SIC codes • Occupational exposure scenarios (OES) • Total release amounts • Per site release amounts • Release days per year • Harmonic mean flows and concentrations • 30Q5 flows and concentrations • Concentrations in still water or large water bodies (such as lakes, bays, or oceans) Page 47 of 204 ------- 402 403 404 405 406 407 408 409 410 411 412 413 414 415 416 417 418 419 420 421 422 423 424 425 426 427 428 429 430 431 432 433 434 435 436 437 438 439 440 441 Public Comment Draft - Do Not Cite of Quote • Drinking water exposure metrics such as lifetime average daily dose (LADD), lifetime average daily concentration (LADC), and acute dose rate (ADR) 2.2.2.3 Step 3: Estimate Drinking Water Exposure Once the above information was extracted and compiled into tables, the E-FAST 2014 drinking water exposure calculations were recreated in Excel to verify the inputs and equations used. This validation was done for the adult age group (21+) only, as that is the only age group assessed in E-FAST 2014. After validating that the E-FAST 2014 calculations for LADD, LADC, and ADR could be replicated using equations in Excel, the chemical spreadsheets were expanded to include additional age groups and possible inputs. Calculations were also added for chronic average daily dose (ADD) using the same equation as that for LADD in E-FAST 2014 but modified with inputs to represent a chronic scenario for a specified time frame rather than for the lifetime. The equations utilized for drinking water exposure calculations are ( DWT\ SWC X (1 - ¦^TYrf) x IRdw XRDX CF1 ADRpor = P0T BW X AT ( DWT\ SWC x (l -X IRdw xEDxRDx CF1 ADDpnr - P0T BW x AT x CF2 ( DWT\ SWC X (1 - ¦^TYrf) x IRdw XEDXRDX CF1 LADDpot = iUU J BW x AT x CF2 SWC x(l- xEDxRDx CF1 LADCP0T = - ^ P0T AT X CF2 Where: SWC = Surface water concentration (ppb or |ig/L) DWT = Removal during drinking water treatment (%) IRdw = Drinking water intake rate (L/day) RD = Release days (days/year for ADD, LADD and LADC; 1 day for ADR) ED = Exposure duration (years for ADD, LADD and LADC; 1 day for ADR) BW = Body weight (kg) AT = Exposure duration (years for ADD, LADD and LADC; 1 day for ADR) CF1 = Conversion factor (1.0x10-03 mg/|ig) CF2 = Conversion factor (365 days/year) For drinking water estimates, concentrations in estuaries or bays are not considered as they are unlikely to be potable waters. Drinking water exposures are also not considered for large lakes due to high uncertainty in the applicable dilution factors. This is in alignment with the methodology used in E-FAST 2014 ( ). ADR or acute exposure concentrations used the modeled 30Q5 stream concentrations while the ADD, LADD, and LADC or chronic calculations used the modeled harmonic mean stream concentrations. Drinking water treatment removal (DWT) was set to 0% to represent a conservative estimate of possible drinking water exposures. Page 48 of 204 ------- 442 443 444 445 446 447 448 449 450 451 452 453 454 455 456 457 458 459 460 461 462 463 464 465 466 467 468 469 470 471 472 473 474 475 476 477 478 479 480 481 482 483 484 485 486 487 488 489 Public Comment Draft - Do Not Cite of Quote Inputs for body weight, averaging time (AT), and exposure duration were applied the same across the evaluation of drinking water, incidental oral exposure, and incidental dermal exposure, but are described here. For all calculations, mean body weight data were used from Chapter 8, Table 8-1 in the U.S. Exposure Factors Handbook (EFH) (\ v « « \ JO I I i). To align with the age groups of interest, weight averages were calculated for the infant age group (birth to <1 year) and toddlers (1 to 5 years). The ranges given in the EFH were weighted by their fraction of the age group of interest. For example, the EFH provides body weight for 0 to 1 month, 1 to 3 months, 3 to 6 months, and 6 to 12 months. Each of those body weights were weighted by their number of months out of 12 to determine the weighted average for an infant 0 to 1 year old. For all ADR calculations, the AT is 1 day, and the days of release are assumed to be 1 according to the methodology used in E-FAST 2014 (U.S. EPA. 2014). For all ADD calculations, the AT and the ED are both equal to the number of years in the relevant age group up to the 95th percentile of the expected duration at a single residence, 33 years ( ). For example, estimates for a child between 6 and 10 years old would be based on an AT and ED of 5 years. For all LADD and LADC calculations, the AT is the lifetime of 78 years, and the ED is the number of years in the relevant age group, up to 33 years. Drinking water exposure was estimated for the following age groups: Adult (21+ years), Youth (16-20 years), Youth (10 to 15 years), Child (6 to 10 years), Toddler (1 to 5 years), and infant (birth to <1 year). For NMP, exposure was also estimated for pregnant females as a susceptible population. Drinking water intake rates are provided in the 2019 update of Chapter 3 of the EFH ( ). Weighted averages were calculated for acute and chronic drinking water intakes for adults 21+ and toddlers 1 to 5 years. From Table 3-17, 95th percentile consumer data were used for acute drinking water intake rates. From Table 3-9, mean per capita data were used for chronic drinking water intake rates. The intake rates from Table 3-3 were used for pregnant females in NMP exposure estimates. Supplemental Files SF FLA Water Pathway Exposure Data for MC and SF FLA Water Pathway Exposure Data for NMP (Appendix B) provide additional details on inputs and assumptions for MC and NMP respectively as well as complete results for each chemical as described Section 3.2.4.2.3 (MC) and Section 3.3.4.1 (NMP). 2.2.2.4 Step 4: Estimate Incidental Oral Exposures from Swimming Estimated surface water concentrations from the initial risk evaluations of MC ( 1020c) and NMP ( 320d) were used to estimate acute and chronic incidental oral exposure from swimming following methodologies originally published in the 1,4-dioxane RE (U.S. EPA. 2020e) and NMP RE ( :020d). Those methodologies presented in the previous risk evaluations have been updated here to include more updated input parameters (e.g., incidental ingestion rates) and consistency amongst evaluated age groups. This screening-level analysis focuses on health endpoints relevant to the most sensitive human population for each evaluated chemical, but also provides the adult population (if different from most sensitive) as a point of comparison across chemicals. For MC, the most sensitive health endpoint is youths aged 11 to 15 years due to greatest exposure when considering age-specific ingestion rate, body weight and duration of exposure. For NMP, the most sensitive groups are pregnant women (due to pregnancy-specific hazards) and youths aged 11 to 15 years (due to greater exposure). The equations used to estimate the acute daily dose rate (ADR) and average daily dose (ADD) for incidental oral ingestion are shown below (U.S. EPA. 2014): SWC * IR * CF1 ADR =—m— Page 49 of 204 ------- 490 491 492 493 494 495 496 497 498 499 500 501 502 503 504 505 506 507 508 509 510 511 512 513 514 515 516 Public Comment Draft - Do Not Cite of Quote SWC * IR * ED * RD * CF1 ADD ~ BW * AT * CF2 Where: SWC = Surface water concentration (ppb or |ig/L) IR = Daily ingestion rate (L/day) RD = Release days (days/yr) ED = Exposure duration (years) BW = Body weight (kg) AT = Averaging time (years) CF1 = Conversion factor (0.001 mg/|ig) CF2 = Conversion factor (365 days/year) All receiving water bodies were considered for evaluation of incidental oral ingestion using modeled 30Q5 and harmonic surface water concentrations. Predicted 30Q5 surface water concentrations are used in the calculation of ADRs and ranged from 2.82xlO~07 to 61.9 |ig/L for MC and 4.52xlO~04 to 812 |ig/L for NMP, while predicted harmonic mean surface water concentrations used in the calculation of ADDs ranged from 1.26x ] 0 07 to 14.3 |ig/L for MC and 3.01 / 10 04 to 812 |ig/L for NMP (SF FLA Water Pathway Exposure Data for MC and SF FLA Water Pathway Exposure Data for NMP; Appendix B). Key inputs/exposure factors used to estimate these oral exposures are included in Table 2-6. Supplemental Files SF FLA Water Pathway Exposure Data for MC and SF FLA Water Pathway Exposure Data for NMP (Appendix B) provide additional details on inputs and assumptions for MC and NMP respectively as well as complete results for each chemical as described Section 3.2.4.2.4 (MC) and Section 3.3.4.2 (NMP). Table 2-6. Incidental Oral Exposure Factors for MC and NMP Input Description (units) Age Group Notes Adult (21+ years) Youth (11-15 years) Pregnant Female (NMP only) IRmc Incidental ingestion rate (L/hr) 0.092 0.152 0.092 Upper percentile hourly ingestion rate for respective age groups from Exposure Factors Handbook, Table 3-7 (U.S. EPA. 2019c) BW Body weight (kg) 80 56.8 65.9 Recommended mean body weight for each population from the Exposure Factors Handbook, Table 8-1 (U.S. EPA. 201 laV Values for NMP for pregnant woman age class are taken from the young women/ female adolescent age class (aged 16-21 years) Page 50 of 204 ------- 517 518 519 520 521 522 523 524 525 526 527 Public Comment Draft - Do Not Cite of Quote Input Description (units) Age Group Notes Adult (21+ years) Youth (11-15 years) Pregnant Female (NMP only) ET Exposure time (hr/day) 3 2 3 High-end default short-term duration from EPA Swimmer Exposure Assessment Model (SWIMODED: based on competitive swimmers in the respective aee class (U.S. EPA, 2015) IRmc- daily Incidental daily ingestion rate (L/day) 0.276 0.304 0.276 Ingestion rate x exposure time IR/BW Weighted incidental daily ingestion rate (L/kg- day) 0.0035 0.0054 0.0042 ED Exposure duration (year for ADD) 33 5 33 AT Averaging time (years for ADD) 33 5 33 CF1 Conversion factor (mg/|ig) 1.00E-03 1.00E-03 1.00E-03 CF2 Conversion factor (days/yr) 365 365 365 2.2.2.5 Step 5: Estimate Incidental Dermal Exposure from Swimming All receiving water bodies were considered for evaluation of incidental dermal contact using modeled 30Q5 and harmonic surface water concentrations. Predicted 30Q5 surface water concentrations are used in the calculation of ADRs and ranged from 2.82x10-07 to 61.9 |ig/L for MC and 4.52x10-04 to 812 |ig/L for NMP, while predicted harmonic mean surface water concentrations used in the calculation of ADDs ranged from 1.26xlO~07to 14.3 |ig/L forMC and 3.01xl0~°4to 812 |ig/L for NMP (SF FLA Water Pathway Exposure Data for MC and SFFLA Water Pathway Exposure Data for NMP; Appendix B). This screening-level analysis focused on the adult (MC) and pregnant female (NMP) age classes, as they represent the worst-case exposure conditions when considering the age-specific surface area to body weight ratio and duration of exposure (Table 2-7). Page 51 of 204 ------- 528 529 530 531 532 533 534 535 536 537 538 539 540 541 542 543 544 545 546 547 548 549 550 551 552 553 554 555 556 557 Public Comment Draft - Do Not Cite of Quote The equations used to estimate the acute daily dose rate (ADR) and average daily dose (ADD) for incidental dermal exposure are shown below ( ): SWC * Kp * SA * ET * CF1 * CF2 ADR = w a n n SWC * Kp * SA* ET * RD * ED * CF1 * CF2 ADD ~ BW * AT *CF3 Where: ADR = Acute Dose Rate (mg/kg/day) ADD = Average Daily Dose (mg/kg/day) SWC = Chemical concentration in water (|ig/L) Kp = Permeability coefficient (cm/hr) SA = Skin surface area exposed (cm2) ET = Exposure time (hr/day) RD = Release days (days/yr) ED = Exposure duration (years) BW = Body weight (kg) AT = Averaging time (years) CF1 = Conversion factor (1.0x10-03 mg/|ig) CF2 = Conversion factor (1.0x10-03 L/cm3) CF3 = Conversion factor (365 days/year) Key inputs/exposure factors used to estimate these dermal exposures are included in Table 2-7. Supplemental Files SF FLA Water Pathway Exposure Data for MC and SF FLA Water Pathway Exposure Data for NMP (Appendix B) provide additional details on inputs and assumptions for MC and NMP respectively as well as complete results for each chemical as described Section 3.2.4.2.5 (MC) and Section 3.3.4.3 (NMP). Page 52 of 204 ------- Public Comment Draft - Do Not Cite of Quote Table 2-7. Incidental Dermal Exposure Factors for MC and > [MP IMC NMP Input Description (units) Adult (>21 years) (Pregnant Female) Notes BW Body weight (kg) 80 65.9 Recommended mean body weight for each population from the Exposure Factors Handbook. Table 8-1 (U.S. EPA. 2011a). Values for NMP for pregnant woman age class are taken from the young women/ female adolescent age class (aged 16-21 years) SA Skin surface area exposed (cm2) 19,500 18,500 MC: Default dermal contact surface area for the adult aae class in SWIMODEL (U.S. EPA. 2015) NMP: Mean total surface area of adult females from the Exposure Factors Handbook, Table 7- 13 ( 2011a) ET Exposure time (hours/day) 3 3 High-end default short-term duration from EPA Swimmer Exposure Assessment Model (SWIMODEL); based on competitive swimmers in the respective age class ( 2015) Kp Permeability coefficient (cm/hr) 7.17E-03 4.78E-04 MC: Estimated from Consumer Exposure Model (U.S. EPA. 2017) NMP: Recalibrated from data in Poet et al. (2010) ED Exposure duration (years for ADD) 33 33 Number of years in age group, up to the 95th percentile residential occupancy period. U.S. EPA Exposure Factors Handbook, Chapter 16, Table 16-5 (U.S. EPA. 2011a) AT Averaging time (years for ADD) 33 33 Number of years in age group, up to the 95th percentile residential occupancy period. U.S. EPA Exposure Factors Handbook, Chapter 16, Table 16-5 (U.S. EPA. 2011a) CF1 Conversion factor (mg/ug) 1.00E-03 1.00E-03 CF2 Conversion factor (L/cm3) 1.00E-03 1.00E-03 CF3 Conversion factor (davs/vear) 365 365 559 2.3 Risk Estimation Approach 560 To calculate risks from fenceline exposures through air and water, EPA used the same methods used in 561 previously published risk evaluations. 562 2,3.1 Characterization of Non-cancer Risks 563 EPA used a Margin of Exposure (MOE) approach to identify potential non-cancer risks. The MOE is the 564 ratio of the non-cancer POD divided by a human exposure dose. Acute and chronic MOEs for non- 565 cancer inhalation and dermal risk were calculated using the following equation: 566 Non — cancer Hazard value (POD) 567 MOEacute or chronic — 568 Human Exposure Page 53 of 204 ------- 569 570 571 572 573 574 575 576 577 578 579 580 581 582 583 584 585 586 587 588 589 590 591 592 593 594 595 596 597 598 599 600 601 602 603 604 605 606 607 608 609 610 611 612 613 614 Public Comment Draft - Do Not Cite of Quote Where: MOE = Margin of exposure (unitless) Hazard value (POD)= HEC (ppm) or HED (mg/kg-d) Human Exposure = Exposure estimate (in ppm or mg/kg-d) MOEs allow for the presentation of a range of risk estimates. EPA interpreted the MOE risk estimates for each use scenario in reference to benchmark MOEs. Benchmark MOEs are the total UF for each non-cancer POD. The MOE estimate was interpreted as a human health risk if the MOE estimate was less than the benchmark MOE {i.e., the total UF). On the other hand, the MOE estimate indicated negligible concerns for adverse human health effects if the MOE estimate was equal to or exceeded the benchmark MOE. Typically, the larger MOE, the more unlikely it is that a non-cancer adverse effect would occur. 2,3,2 Characterization of Cancer Risks Extra cancer risks for repeated exposures to a chemical were estimated using the following equations: Inhalation Cancer Risk = Human Exposure x IUR or Dermal/Oral Cancer Risk = Human Exposure x CSF Where: Risk = Extra cancer risk (unitless) Human exposure = Exposure estimate (LADC in ppm) IUR = Inhalation unit risk (1 x 10~6 per ppm) CSF = Cancer slope factor (1.2><10_1 per mg/kg-d) Estimates of extra cancer risks are interpreted as the incremental probability of an individual developing cancer over a lifetime following exposure {i.e., incremental or extra individual lifetime cancer risk). EPA used 1 x 10~6 as the benchmark for cancer risk in fenceline communities. This is consistent with the cancer benchmark used for general population cancer risk in several other EPA programs and in previous risk evaluations . It is important to note that exposure related considerations (duration, magnitude, specific population exposed) can affect EPA's estimates of the excess lifetime cancer risk (ELCR). In order to address increased exposure and sensitivity of younger lifestages, total lifetime cancer risk across lifestages was calculated by integrating partial risk for each lifestage based on differential exposure. For chemicals with a mutagenic mode of action, EPA applied age-dependent adjustment factors (ADAFs) using methods consistent with EPA's supplemental guidance for assessing susceptibility for early-life exposure to carcinogens, ( )05). Specifically, for chemical with a mutagenic mode of action, EPA applied a 10-fold adjustment for exposure before 2 years of age, a 3- fold adjustment for exposures between 2 and <16 years of age and no additional adjustment for exposures at 16 years of age and above. 2.4 Key Assumptions and Uncertainties 2.4,1 Assumptions and Uncertainties in Release Estimation EPA estimated releases using reported data from TRI and DMR. TRI and DMR data were determined to have a "medium" confidence rating through EPA's systematic review process. However, when using TRI data to analyze chemical releases, it is important to acknowledge that TRI reporting does not Page 54 of 204 ------- 615 616 617 618 619 620 621 622 623 624 625 626 627 628 629 630 631 632 633 634 635 636 637 638 639 640 641 642 643 644 645 646 647 648 649 650 651 652 653 654 655 656 657 658 659 660 661 662 Public Comment Draft - Do Not Cite of Quote include all releases of the chemical and therefore, the number of sites for a given OES may be underestimated. Due to limiting the scope of this screening-level analysis to facilities that report releases to TRI and DMR, it is uncertain, the extent to which, sites not captured in these databases have air emissions or water releases of a chemical and whether any air emissions would be stack or fugitive and whether water releases would be to surface water, POTW, or non-POTW WWT. TRI data do not include • Releases from any facility that used the chemical in quantities below the applicable annual chemical activity threshold (e.g., 25,000 lb manufactured or processed, or 10,000 lb otherwise used, for most chemicals); • Releases from any facility that is not in a TRI covered sector; and • Releases from any facility that does not meet the TRI employment threshold of greater than 10 full-time employee equivalents (20,000 labor hours) for the year. EPCRA section 313 states that facilities may estimate their release quantities using "readily available data," including monitoring data, collected for other purposes. When data are not readily available, EPCRA section 313 states that "reasonable estimates" may be used. The facility is not required to monitor or measure the quantities, concentration, or frequency of any toxic chemical release for TRI reporting. TRI guidance states that not using readily available information, such as relevant monitoring data collected for compliance with other regulations, could result in enforcement and penalties. For each release quantity reported, TRI facilities select a "Basis of estimate" code indicating the principal method used to determine the amount of the release. TRI provides six basis of estimate codes to choose from: continuous monitoring, periodic monitoring, mass balance, published emissions factors, site-specific emissions factors, or engineering calculations/best engineering judgment. In facilities where a chemical is used in multiple operations, the facility may use a combination of methods to calculate the release reported. In such cases, TRI instructs the facility to enter the basis of estimate code of the method that applies to the largest portion of the release quantity. Additional details on the basis of estimate, such as any calculations and underlying assumptions, are not reported. For any release quantity that is less than 1,000 lb, facilities may report either the estimated quantity or a range code. The 1,000-pound limit for range code reporting applies to each type of release reported to TRI - fugitive air emissions, stack air emissions, water discharges, each type of land disposal, and each type of off-site transfer. There are three TRI range codes: 1-10; 11-499; and 500-999 lb. TRI data tools display the approximate midpoint of the range (i.e., 5, 250, or 750 lb). Although analyses using data that was reported as a range code may add uncertainty, it is not clear that the uncertainty associated with a range code is greater than that associated with any other estimated release value. Range code reporting is not permitted for chemicals of special concern. TRI facilities enter the facility's primary six-digit North American Industry Classification System (NAICS) code indicating the primary economic activity at the facility. Facilities can also enter secondary NAICS codes. NAICS codes are reported for the facility as a whole and are not chemical specific. When using TRI chemical release data for a facility that also reported secondary NAICS codes, there may be uncertainty as to which NAICS is associated with the use of the chemical. TRI guidance states that release estimates need not be reported to more than two significant figures. However, the guidance also states that facilities should report release quantities at a level of precision supported by the accuracy of the underlying data and the estimation techniques on which the estimate was based. If a facility's release calculations support reporting an amount that is more precise than two Page 55 of 204 ------- 663 664 665 666 667 668 669 670 671 672 673 674 675 676 677 678 679 680 681 682 683 684 685 686 687 688 689 690 691 692 693 694 695 696 697 698 699 700 701 702 703 704 705 706 707 708 709 710 711 Public Comment Draft - Do Not Cite of Quote significant digits, then the facility should report that more precise amount. The facility makes the determination of the accuracy of their estimate and the appropriate significant digits to use. For chemicals that meet certain criteria, facilities have the option of submitting a TRI Form A Certification Statement instead of a TRI Form R. The Form A does not include any details on the chemical release or waste management quantities. The criteria for a Form A are that during the reporting year, the chemical (1) did not exceed 500 lb for the total annual reportable amount (including the sum of on- and off-site quantities released, treated, recycled, and used for energy recovery); (2) amounts manufactured, processed, or otherwise used do not exceed 1 million lb; and (3) the chemical is not a chemical of special concern. When conducting analyses of chemical releases and a facility has submitted a Form A for the chemical, there is no way to discern the quantity released to each medium or even if there were any releases. For air emissions, where facilities reported to TRI with a Form A, EPA used the Form A threshold for total releases of 500 lb/year. EPA used the entire 500 lb/year for both the fugitive and stack air release estimates; however, since this threshold is for total site releases, these 500 lb/year are either to fugitive air or stack air for this analysis, not both (since that would double count the releases and exceed the total release threshold for Form A). Furthermore, the threshold represents an upper limit on total releases to all environmental media from the facility; therefore, assessing the air emissions at the threshold value likely overestimates actual air emissions from the facility. In addition, information on the use of the chemical at facilities in TRI and DMR is limited; therefore, there is some uncertainty as to whether the mapping of each facility to an OES does in fact represent that specific OES. If facilities were categorized under a different OES, the annual air emissions or water releases for each site would remain unchanged; however, average daily releases may change depending on the release days expected for the different OES. Facilities reporting to TRI and DMR only report annual releases; to assess daily releases, EPA estimated the release days and averaged the annual releases over these days. There is some uncertainty that all facilities for a given OES operate for the assumed duration; therefore, the average daily release may be higher if sites have fewer release days or lower if they have greater release days. Furthermore, chemical concentrations in air emissions and wastewater streams at each facility may vary from day-to-day such that on any given day the actual daily releases may be higher or lower than the estimated average daily discharge. In some cases, the number of facilities for a given OES was estimated using data from the U.S. Census. In such cases, the average daily release calculated from sites reporting to TRI or DMR was applied to the total number of sites reported in (1 ; S Census Bureau. 2015). It is uncertain how accurate this average release is to actual releases at these sites; therefore, releases may be higher or lower than the calculated amount. For air emissions, where facilities reported to TRI with a Form A, EPA used the Form A threshold for total releases of 500 lb/yr. EPA used the entire 500 lb/year for both the fugitive and stack air release estimates; however, since this threshold is for total site releases, these 500 lb/year are either to fugitive air or stack air for this analysis, not both (since that would double count the releases and exceed the total release threshold for Form A). EPA used the entire 500 lb/year for both the fugitive and stack air release estimates; however, since this threshold is for total site releases, these 500 lb/year are either to fugitive air or stack air for this analysis, not both (since that would double count the releases and exceed the total release threshold for Form A). Furthermore, the threshold represents an upper limit on total releases to all environmental media from the facility; therefore, assessing the air emissions at the threshold value likely overestimates actual air emissions from the facility. Page 56 of 204 ------- 712 713 714 715 716 111 718 719 720 721 722 723 724 725 726 727 728 729 730 731 732 733 734 735 736 737 738 739 740 741 742 743 744 745 746 747 748 749 750 751 752 753 754 755 756 757 758 759 Public Comment Draft - Do Not Cite of Quote For release estimates developed for an OES when 2019 TRI data were not available, there are uncertainties related to the use of prior year TRI data or, in their absence, the use of modeling. Use of the past years' TRI data may introduce uncertainties related to whether those releases are currently ongoing or the extent to which past years' data reflects current releases. Although no new models were developed for this screening level fenceline analysis, the adaptations made to and uses of these models as part of the screening-level fenceline analysis may result in release estimates higher or lower than the actual amount. Additionally, the approach used for scenario development for estimated releases based on modeling or other data sources differs from the facility-specific approach used for OES for which TRI data were available (as described in section 2.1.2.2). This may introduce uncertainties that differ from those of the scenarios using TRI data, described above. TRI guidance states that release estimates need not be reported to more than two significant figures. However, the guidance also states that facilities should report release quantities at a level of precision supported by the accuracy of the underlying data and the estimation techniques on which the estimate was based. If a facility's release calculations support reporting an amount that is more precise than two significant digits, then the facility should report that more precise amount. The facility makes the determination of the accuracy of their estimate and the appropriate significant digits to use. For chemicals that meet certain criteria, facilities have the option of submitting a TRI Form A Certification Statement instead of a TRI Form R. The Form A does not include any details on the chemical release or waste management quantities. The criteria for a Form A are that during the reporting year, the chemical (1) did not exceed 500 lb for the total annual reportable amount (including the sum of on- and off-site quantities released, treated, recycled, and used for energy recovery); (2) amounts manufactured, processed, or otherwise used do not exceed 1 million lb; and (3) the chemical is not a chemical of special concern. When conducting analyses of chemical releases and a facility has submitted a Form A for the chemical, there is no way to discern the quantity released to each medium or even if there were any releases. For air emissions, where facilities reported to TRI with a Form A, EPA used the Form A threshold for total releases of 500 lb/year. EPA used the entire 500 lb/year for both the fugitive and stack air release estimates; however, since this threshold is for total site releases, these 500 lb/year are either to fugitive air or stack air for this analysis, not both (since that would double count the releases and exceed the total release threshold for Form A). Furthermore, the threshold represents an upper limit on total releases to all environmental media from the facility; therefore, assessing the air emissions at the threshold value may overestimate actual air emissions from the facility. 2.4.2 Assumptions and Uncertainties in Air Pathway Exposure Modeling Pre-screening Analysis IIOAC provides exposure concentrations at three pre-defined distances (100 meters, 100 to 1,000 meters, and 1,000 meters) which is a limitation to the model itself (it does not estimate exposure concentrations closer or farther out than these distances). Based on this current fenceline work, exposures from fugitive releases were found to peak around 10 meters from a facility and rapidly decay at farther distances and stack releases were found to peak around 100 meters. Therefore, where a facility's releases are primarily fugitive in nature, the inherent distance limitations of the model prohibit it from estimating exposures to receptors closer to a facility (less than 100 meters from the facility). This could result in the pre-screening modeling methodology not identifying or capturing exposures and associated potential risk from such fugitive releases for receptors closer than 100 meters. Taking the IIOAC pre-screening results alone, without considering release type (stack/fugitive) and other factors, could then lead to a decision to screen out a pathway due to no risk at 100 meters, when there is exposure and associated risk at distances closer than 100 meters. This issue could be avoided by taking a Page 57 of 204 ------- 760 761 762 763 764 765 766 767 768 769 770 111 772 773 774 775 776 777 778 779 780 781 782 783 784 785 786 787 788 789 790 791 792 793 794 795 796 797 798 799 800 801 802 803 804 805 806 807 808 Public Comment Draft - Do Not Cite of Quote closer look at exposure concentrations and associated risks at 100 meters to see how close to (or far off) the estimated risks are from the relevant benchmarks. Even if risk is not explicitly indicated at 100 meters, if it is close to indicating a risk (e.g., close to a benchmark), it may warrant a full screening level analysis to be conducted. Meteorological data can have a significant impact on exposure concentrations upwind and downwind of a releasing facility. The use of 14 pre-defined meteorological stations representing regions of the United States generalizes the meteorological data across a wide area where competing conditions can significantly influence the exposure concentrations modeled. However, when using IIOAC for pre- screening work, EPA used the meteorological stations within IIOAC which provided high end and central tendency exposure concentration estimates, based on a sensitivity analysis, therefore maintaining a conservative estimate of the exposure concentrations used to calculate risk. This approach adds confidence to the findings by ensuring under a high-end exposure scenario potential risks would be captured. Screening Analysis AERMOD is EPA's regulatory model and has been thoroughly peer reviewed therefore the general confidence in results from the model is high but reliant on the integrity and quality of the inputs used and interpretation of the results. For the full-screening level analysis, EPA used 2019 TRI data for release information. There is uncertainty around the use of only 2019 TRI data for the full-screening level analysis. The 2019 TRI dataset used for the full-screening level analysis does not have actual release point locations which can affect the estimated concentrations at varying distances modeled. For the release location, EPA used a local-coordinate system. EPA centered a facility's emissions on one location which was assigned the local coordinate of (0,0) and concentrations were estimated at modeled distances in concentric rings from that location. However, the (0,0) coordinate was placed at a location which represents the latitude/longitude (lat/long) information reported to TRI. That lat/long may represent the mailing address location of the office building associated with a very large facility rather than the actual release location (e.g., a specific process stack). This discrepancy between the (0,0) coordinate from which an exposure concentration is modeled for the full-screening level analysis and the actual release point could result in an exposure concentration that does not represent the actual distance where fenceline communities may be exposed. This is particularly relevant for larger facilities where the actual release point may be several hundred meters to the northeast of the office building. In this situation, the exposure concentrations estimated at several hundred meters from the (0,0) coordinate (office building) may be located within the facility property-line; however, the exposure concentration should be applied from the actual release point. This could shift the actual modeled exposure concentration from within the facility property-line to well outside of the facility property-line where fenceline communities may be exposed (e.g., the actual release point may be directly next to a residential community or school yard just outside the facility property-line). The 2019 dataset used for full-screening level analysis does not include source specific physical characteristics like stack height, exit gas temperature, etc. which can affect plume characteristics and associated dispersion of the plume. For the source specific characteristics, EPA used physical stack parameters and plume characteristics consistent with those used in IIOAC, including, but not limited to: stack emissions released from a point source at 10 meters above ground from a 2-m inside diameter stack, with an exit gas temperature of 300 °Kelvin and an exit gas velocity of 5 m per second (see Table 6 of the IIOAC User Guide). EPA acknowledges these stack parameters represent conservative plume characteristics which resemble a slow-moving, low-to-the-ground plume with limited dispersion but Page 58 of 204 ------- 809 810 811 812 813 814 815 816 817 818 819 820 821 822 823 824 825 826 827 828 829 830 831 832 833 834 835 836 837 838 839 840 841 842 843 844 845 846 847 848 849 850 851 852 853 854 855 856 Public Comment Draft - Do Not Cite of Quote believe are appropriate for screening level purposes. None-the-less, use of these conservative parameters may overestimate emissions for certain facilities modeled. Additionally, while these default values are based on national averages and some research into typical stack parameters and conditions, they may not be applicable or representative of all sources evaluated in this fenceline work. As discussed in the release section, some facilities modeled relied on release data from the TRI Form A (which has a reporting threshold of 500 lb). Since there is no source attribution associated with a Form A reporting value, EPA modeled each facility associated with a Form A submittal twice, once assuming all 500 lb of the reporting threshold was fugitive and once assuming all 500 lb of the reporting threshold was stack. This maintains a conservative estimate, in terms of total release, but may overestimate exposure concentrations associated with these releases if a facility did not actually release all 500 lb. At the same time, although it maintains a conservative estimate the resulting modeled concentrations for Form A facilities tended to be low in comparison to the majority of TRI reporting facilities reporting an actual stack and/or fugitive release across a given OES. Additionally, in each case Form A modeled facilities tended to have higher exposure concentrations resulting from the fugitive release scenario compared to the stack release scenario. Although this approach could lead to a potential concern over double counting a facility release, when presenting potential exposures EPA relies on the highest (more conservative) exposure concentration between the two release types for purposes of evaluating potential risks to fenceline communities. As discussed above, this tended to result in EPA considering the scenario where 500 lb of release occurred under the fugitive release scenario for purposes of presenting potential exposures and associated potential risks. Co-resident Screening Analysis IECCU does not include default values for select input parameters and relies on user derived input parameters. In many cases, the availability of reference data for the input parameters is limited or non- existent and therefore inputs rely on other models to estimate an input parameter. This places a higher reliance on the efficacy of the models used to estimate input parameters which may or may not be appropriate or thoroughly reviewed. EPA minimized this uncertainty by using reference data, where reasonably available and by relying on other EPA reviewed and/or approved models to derive input parameters. As described in the model documentation, the Q12 flow is a significant factor when estimating transport of the chemical of concern into the adjacent living space and therefore should be well established to ensure confidence in the results. EPA minimized uncertainty by estimating the Q12 two different ways for each of the two buildings configuration. Not only does this approach provide a variation in the Q12, but it also provides results which can be compared for consistency. Comparison of the two approaches for the Q12 values showed consistency across both methods within a building configuration and therefore helps provide added confidence that the results are reliable. 2.4.3 Assumption and Uncertainties in Drinking Water Monitoring Results Drinking water monitoring data were identified only for MC and only through the discussed data found in the Six-Year Review of Drinking Water Standards. It is noted that the date range of this dataset is between 2006 and 2011 and those monitored values may not represent current conditions, nevertheless they represented the most recent available monitored information on drinking water concentrations and provide relevant information to possible drinking water exposures. Additionally, these measurements are taken at the point of drinking water distribution meaning the sampled location may be temporally or spatially separate from the initial point of chemical release. Finally, due to the different years between modeled and monitored information available for MC, the monitored results were not linked to physical Page 59 of 204 ------- 857 858 859 860 861 862 863 864 865 866 867 868 869 870 871 872 873 874 875 876 877 878 879 880 881 882 883 884 885 886 887 888 889 890 891 892 893 894 895 896 897 898 899 900 901 902 903 904 Public Comment Draft - Do Not Cite of Quote locations or compared to modeled estimates of instream and drinking water concentrations from facility releases. 2.4,4 Assumptions and Uncertainties in Water Pathway Exposure Modeling Estimation of all water pathway exposures is dependent on modeling done through E-FAST 2014 (U.S. 14) which is subject to a number of assumptions and uncertainties. Since modeling was not redone for this evaluation the original risk evaluations for both MC ( 020c) and NMP (U.S. MM) go into greater depth on these uncertainties and assumptions, but they are briefly discussed here . The modeled scenarios used and estimated high and low days of release frequency for all direct releasers and a high days of release frequency for all indirect releasers. The greater the number of release days, the more a per-day release will be diluted assuming the same overall annual loading estimate. The selection of both a high and low number of release days is intended to bracket and provide the range of possible releases to stream waterbodies, but release days may vary across and between industries and may not be accurately represented by these assumed values. The applied stream flow distribution is another key parameter determining output results. The modeled 30Q5 and harmonic mean surface water concentrations are used to calculate the estimated water pathway exposures for drinking water, incidental oral, and incidental dermal exposures. The flow distributions are applied by selecting a facility-specific NPDES code in E-FAST 2014. When site- specific or surrogate site-specific stream flow data were not available, flow data based on a representative industry sector were used in the assessment. This includes cases where a receiving facility for an indirect release could not be determined. In such cases, it is likely that the stream concentration estimates are higher than they would be if a facility-specific NPDES code was able to be applied, except in certain cases (e.g., NPDES associated with low-flow or intermittent streams or bays). Additionally, the stream flow data currently available in E-FAST 2014 are 15 to 30 years old and may not represent current conditions at a particular location. Due to the age and spatial resolution of this dataset, the input waterbody flow values may represent either an overestimate or underestimate of actual flow conditions depending on location. Nevertheless, the used datasets represent the most comprehensive and accurate nationwide datasets available for modeling evaluation and analysis. The use of E-FAST 2014 also estimates waterbody surface water concentrations at the point of release, without considering post-release environmental fate or degradation processes such as volatilization, biodegradation, photolysis, hydrolysis, or partitioning. Additionally, E-FAST 2014 does not estimate stream concentrations based on the potential for downstream transport and dilution. These considerations tend to lead to higher predicted surface water concentrations. Dilution is incorporated, but it is based on the stream flow applied. Estimated drinking water exposures were based on the assumption that an individual is exposed to potential waterbody concentrations as the point of release without any potential for transport, dilution, or treatment. Estimation of waterbody concentrations at the point of actual drinking water intakes or the distances to these locations was beyond the scope of this evaluation, but in most cases, it would be expected that waterbody concentrations at these locations would be lower even without treatment. Therefore, our analysis represents a higher-end estimate of possible drinking water exposures. Estimation of incidental dermal and oral exposures used default inputs for exposure time from EPA's SWIMODEL. These exposure time defaults are based on swimming pool use patterns rather than freshwater bodies assumed here and thus represents an uncertainty about the application of swimming Page 60 of 204 ------- 905 906 907 908 909 910 911 912 913 914 915 916 917 918 919 920 921 922 923 924 925 926 927 928 929 930 931 932 933 934 935 936 937 938 939 940 941 942 943 944 945 Public Comment Draft - Do Not Cite of Quote pool duration data to this analysis. Additionally, these evaluations are based on estimated waterbody concentrations at the point of release with the assumption that an individual would be incidentally exposed at that location. This assumption represents a higher-end estimate of possible exposure, as activities occurring farther downstream would be expected to have lower waterbody concentrations. 2,4,5 Assumptions and Uncertainties in Risk Characterization Exposure Duration This analysis provides exposure and hazard values based on a 24-hour exposure. This assessment assumes that an individual living nearby a facility will be exposed to a chemical at a similar concentration for all hours of the day—either they are present at home all day or remain close-by. This uncertainty may result in an overestimation of exposure and risk, especially for chronic durations, for exposed individuals who may regularly travel farther away from exposure sources and would not be chronically exposed at the same concentration continuously. Similarly, chronic and lifetime exposure and risk estimates are only relevant to individuals who reside at the same location for years or decades. These longer-term exposures would vary for individuals who did not remain within the same range of a particular facility. Distance Where Risk Identified IIOAC and AERMOD provided exposure concentrations at discrete distances. EPA calculated risk at modeled discrete distances. Therefore, there is uncertainty of risk between the two distances modeled. For example, if we found risk at 100 meters and we did not find risk at 1000 meters, EPA is uncertain if there is risk at 101 to 999 meters. To not underestimate risk beyond the risk showing distance (e.g., at 101 meters), or overestimate risk closer to the distance where risk was not found (e.g., at 999 meters), remodeling may be required to determine exposure concentrations, and thus calculating risk between the two discrete distances previously modeled. As discussed in Section 2.1.2.2, EPA review of land use patterns was limited to those facilities with GIS locations that showed risk. Because estimated releases do not have a physical location associated with a facility, EPA was unable to visually examine land use patterns around the theoretical facility. Therefore, EPA was unable to conduct such analysis for alternative release estimates showing risk. Additionally, reported TRI facility's location data (latitude/longitude) may not represent the actual location of the releasing source (e.g., a processes stack). Potentially Exposed or Susceptible Subpopulations Human health toxicity values for this analysis incorporate the same considerations for PESS as were described in the respective risk evaluations for each chemical. For oral and dermal exposures, risks were additionally estimated for multiple relevant lifestages and subpopulations, with the most sensitive results (based on elevated exposure) presented in this analysis alongside adult estimates. Inhalation risk estimates are based on air concentrations and were not adjusted for potential lifestage-specific differences, consistent with current EPA guidance which assumes that lifestage-specific differences in inhalation dosimetry are covered by the 10x intraspecies uncertainty factor (UFh) ( 012a). Page 61 of 204 ------- Public Comment Draft - Do Not Cite of Quote 1 3 CASE STUDY RESULTS 2 EPA presents three case study chemicals in this section: two case study chemicals for the air pathway 3 (1-BP and MC) and two case study chemicals for the water pathway (MC and NMP). The purpose of 4 these case study chemicals is to show the application and efficacy of the proposed screening level 5 methodology to estimate releases, potential exposures and capture potential risks to fenceline 6 communities for select pathways not previously evaluated in published risk evaluations. While these 7 case study chemicals are among the seven chemicals for which EPA published risk evaluations between 8 2020 and 2021 and intends to conduct a screening level analysis following finalization of the screening 9 level methodology and framework development, the results presented here are for illustrative purposes 10 only and not final agency action. Any results, risks, or risk conclusions, as presented here, are not 11 intended to be used to support risk management actions or rulemaking. 12 3.1 1-Bromopropane (Air Pathway) 13 3.1.1 Background for 1-BP 14 1-Bromopropane (1-BP) is a highly volatile, liquid organic compound. It degrades slowly in the 15 atmosphere and can be transported over long distances. Its volatility and biodegradability are such that 16 intermittent releases to surface water are not expected to accumulate. However, continuous releases can 17 lead to persistent concentrations. It has low affinity for organic surfaces and is therefore expected to be 18 mobile in groundwater (U.S. EPA. 2020b). The physical-chemical properties of 1-BP are summarized in 19 T ableApx A-1. 20 3.1,2 Human Health Hazard Endpoints for 1-BP 21 All hazard values used to calculated risk for 1-BP in this report are derived from the previously peer- 22 reviewed PODs published in the Final Risk Evaluation for 1 -Bromopropane ( 2020b). In the 23 Final Risk Evaluation, EPA utilized the endpoints shown in Table 3-1 for risk determination. For 1-BP, 24 distinct human equivalent concentrations (HECs) for non-cancer endpoints were derived for 25 occupational and consumer scenarios. Additionally, an inhalation unit risk (IUR) for lifetime cancer risk 26 was applied for both occupational and consumer scenarios for COUs where it was applicable. 27 Table 3-1. Hazard Values Used for Risk Estimation in the 1-BP Risk Evaluation Scenario Endpoint Occupational POD Consumer POD Benchmark Reference Acute Developmental: Post-implantation loss 17 ppm 6 ppm 100 (W.l.L. Research. ^ ) Chronic Developmental: Post-implantation loss 17 ppm 6 ppm 100 (W.l.L. Research, ^ ) Cancer Respiratory adenomas/carcinoma 4E-03 per ppm 6E-03 per ppm 1E-4 (occup.); 1E-6 (cons.) (NIP. 20ID 29 30 For the analyses in this report, EPA derived POD values for fenceline communities based on a 31 continuous exposure scenario. The noncancer HECs were derived from the original benchmark 32 concentration levels (BMCLs) from the animal studies as presented in Table 3-8 of ( 2020b). 33 The acute and chronic HECs are for the developmental endpoint of post-implantation loss, with a 34 BMCLi of 23 ppm following 6 hr/day daily inhalation exposure of pregnant rats from pre-mating 35 through gestational day 20. In adjusting for continuous 24 hr/day exposure, the resulting HEC matches Page 62 of 204 ------- 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 Public Comment Draft - Do Not Cite of Quote the value used for consumers in the Final Risk Evaluation. For cancer, the IUR value used for consumers was already adjusted to continuous exposure and did not require any further extrapolation for evaluation of risks to fenceline communities. The adjusted POD values for fenceline communities are presented below in Table 3-2. Table 3-2. Hazard Values for 1- 3P Used in this Fenceline Analysis Scenario Endpoint Fenceline HEC/IUR Benchmark Reference Acute Developmental: Post-implantation loss 6 ppm 100 fW.l.L. Research. 2001) Chronic Developmental: Post-implantation loss 6 ppm 100 fW.l.L. Research. 2001) Cancer Respiratory adenomas/carcinoma 6E-03 per ppm 1E-6 (NIP. 2011) 3.1.2.1 Assumptions and Uncertainties for 1-BP Human Health Hazard The PODs used for the fenceline analysis match those used in the risk evaluation, so there is no uncertainty associated with any additional extrapolation for fenceline communities. Any other assumptions or uncertainties inherent to the human health hazard assessment in the Final Risk Evaluation for 1 -Bromopropane ( 2020b) are still applicable for this analysis. 3.1.3 Environmental Releases for 1-BP This case study provides information specific to the 1-BP fenceline environmental release analysis that is not captured in the general methodology described in Section 2.1.1. 3.1.3.1 Step 1: Obtain 2019 TRI Data For 1-BP, the 2019 TRI dataset used for this fenceline analysis includes a total of 59 sites that reported stack and fugitive air releases ( 21). These data include nine Form A submissions and 50 Form R submissions. 3.1.3.2 Step 2: Map 2019 TRI to OES EPA followed the methodology described in Section 2.1.1.2 to map the facilities in 2019 TRI to the OES in the published 1-BP Risk Evaluation ( 020b) (see Appendix E). However, there were a few deviations from this general methodology that EPA encountered during the mapping of 1-BP 2019 TRI sites to OES, which are described below. • The 1-BP Risk Evaluation is unique in that it makes a distinction between the "Import" and "Repackaging" OES, even though the "Import" OES is expected to also include repackaging operations (U.S. EPA. 2020b). The mapping of the 2019 TRI data to the "Import" and "Repackaging" OES was based largely on the mapping of 2018 TRI ( 2019b). 2016 TRI ( ), and preliminary 2017 TRI ( 2020a) data to OES. The assignment of these OES was also informed in part by 2016 CDR (1 c. « i1 \ JO 16b). • The 2019 TRI data for 1-BP includes many sites that report the TRI uses/sub-uses for "Ancillary or Other use - Cleaner" and "Ancillary or Other use - Degreaser" ( '21). EPA was unable to determine the specific types of cleaning or degreasing from the TRI uses/sub-uses, NAICS codes, or internet searches of the facilities. Therefore, for these facilities, EPA assigned the OES as "Degreasing (Batch Vapor Degreaser (Open-Top); Batch Vapor Degreaser (Closed- Page 63 of 204 ------- 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 Public Comment Draft - Do Not Cite of Quote Loop); In-Line Vapor Degreaser (Conveyorized); Cold Cleaner." This OES designation is a grouping of the following COUs from the 1-BP Risk Evaluation: Batch Vapor Degreaser (Open- Top), Batch Vapor Degreaser (Closed-Loop), In-Line Vapor Degreaser (Conveyorized), and Cold Cleaner. EPA did not include the OES for Aerosol Spray Degreaser/Cleaner, Dry Cleaning, or Spot Cleaner/Stain Remover in this grouping because facilities conducting these types of cleaning and degreasing are not expected to be captured in TRI because they likely use 1-BP at quantities below the reporting threshold or do not use a NAICS code that is included in a TRI- covered industry sector. • There were multiple sites in the 1-BP 2019 TRI data set that initially mapped to the COU for "Functional fluids (closed systems) - refrigerant" ( 1021). However, upon review of NAICS codes and research into these facilities, EPA determined that the COU for "Functional fluids (open system) - cutting oils" was more appropriate because these facilities produce fabricated metal products. The use of 1-BP in metalworking fluids at quantities that would trigger TRI reporting is much more likely than the use of 1-BP in refrigerant flushes at these types of sites. • One facility reported the TRI use/sub-use for "Processing: Repackaging"; however, this facility reported the NAICS code 562211, Hazardous Waste Treatment and Disposal ( ?21). Based on the NAICS code, EPA assigned the "Disposal and Recycling" OES. An additional site reported the TRI use/sub-use of "Ancillary or other use as a fuel" and the NAICS code 327310, Cement Manufacturing. Because 1-BP is not typically used in cement manufacturing, EPA interpreted this as the combustion of 1-BP in an incineration process with energy recovery, which is covered in the "Disposal and Recycling" OES ( >21). The 1-BP fenceline analysis spreadsheet, SF FLA Environmental Releases to Ambient Air for 1-BP (Appendix B), contains the rationale for the mapping of each facility in 2019 TRI to an OES. Refer to this spreadsheet for details of the mapping at the facility-level. 3.1.3.3 Step 3: Estimate Number of Release Days for Each OES EPA estimated the number of release days for each 1-BP OES according to the methodology in Section 2.1.1.3. Specifically, the number of release days was assumed to be equal to the number of operating days, which were estimated for each OES as shown in Table 3-3. Table 3-3. Number of Release Days for Each 1-BP OES OES Number of Release Days (days/year) Basis for Number of Release Days Manufacture 350 Number of release days for "Manufacture of Solvents" discussed in Section 2.1.1.3 Import 250 Number of release days for "All Other Scenarios" Processing as a Reactant 350 Number of release days for "Processing as a Reactant" Processing - Incorporation into Formulation, Mixture, or Reaction Product 300 Number of release days for "Other Chemical Plant Scenarios" Processing - Incorporation into Articles 250 Number of release days for "All Other Scenarios" Repackaging 250 Number of release days for "All Other Scenarios" Page 64 of 204 ------- Public Comment Draft - Do Not Cite of Quote Number of OES Release Days (days/year) Basis for Number of Release Days Degreasing, which includes the following 260 Vapor Decreasing ESD (Organization for OES: Economic and Develop.m.eni 2017) Batch Vapor Degreasing (Open-Top) Batch Vapor Degreasing (Closed-Loop) In-line Vapor Degreasing (Conveyorized) Cold Cleaning Aerosol Spray Degreaser/Cleaner 260 (low-end) and 364 (high- end) Brake Servicing Near-Field/Far-Field Inhalation Exposure Model Dry Cleaning 250 (low-end) and 312 (high- end) Dry Cleaning Multi-Zone Inhalation Exposure Model Spot Cleaner/Stain Remover 289 (50th Spot Cleaning Near-Field/Far-Field Inhalation percentile) and Exposure Model 307 (95th percentile) Spray Adhesives 260 Based on 5 days/week and 52 weeks/year per literature (Trinitv Consultants, 2015) THERMAX Installation N/A Ambient air release estimates are not provided for this OES because it is specific to occupational and consumer exposures resulting from off-gassing of 1-BP from the installed product and not expected to result in exposure to fenceline communities. Other Uses - Cutting Oils 250 Number of release days for "All Other Scenarios" Other Uses - Asphalt Extraction 250 Number of release days for "All Other Scenarios" Disposal and Recycling 250 Number of release days for "All Other Scenarios" 101 3.1.3.4 Step 4: Estimate Air Emissions for OES with No TRI Data 102 A summary of the air release assessment approaches for each 1-BP OES is included in Table 3-4. Of the 103 15 OES listed in in Table 3-4, 7 have directly applicable 2019 TRI data that were used. For the 104 remaining eight OES without 2019 TRI data, EPA used the hierarchy of alternate air assessment 105 approaches described in Section 2.1.1.4. Specifically, EPA estimated air releases with past years' TRI 106 data for three OES, modeling for two OES, literature values for one OES, and a combination of 107 modeling and literature values for one OES. Air estimates are not required for the remaining one OES. 108 Page 65 of 204 ------- Public Comment Draft - Do Not Cite of Quote Table 3-4. Summary of Air Release Estimation Approaches for Eac ti 1-BP OES OES Range of Annual Fugitive Air Release (kg/site-yr) Range of Annual Stack Air Release (kg/site-yr) Air Release Estimation Approach Notes Manufacture 227 to 3,04^ 227to2,307/g 2019 TRI (U.S. EPA. 2021) 2019 TRI data are available for two sites (one Form A). Import 227 (same for all sites)" 227 (same for all sites)" 2019 TRI (U.S. EPA. 2021) 2019 TRI data are available for four sites (all Form As). Processing as a Reactant 635 (same for all years/ 1.36 to 2.72^ Past years' TRI data (U.S. EPA. 2020a. 2019b. 2017) 2019 TRI data are not available for this OES. However, one site reported use of 1-BP as a reactant in 2016 through 2018 TRI (this site did not report for 1-BP in 2019 TRI). Because only three data points are available, EPA presented the central tendency (50th percentile) and maximum of these three years' data for fugitive and stack air releases for this site. Processing - Incorporation into Formulation, Mixture, or Reaction Product Oto l,105cde/* 0to340cde/g 2019 TRI (U.S. EPA. 2021) 2019 TRI data are available for 11 sites (three Form As). Processing - Incorporation into Articles 508 to 520® 943 to 974® Past years' TRI data (U.S. EPA. 2020a. 2019b. 2017) 2019 TRI data are not available for this OES. However, one site reported use of 1-BP for articles in 2016 through 2018 TRI (this site did not report for 1-BP in 2019 TRI). Because only three data points are available, EPA presented the central tendency (50th percentile) and maximum of these three years' data for fugitive and stack air releases for this site. Repackaging 88 (1 site)c 0 (1 site) 2019 TRI (U.S. EPA. 2021) 2019 TRI data are available for one site (not a Form A). Degreasing, which includes the following OES: Batch Vapor Degreasing (Open-Top), Batch Vapor Oto 53,319flcde/g 0to50,615flce/g 2019 TRI (U.S. EPA. 2021) 2019 TRI data are available for 34 sites (one Form A). Page 66 of 204 ------- Public Comment Draft - Do Not Cite of Quote OES Range of Annual Fugitive Air Release (kg/site-yr) Range of Annual Stack Air Release (kg/site-yr) Air Release Estimation Approach Notes Degreasing (Closed-Loop), In-line Vapor Degreasing (conveyorized), Cold Cleaning Aerosol Spray Degreaser/ Cleaner 277 (CT) to 377 (HE) 0 (all fugitive) Modeling 2019 TRI data and past years' TRI data are not available for this OES. EPA modeled air releases from this OES using the Brake Servicing Near-Field/Far-Field Inhalation Exposure Model. Dry Cleaning 57 to 1,294 0 (all fugitive) Literature (Trinity Consultants, 2015)and modeling (pending discussion with exposure assessors) 2019 TRI data and past years' TRI data are not available for this OES. 1-BP emission data are available in a Trinitv report (Trinity Consultants, 2015) for two companies (data are from 2014). The Trinity report is cited in the published 1-BP Risk Evaluation. EPA presented these emission data for each company, assuming the releases were entirely to fugitive air. The data available from the Trinity report were insufficient to calculate a 50th and 95th percentile, so the low-end and high-end values were presented. In addition to air releases for air modeling for fenceline communities, EPA required air release modeling for co-residence communities (people who live in a building with a dry cleaner on the ground floor) using the model for 3rd generation drv cleaning machines (U.S. EPA. 2020b). Spot Cleaner/ Stain Remover 75.3 (CT) to 80 (HE) 0 (all fugitive) Modeling 2019 TRI data and past years' TRI data are not available for this OES. EPA adapted the Spot Cleaning Model and ran it to estimate daily air emissions for this OES. Spray Adhesive s 0(1 site, all stack) 614 (1 site) Literature (Trinity 2019 TRI data and past years' TRI data are not available for this OES. Additionally, there are no current Page 67 of 204 ------- Public Comment Draft - Do Not Cite of Quote OES Range of Annual Fugitive Air Release (kg/site-yr) Range of Annual Stack Air Release (kg/site-yr) Air Release Estimation Approach Notes applicable modeling approaches for this OES. 1-BP emission data are available in the Trinity report (Trinity Consultants. 2015) for one company (data are from 2013). The Trinity report is cited in the published 1-BP Risk Evaluation. EPA presented these emission data, which the report indicates are entirely to stack air. 2015) THERMAX Installation N/A N/A N/A Ambient air release estimates are not provided for this OES because it is specific to occupational and consumer exposures resulting from off-gassing of 1-BP from the installed product and not expected to result in exposure to fenceline communities. Other Uses - Cutting Oils Oto 663bcf 0 to 201bf 2019 TRI (U.S. EPA. 2021) 2019 TRI data are available for five sites for use of 1-BP in functional fluids (open system) - cutting oils (no Form As). Other Uses - Asphalt Extraction 7,235 (1 site)6 9,862 (1 site)d Past years' TRI data (U.S. EPA. 2020a. 2019b. 2017) 2019 TRI data are not available for this OES. However, data are available for the asphalt extraction OES for one site in 2016 and 2017 TRI (this site did not report for 1-BP to 2018 or 2019 TRI). EPA presented these 2016 and 2017 TRI data for this one site. Note that for year 2016, these air releases were reported entirely to fugitive air, and for year 2017, these air releases were reported entirely to stack air. Disposal and Recycling 18.1 to29y 5.22 to 5.3\f 2019 TRI (U.S. EPA. 2021) 2019 TRI data are available for two sites (no Form A's). "This range includes estimates based on continuous monitoring data or measurements. h This range includes estimates based on periodic or random monitoring data or measurements . c This range includes estimates based on mass balance calculations, such as calculation of the amount in streams entering and leaving process equipment. ''This range includes estimates based on published emissions factors, such as those relating release quantity to through-put or equipment type (e.g., air emissions factors). '' This range includes estimates based on site-specific emissions factors, such as those relating release quantity to through- put or equipment type (e.g., air emissions factors). 'This range includes estimates based on other approaches such as engineering calculations (e.g., estimating volatilization using published mathematical formulas) or best engineering judgment. Page 68 of 204 ------- 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 133 134 135 136 Public Comment Draft - Do Not Cite of Quote OES Range of Annual Fugitive Air Release (kg/site-yr) Range of Annual Stack Air Release (kg/site-yr) Air Release Estimation Approach Notes v This range includes Form A submissions, for which EPA used the entire 500 1 release estimates; however, since this threshold is for total site releases, these 50C air for this analysis, not both. j/year for both the fugitive and stack air lb/year are either to fugitive air or stack 3.1.3.5 Step 5: Prepare Air Emission Summary for Ambient Air Exposure Modeling Using the work completed in Steps 1 through 4, EPA compiled a summary of air releases on a per-site basis for each 1-BP OES, in the format of Table 2-1. See the supplemental fenceline analysis spreadsheet SF FLA Environmental Releases to Ambient Air for 1-BP (Appendix B) for this summary. To model exposures resulting from these air emissions, EPA used the daily emissions, site identity and location information, and release duration and pattern information from this summary. Additional information on the modeled 1-BP exposures is provided in the next section. 3.1,4 Exposures for 1-BP All three fenceline exposure methodologies (pre-screening, screening, and co-resident screening) were utilized to evaluate potential exposures to fenceline communities for 1-BP. Pre-screening Analysis Pre-screening work for 1-BP is included in Appendix D. Inputs for all IIOAC model runs for all exposure scenarios are included in Supplemental File SF FLA Air Pathway Input Parameters for IIOAC for 1-BP andMC (Appendix B). Based on the pre-screening analysis, there is an indication of potential exposures and associated risks to fenceline communities and therefore EPA conducted a full- screening level analysis for 1-BP. Full-Screening Analysis A total of 14 OES were evaluated for 1-BP as presented in Table 3-5. A total of 59 real facilities and 5 surrogate facilities were modeled. Exposure modeling was also performed for those OES where releases were estimated, although there is no real facility associated with those estimates and therefore a "number of facilities" is not available for those OES. Inputs for all AERMOD model runs for all exposure scenarios are included in Supplemental File SF _FLA_Air Pathway Input Parameters for AERMOD for 1-BP andMC (Appendix B). Table 3-5. Fenceline Community Exposure Scenarios for 1-BP OES Release Data Source Number of Facilities in OES" Aerosol Spray Degreaser/Cleaner Estimate - Asphalt Extraction TRI (2016-2017) 1 surrogate Degreasing TRI (2019) 34 Dry-Cleaning Estimate - (2 surrogate) Processing into Formulation TRI 11 Import TRI 4 Page 69 of 204 ------- 137 138 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 157 158 159 160 161 162 163 164 165 Public Comment Draft - Do Not Cite of Quote OES Release Data Source Number of Facilities in OES" Processing-Incorporation into Articles TRI (2016-2018) 1 surrogate Manufacturing TRI 2 Other Uses - Cutting Oils TRI 5 Processing as Reactant TRI (2016-2018) 1 surrogate Recycling and Disposal TRI 2 Repackaging TRI 1 Spot Cleaner/Stain Remover Estimate - Spray Adhesives Estimate - Total 59 (+5 surrogate) a When (-) is indicated for the number of facilities in OES, no facilities were identified via TRI reporting. The provided estimates are based on modeling of theoretical facilities. Modeling results for inhalation exposure concentrations are categorized by OES and presented by facility. Daily and annual average concentrations are summarized for three percentile concentrations (10th, 50th, 95th) to cover the range of exposure concentrations across all nine distances modeled (5, 10, 30, 60, 100, 100 to 1,000, 2,500, 5,000, and 10,000 meters) and can be found in the Supplemental File SF _FLA_y4/> Pathway Full-Screen Results for 1-BP (Appendix B). Exposure concentrations are presented as a total concentration to inform the total exposure to a given receptor at each modeled distance from each releasing facility. EPA did not identify air monitoring data to which modeled concentrations could be compared at the distances modeled. EPA conducted a source attribution analysis which provides exposure concentrations from each release type (fugitive and stack) at each modeled distance for each facility in anticipation of informing future risk management actions and the potential need for a more detailed analysis if risks are identified. For facilities reporting both fugitive and stack releases within TRI, adding the exposure concentrations for each release type at each modeled distance provides the total concentration used for risk calculation purposes in this report. EPA further distilled exposure results for the 95th percentile values across all facilities within each OES, at all nine distances modeled, and is presenting them in Table 3-6. The purpose of this further distillation is to present a smaller subset of results within the body of this report. The further distilled results presented here are carried into the risk characterization section of the body of this report for risk calculation purposes. The minimum and maximum concentrations in Table 3-6 represent the lowest and highest 95th percentile concentrations, respectively, among all facilities categorized into the respective OES at each distance modeled. The mean 95th percentile concentrations in Table 3-6 represent arithmetic averages across all facilities within the given OES at each distance modeled. Additionally, for certain OES, there are a variety of industry types and release points (stack, fugitive, stack, and fugitive) categorized within an OES which may not be directly comparable. This results in a wide range of modeled exposure Page 70 of 204 ------- 166 167 168 169 170 171 172 173 174 175 176 111 178 179 180 Public Comment Draft - Do Not Cite of Quote concentrations which, in some cases, extends over many orders of magnitude. For example, in the degreaser OES, there are 34 facilities that may include open-top degreasers, batch degreasers, closed- loop degreasers, and others. Although releases within an industry type may be comparable, releases across industry types may have considerably different emission profiles and therefore may not be comparable. Further, looking at the release points, EPA found that fugitive releases do not have much lift or dispersion resulting in higher concentrations very near facilities (around 10 meters) and lower concentrations around 100 meters. In contrast, stack releases often have more lift and dispersion resulting in lower concentrations around 10 meters and higher concentrations around 100 meters. Even with these different concentration profiles, the modeled exposure concentrations from stacks are still several orders of magnitude lower than fugitive concentrations. This can skew the mean of the 95th percentile modeled concentrations across multiple facilities orders of magnitude lower, thus underestimating exposures and associated risks. Page 71 of 204 ------- Public Comment Draft - Do Not Cite of Quote 1 Table 3-6. 95th Percentile Exposure Concentration Summary across Facilities within Each PES for 1-BP OES" Number of TRI Facilities Evaluated h Distance from Facility (meters) Concentration (ppm) Daily Average Annual Average Single Facility Minimum Arithmetic Mean Maximum Single Facility Minimum Arithmetic Mean Maximum Aerosol Spray Degreaser/ Cleaner 5 3.92E-03 6.70E-03 9.91E-03 8.11E-04 1.83E-03 3.08E-03 10 6.91E-03 9.65E-03 1.27E-02 1.47E-03 2.57E-03 3.88E-03 30 2.81E-03 3.39E-03 3.97E-03 5.83E-04 8.13E-04 1.08E-03 60 9.54E-04 1.17E-03 1.40E-03 2.12E-04 2.78E-04 3.49E-04 100 3.55E-04 4.42E-04 5.40E-04 8.30E-05 1.06E-04 1.30E-04 100-1,000 9.22E-06 1.11E-05 1.31E-05 5.61E-06 6.93E-06 8.22E-06 2,500 3.49E-07 4.24E-07 5.07E-07 8.65E-08 1.29E-07 2.10E-07 5,000 9.58E-08 1.19E-07 1.41E-07 2.40E-08 3.97E-08 6.78E-08 10,000 3.08E-08 4.44E-08 5.88E-08 1.04E-08 1.64E-08 2.69E-08 Asphalt Extraction 1 5 7.59E-02 2.88E-02 10 1.57E-01 6.77E-02 30 8.57E-02 3.73E-02 60 3.71E-02 1.62E-02 100 1.92E-02 8.46E-03 100-1,000 1.62E-03 8.43E-04 2,500 1.72E-04 6.39E-05 5,000 5.89E-05 2.13E-05 10,000 1.98E-05 7.04E-06 Page 72 of 204 ------- Public Comment Draft - Do Not Cite of Quote Concentration (ppm) OES" Number of TRI Facilities Distance from Facility Daily Average Annual Average Evaluated h (meters) Single Facility Minimum Arithmetic Mean Maximum Single Facility Minimum Arithmetic Mean Maximum 5 1.79E-12 1.96E-01 1.79E+00 3.19E-11 6.69E-02 6.53E-01 10 3.29E-10 2.46E-01 2.13E+00 2.16E-09 8.50E-02 8.23E-01 30 2.12E-06 8.27E-02 6.43E-01 5.21E-07 2.69E-02 2.42E-01 60 1.48E-05 3.08E-02 2.28E-01 5.60E-06 9.74E-03 8.32E-02 Degreasing 34 100 3.15E-05 1.37E-02 9.53E-02 1.26E-05 4.27E-03 3.48E-02 100-1,000 7.13E-06 8.41E-04 5.30E-03 4.20E-06 4.52E-04 3.01E-03 2,500 1.04E-06 7.27E-05 4.09E-04 3.25E-07 2.10E-05 1.42E-04 5,000 5.01E-07 2.58E-05 1.62E-04 1.39E-07 7.37E-06 4.62E-05 10,000 1.99E-07 9.20E-06 6.93E-05 6.25E-08 2.77E-06 1.82E-05 5 7.10E-04 9.66E-03 3.73E-02 1.59E-04 2.99E-03 1.37E-02 10 1.22E-03 1.32E-02 4.55E-02 2.91E-04 4.18E-03 1.71E-02 30 5.89E-04 5.25E-03 1.64E-02 1.37E-04 1.54E-03 5.80E-03 60 2.27E-04 2.07E-03 6.68E-03 5.15E-05 5.85E-04 2.26E-03 Dry Cleaning - 100 9.85E-05 9.01E-04 2.97E-03 2.22E-05 2.60E-04 1.04E-03 100-1,000 4.95E-06 4.40E-05 1.46E-04 2.40E-06 2.80E-05 1.05E-04 2,500 2.54E-07 2.49E-06 7.81E-06 7.54E-08 1.30E-06 5.44E-06 5,000 6.92E-08 7.08E-07 2.18E-06 2.50E-08 4.27E-07 1.90E-06 10,000 2.29E-08 2.31E-07 7.20E-07 8.61E-09 1.44E-07 6.63E-07 Page 73 of 204 ------- Public Comment Draft - Do Not Cite of Quote Concentration (ppm) OES" Number of TRI Facilities Distance from Facility Daily Average Annual Average Evaluated h (meters) Single Facility Minimum Arithmetic Mean Maximum Single Facility Minimum Arithmetic Mean Maximum 5 2.41E-11 5.73E-03 2.55E-02 2.20E-11 2.29E-03 1.17E-02 10 7.63E-10 7.28E-03 3.87E-02 8.07E-10 3.02E-03 1.62E-02 30 4.22E-07 2.91E-03 1.83E-02 1.50E-07 1.22E-03 8.04E-03 60 6.70E-06 1.19E-03 7.80E-03 2.47E-06 4.95E-04 3.41E-03 Processing into Formulation 11 100 1.72E-05 5.78E-04 3.84E-03 6.01E-06 2.38E-04 1.67E-03 100-1,000 5.57E-06 4.67E-05 3.06E-04 2.70E-06 2.59E-05 1.72E-04 2,500 6.54E-07 4.23E-06 2.49E-05 2.01E-07 1.46E-06 8.93E-06 5,000 2.51E-07 1.54E-06 8.55E-06 7.63E-08 5.06E-07 2.89E-06 10,000 8.70E-08 5.59E-07 2.95E-06 2.82E-08 1.78E-07 9.46E-07 5 7.82E-16 2.92E-03 7.09E-03 3.06E-13 6.37E-04 1.56E-03 10 9.90E-12 4.41E-03 1.03E-02 2.98E-10 8.76E-04 1.95E-03 30 1.03E-06 1.46E-03 3.12E-03 3.52E-07 2.55E-04 5.72E-04 60 2.64E-05 4.91E-04 9.90E-04 6.52E-06 8.81E-05 1.89E-04 Import 4 100 5.65E-05 2.02E-04 3.62E-04 1.28E-05 3.78E-05 6.86E-05 100-1,000 5.59E-06 6.37E-06 7.38E-06 3.40E-06 4.12E-06 5.23E-06 2,500 1.53E-07 1.94E-07 2.40E-07 5.54E-08 6.41E-08 7.61E-08 5,000 1.69E-08 3.94E-08 6.55E-08 1.76E-08 2.17E-08 2.76E-08 10,000 1.57E-09 1.04E-08 1.92E-08 7.86E-09 1.01E-08 1.32E-08 Page 74 of 204 ------- Public Comment Draft - Do Not Cite of Quote OES" Number of TRI Facilities Evaluated h Distance from Facility (meters) Concentration (ppm) Daily Average Annual Average Single Facility Minimum Arithmetic Mean Maximum Single Facility Minimum Arithmetic Mean Maximum Processing- Incorporation into Articles 1 5 1.86E-02 5.03E-03 10 1.99E-02 5.52E-03 30 6.36E-03 1.74E-03 60 2.48E-03 6.73E-04 100 1.18E-03 3.26E-04 100-1,000 1.12E-04 5.39E-05 2,500 1.26E-05 3.07E-06 5,000 4.44E-06 1.04E-06 10,000 1.51E-06 3.50E-07 Manufacturing 2 5 2.86E-10 3.87E-02 1.08E-01 1.86E-10 1.45E-02 4.06E-02 10 4.80E-09 5.19E-02 1.45E-01 1.70E-09 1.96E-02 5.48E-02 30 9.30E-07 1.82E-02 5.08E-02 2.44E-07 7.48E-03 2.09E-02 60 1.01E-05 7.45E-03 2.08E-02 3.95E-06 3.00E-03 8.39E-03 100 2.30E-05 3.52E-03 9.83E-03 8.94E-06 1.41E-03 3.94E-03 100-1,000 7.95E-06 2.89E-04 8.03E-04 3.83E-06 1.67E-04 4.65E-04 2,500 2.02E-06 2.69E-05 7.45E-05 6.55E-07 8.86E-06 2.46E-05 5,000 9.75E-07 1.05E-05 2.91E-05 2.94E-07 3.16E-06 8.75E-06 10,000 4.41E-07 4.08E-06 1.13E-05 1.27E-07 1.15E-06 3.17E-06 Page 75 of 204 ------- Public Comment Draft - Do Not Cite of Quote Concentration (ppm) OES" Number of TRI Facilities Distance from Facility Daily Average Annual Average Evaluated h (meters) Single Facility Minimum Arithmetic Mean Maximum Single Facility Minimum Arithmetic Mean Maximum 5 7.89E-10 8.32E-03 3.81E-02 4.38E-07 3.63E-03 1.69E-02 10 1.47E-06 8.53E-03 3.66E-02 2.68E-06 4.16E-03 1.87E-02 30 4.13E-05 2.75E-03 1.10E-02 1.12E-05 1.36E-03 5.91E-03 60 1.76E-05 1.04E-03 4.04E-03 8.44E-06 5.12E-04 2.18E-03 Other Uses - Cutting Oil 5 100 8.84E-06 4.76E-04 1.79E-03 4.20E-06 2.32E-04 9.73E-04 100-1,000 7.59E-07 3.29E-05 1.19E-04 4.36E-07 2.04E-05 7.81E-05 2,500 7.33E-08 2.68E-06 9.11E-06 2.78E-08 1.17E-06 4.51E-06 5,000 2.99E-08 8.98E-07 3.04E-06 1.04E-08 3.79E-07 1.44E-06 10,000 1.20E-08 3.05E-07 1.04E-06 3.95E-09 1.23E-07 4.65E-07 5 9.90E-03 3.61E-03 10 1.43E-02 5.66E-03 30 6.10E-03 2.30E-03 60 2.49E-03 9.16E-04 Processing as Reactant 1 100 1.16E-03 4.26E-04 100-1,000 8.19E-05 5.03E-05 2,500 6.45E-06 1.94E-06 5,000 2.13E-06 6.35E-07 10,000 7.07E-07 2.10E-07 Page 76 of 204 ------- Public Comment Draft - Do Not Cite of Quote Concentration (ppm) OES" Number of TRI Facilities Distance from Facility Daily Average Annual Average Evaluated h (meters) Single Facility Minimum Arithmetic Mean Maximum Single Facility Minimum Arithmetic Mean Maximum 5 2.68E-04 3.90E-04 5.11E-04 7.19E-05 1.05E-04 1.38E-04 10 5.00E-04 7.00E-04 8.99E-04 1.48E-04 1.93E-04 2.37E-04 30 2.64E-04 3.61E-04 4.57E-04 7.50E-05 9.65E-05 1.18E-04 60 1.09E-04 1.52E-04 1.95E-04 3.02E-05 3.94E-05 4.86E-05 Recycling and Disposal 2 100 5.43E-05 7.50E-05 9.57E-05 1.42E-05 1.91E-05 2.39E-05 100-1,000 3.88E-06 5.53E-06 7.18E-06 1.82E-06 2.63E-06 3.44E-06 2,500 3.53E-07 4.88E-07 6.22E-07 7.26E-08 1.05E-07 1.38E-07 5,000 1.15E-07 1.63E-07 2.11E-07 2.42E-08 3.51E-08 4.60E-08 10,000 3.88E-08 5.30E-08 6.72E-08 8.20E-09 1.19E-08 1.55E-08 5 2.69E-03 6.19E-04 10 3.84E-03 8.12E-04 30 1.24E-03 2.32E-04 60 3.96E-04 7.48E-05 Repackaging 1 100 1.42E-04 2.73E-05 100-1,000 2.79E-06 1.82E-06 2,500 6.84E-08 3.62E-08 5,000 1.04E-08 1.40E-08 10,000 1.22E-09 7.11E-09 Page 77 of 204 ------- Public Comment Draft - Do Not Cite of Quote OES" Number of TRI Facilities Evaluated h Distance from Facility (meters) Concentration (ppm) Daily Average Annual Average Single Facility Minimum Arithmetic Mean Maximum Single Facility Minimum Arithmetic Mean Maximum Spot Cleaner/Stain Remover - 5 1.03E-03 1.54E-03 2.03E-03 2.12E-04 4.41E-04 6.74E-04 10 1.84E-03 2.25E-03 2.64E-03 3.94E-04 6.27E-04 8.66E-04 30 7.58E-04 8.00E-04 8.40E-04 1.60E-04 2.01E-04 2.43E-04 60 2.58E-04 2.77E-04 2.98E-04 5.89E-05 6.90E-05 7.89E-05 100 9.61E-05 1.05E-04 1.14E-04 2.35E-05 2.66E-05 2.95E-05 100-1,000 2.55E-06 2.74E-06 2.93E-06 1.67E-06 1.82E-06 2.08E-06 2,500 9.40E-08 1.04E-07 1.17E-07 2.52E-08 3.37E-08 4.60E-08 5,000 2.77E-08 2.92E-08 3.15E-08 6.85E-09 1.02E-08 1.48E-08 10,000 9.60E-09 1.10E-08 1.22E-08 2.82E-09 4.02E-09 5.59E-09 Spray Adhesives - 5 1.68E-11 5.01E-11 10 1.66E-08 6.42E-09 30 9.56E-06 2.48E-06 60 7.33E-05 2.35E-05 100 1.33E-04 4.34E-05 100-1,000 1.63E-05 1.03E-05 2,500 8.95E-07 2.90E-07 5,000 3.58E-07 1.11E-07 10,000 1.62E-07 5.08E-08 Page 78 of 204 ------- Public Comment Draft - Do Not Cite of Quote OESa Number of TRI Facilities Evaluated h Distance from Facility (meters) Concentration (ppm) Daily Average Annual Average Single Facility Minimum Arithmetic Mean Maximum Single Facility Minimum Arithmetic Mean Maximum " Thermax Installation was not evaluated for general population exposure as it is an indoor installation activity and EPA does not expect general population exposure to occur from such activity. Thermax Installation was evaluated for occupational and consumer exposure as a condition of use in the 2020 published risk evaluation for 1-BP. h When (-) is indicated for the total number of facilities, no facilities were identified via TRI reporting. The provided estimates are based on modeling of theoretical facilities. 2 3 4 Page 79 of 204 ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Public Comment Draft - Do Not Cite of Quote Co-resident Analysis EPA evaluated one OES (dry-cleaning) using the co-resident screening methodology. Site specific emission data was not identified for dry-cleaners using 1-BP so far-field indoor air concentrations within the dry-cleaner shop were modeled, and estimated emission rates were for third generation dry-cleaning machines. For this work, all emissions from dry cleaning activities are assumed to be fugitive emissions. EPA considered both dry-cleaning and spot-cleaning operations for 1-BP. Estimated emission rates were provided for nine emission scenarios, representing a variety of operational scales, conditions, and source strengths. Exposure scenarios include two building configurations, each with two different methods for estimating Q12, resulting in a total of 36 exposure scenarios which were modeled with IECCU. Table 3-7 provides a summary of the 36 exposure scenarios evaluated for 1-BP co-resident analysis. Inputs for all IECCU model runs for all exposure scenarios are included in Supplemental File SF FLA Air Pathway Information for Co-Resident Exposure Modeling for 1-BP (Appendix B). Table 3-7. Simulation Matrix for Evaluating Co-resident Exposures from Dry-Cleaning Operations (IECCU) for 1-BP Serial No. Building Type Method for Estimating Q12 1-BP Emission Scenario Model File Name 1 1 01-B1-M1-S1.IEC 2 2 02-B1-M1-S2.IEC 3 3 03-B1-M1-S3.IEC 4 4 04-B1-M1-S4.IEC 5 Method 1 - Literature (monitored) 5 05-B1-M1-S5.IEC 6 6 06-B1-M1-S6.IEC 7 7 07-B1-M1-S7.IEC 8 8 08-B1-M1-S8.IEC 9 B1 -Two zones - 9 09-B1-M1-S9.IEC 10 architecturally separated 1 10-B1-M2-S1.IEC 11 2 11-B1-M2-S2.IEC 12 3 12-B1-M2-S3.IEC 13 4 13-B1-M2-S4.IEC 14 Method 2 - Stack effect 5 14-B1-M2-S5.IEC 15 6 15-B1-M2-S6.IEC 16 7 16-B1-M2-S7.IEC 17 8 17-B1-M2-S8.IEC 18 9 18-B1-M2-S9.IEC Page 80 of 204 ------- Public Comment Draft - Do Not Cite of Quote Serial No. Building Type Method for Estimating Q12 1-BP Emission Scenario Model File Name 19 1 19-B2-M3-S1.IEC 20 2 20-B2-M3-S2.IEC 21 3 21-B2-M3-S3.IEC 22 4 22-B2-M3-S4.IEC 23 Method 3 -Literature (recommended) 5 23-B2-M3-S5.IEC 24 6 24-B2-M3-S6.IEC 25 7 25-B2-M3-S7.IEC 26 8 26-B2-M3-S8.IEC 27 B2 - Two zones - architecturally inter- 9 27-B2-M3-S9.IEC 28 connected 1 28-B2-M4-S1 IEC 29 2 29-B2-M4-S2.IEC 30 3 30-B2-M4-S3.IEC 31 4 31-B2-M4-S4.IEC 32 Method 4 - HVAC Recirculation Rate 5 32-B2-M4-S5 IEC 33 6 33-B2-M4-S6.IEC 34 7 34-B2-M4-S7.IEC 35 8 35-B2-M4-S8.IEC 36 9 36-B2-M4-S9.IEC 18 19 The maximum and central tendency unadjusted 24-hour TWA and adjusted annual TWA predicted 1-BP 20 concentrations from IECCU are summarized in Table 3-8. All exposure concentrations and associated 21 calculated TWA values for all IECCU model runs for all exposure scenarios are included in 22 Supplemental File SFFLA^//' Pathway Information for Co-Resident Exposure Modeling for 1-BP 23 (Appendix B). 24 Page 81 of 204 ------- 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Public Comment Draft - Do Not Cite of Quote Table 3-8. Predicted 1-B ' Concentrations for Co-resident Apartment Building Configuration Method for Estimating Q12 Predicted 1-BP Concentrations (ppm) Unadjusted 24-hour TWA Adjusted Annual TWA High End Central Tendency High End Central Tendency B1 Method 1 (Qi2= 0.822 m3/hr) 0.10 0.02 0.09 0.02 Method 2 (Q12 = 3.39 m3/hr) 0.42 0.07 0.36 0.06 B2 Method 3 (Q12 =134 m3/hr) 5.15 1.16 4.41 0.95 Method 4 (Q12 = 1,960 m3/hr) 5.16 1.35 4.41 1.11 3,1,5 Risk Characterization for 1-BP 3.1.5.1 Fenceline Inhalation Risk for 1-BP EPA calculated risk estimates for each of the endpoints in Table 3-2 across all known TRI reporters and other modeled facilities under each OES. EPA calculated risk estimates for each facility using the 10th, 50th, and 95th percentile of modeled exposure concentrations around the releasing facility. The 95th percentile estimates were then further distilled across facilities within a given OES to present the range from minimum to maximum risk. Based on the 95th percentile values, risks were indicated for at least one facility relative to benchmarks for 13 of 14 OES. Risks were not indicated for any OES beyond 1,000 m from a facility. These results are summarized below in Table 3-9. Results for 10th and 50th percentile measurements along with facility-specific results are provided in SFFLA^//' Pathway Full-Screen Results for 1-BP (Appendix B). Page 82 of 204 ------- Public Comment Draft - Do Not Cite of Quote 1 Table 3-9.1-BP Inhalation Risk across OES at Various Distances from Releasing Facility (Based on 95th Percentile Exposure 2 Concentrations) Occupational Exposure Scenario Number of TRI Facilities Distance from Facility (meters) Estimated MOE Estimated Cancer Risk Non-cancer Cancer (Benchmark 1E-06) Acute (Benchmark 100) Chronic (Benchmark 100) Total" w/ Risk Single Facility Min Risk* Mean Riskc Max Risk'' Single Facility Min Risk Mean Risk Max Risk Single Facility Min Risk Mean Risk Max Risk Aerosol Spray Degreaser/ Cleaner 5 N/A 1,531 895 605 N/A 7,398 3,271 1,948 N/A 4.9E-06 1.1E-05 1.8E-05 10 N/A 868 622 472 N/A 4,082 2,337 1,546 N/A 8.8E-06 1.5E-05 2.3E-05 30 N/A 2,135 1,771 1,511 N/A 1.0E+04 7,377 5,556 N/A 3.5E-06 4.9E-06 6.5E-06 60 N/A 6,289 5,131 4,286 N/A 2.8E+04 2.2E+04 1.7E+04 N/A 1.3E-06 1.7E-06 2.1E-06 100 N/A 1.7E+04 1.4E+04 1.1E+04 N/A 7.2E+04 5.7E+04 4.6E+04 N/A 5.0E-07 6.4E-07 7.8E-07 100-1,000 N/A 6.5E+05 5.4E+05 4.6E+05 N/A 1.1E+06 8.7E+05 7.3E+05 N/A 3.4E-08 4.2E-08 4.9E-08 2,500 N/A 1.7E+07 1.4E+07 1.2E+07 N/A 6.9E+07 4.7E+07 2.9E+07 N/A 5.2E-10 7.7E-10 1.3E-09 5,000 N/A 6.3E+07 5.1E+07 4.3E+07 N/A 2.5E+08 1.5E+08 8.8E+07 N/A 1.4E-10 2.4E-10 4.1E-10 10,000 N/A 1.9E+08 1.4E+08 1.0E+08 N/A 5.8E+08 3.7E+08 2.2E+08 N/A 6.2E-11 9.8E-11 1.6E-10 Asphalt Extraction 1 1 5 79 - - - 208 - - - 1.7E-04 10 38 - - - 89 - - - 4.1E-04 30 70 - - - 161 - - - 2.2E-04 60 162 - - - 370 - - - 9.7E-05 100 313 - - - 709 - - - 5.1E-05 100-1,000 3,704 - - - 7,117 - - - 5.1E-06 2,500 3.4E+3 - - - 9.4E+04 - - - 3.8E-07 5,000 1.0E+05 - - - 2.8E+05 - - - 1.3E-07 10,000 3.0E+05 - - - 8.5E+05 - - - 4.2E-08 Degreasing 34 30 5 N/A 3.4E+12 31 3 N/A 1.9E+11 90 9 N/A 1.9E-13 4.0E-04 3.9E-03 10 N/A 1.8E+10 24 3 N/A 2.8E+09 71 7 N/A 1.3E-11 5.1E-04 4.9E-03 30 N/A 2.8E+06 73 9 N/A 1.2E+07 223 25 N/A 3.1E-09 1.6E-04 1.5E-03 60 N/A 4.1E+05 195 26 N/A 1.1E+06 616 72 N/A 3.4E-08 5.8E-05 5.0E-04 100 N/A 1.9E+05 438 63 N/A 4.8E+05 1,404 172 N/A 7.6E-08 2.6E-05 2.1E-04 100-1,000 N/A 8.4E+05 7,134 1,132 N/A 1.4E+06 1.3E+04 1,993 N/A 2.5E-08 2.7E-06 1.8E-05 2,500 N/A 5.8E+06 8.3E+04 1.5E+04 N/A 1.8E+07 2.9E+05 4.2E+04 N/A 2.0E-09 1.3E-07 8.5E-07 5,000 N/A 1.2E+07 2.3E+05 3.7E+04 N/A 4.3E+07 8.1E+05 1.3E+05 N/A 8.3E-10 4.4E-08 2.8E-07 Page 83 of 204 ------- Public Comment Draft - Do Not Cite of Quote Occupational Exposure Scenario Number of TRI Facilities Distance from Facility (meters) Estimated MOE Estimated Cancer Risk Non-cancer Cancer (Benchmark 1E-06) Acute (Benchmark 100) Chronic (Benchmark 100) Total" w/ Risk Single Facility Min Risk* Mean Riskc Max Risk'' Single Facility Min Risk Mean Risk Max Risk Single Facility Min Risk Mean Risk Max Risk 10,000 N/A 3.0E+07 6.5E+05 8.7E+04 N/A 9.6E+07 2.2E+06 3.3E+05 N/A 3.8E-10 1.7E-08 1.1E-07 Dry Cleaning 5 N/A 8,451 621 161 N/A 3.8E+04 2,004 438 N/A 9.5E-07 1.8E-05 8.2E-05 10 N/A 4,918 456 132 N/A 2.1E+04 1,434 351 N/A 1.7E-06 2.5E-05 1.0E-04 30 N/A 1.0E+04 1,143 366 N/A 4.4E+04 3,886 1,034 N/A 8.2E-07 9.3E-06 3.5E-05 60 N/A 2.6E+04 2,903 898 N/A 1.2E+05 1.0E+04 2,655 N/A 3.1E-07 3.5E-06 1.4E-05 100 N/A 6.1E+04 6,659 2,020 N/A 2.7E+05 2.3E+04 5,769 N/A 1.3E-07 1.6E-06 6.2E-06 100-1,000 N/A 1.2E+06 1.4E+05 4.1E+04 N/A 2.5E+06 2.1E+05 5.7E+04 N/A 1.4E-08 1.7E-07 6.3E-07 2,500 N/A 2.4E+07 2.4E+06 7.7E+05 N/A 8.0E+07 4.6E+06 1.1E+06 N/A 4.5E-10 7.8E-09 3.3E-08 5,000 N/A 8.7E+07 8.5E+06 2.8E+06 N/A 2.4E+08 1.4E+07 3.2E+06 N/A 1.5E-10 2.6E-09 1.1E-08 10,000 N/A 2.6E+08 2.6E+07 8.3E+06 N/A 7.0E+08 4.2E+07 9.0E+06 N/A 5.2E-11 8.6E-10 4.0E-09 Processing into Formulation 11 9 5 N/A 2.5E+11 1,048 235 N/A 2.7E+11 2,617 513 N/A 1.3E-13 1.4E-05 7.0E-05 10 N/A 7.9E+09 824 155 N/A 7.4E+09 1,986 370 N/A 4.8E-12 1.8E-05 9.7E-05 30 N/A 1.4E+07 2,063 328 N/A 4.0E+07 4,912 746 N/A 9.0E-10 7.3E-06 4.8E-05 60 N/A 9.0E+05 5,046 769 N/A 2.4E+06 1.2E+04 1,760 N/A 1.5E-08 3.0E-06 2.0E-05 100 N/A 3.5E+05 1.0E+04 1,563 N/A 1.0E+06 2.5E+04 3,593 N/A 3.6E-08 1.4E-06 1.0E-05 100-1,000 N/A 1.1E+06 1.3E+05 2.0E+04 N/A 2.2E+06 2.3E+05 3.5E+04 N/A 1.6E-08 1.6E-07 1.0E-06 2,500 N/A 9.2E+06 1.4E+06 2.4E+05 N/A 3.0E+07 4.1E+06 6.7E+05 N/A 1.2E-09 8.7E-09 5.4E-08 5,000 N/A 2.4E+07 3.9E+06 7.0E+05 N/A 7.9E+07 1.2E+07 2.1E+06 N/A 4.6E-10 3.0E-09 1.7E-08 10,000 N/A 6.9E+07 1.1E+07 2.0E+06 N/A 2.1E+08 3.4E+07 6.3E+06 N/A 1.7E-10 1.1E-09 5.7E-09 Import 4 4 5 N/A 7.7E+15 2,054 846 N/A 2.0E+13 9,417 3,846 N/A 1.8E-15 3.8E-06 9.4E-06 10 N/A 6.1E+11 1,361 583 N/A 2.0E+10 6,847 3,077 N/A 1.8E-12 5.3E-06 1.2E-05 30 N/A 5.8E+06 4,108 1,923 N/A 1.7E+07 2.4E+04 1.0E+04 N/A 2.1E-09 1.5E-06 3.4E-06 60 N/A 2.3E+05 1.2E+04 6,061 N/A 9.2E+05 6.8E+04 3.2E+04 N/A 3.9E-08 5.3E-07 1.1E-06 100 N/A 1.1E+05 3.0E+04 1.7E+04 N/A 4.7E+05 1.6E+05 8.7E+04 N/A 7.7E-08 2.3E-07 4.1E-07 100-1,000 N/A 1.1E+06 9.4E+05 8.1E+05 N/A 1.8E+06 1.5E+06 1.1E+06 N/A 2.0E-08 2.5E-08 3.1E-08 2,500 N/A 3.9E+07 3.1E+07 2.5E+07 N/A 1.1E+08 9.4E+07 7.9E+07 N/A 3.3E-10 3.8E-10 4.6E-10 5,000 N/A 3.6E+08 1.5E+08 9.2E+07 N/A 3.4E+08 2.8E+08 2.2E+08 N/A 1.1E—10 1.3E-10 1.7E-10 10,000 N/A 3.8E+09 5.8E+08 3.1E+08 N/A 7.6E+08 6.0E+08 4.5E+08 N/A 4.7E-11 6.0E-11 7.9E-11 Page 84 of 204 ------- Public Comment Draft - Do Not Cite of Quote Occupational Exposure Scenario Number of TRI Facilities Distance from Facility (meters) Estimated MOE Estimated Cancer Risk Non-cancer Cancer (Benchmark 1E-06) Acute (Benchmark 100) Chronic (Benchmark 100) Total" w/ Risk Single Facility Min Risk* Mean Riskc Max Risk'' Single Facility Min Risk Mean Risk Max Risk Single Facility Min Risk Mean Risk Max Risk Processing- Incorporation into Articles 1 1 5 323 - - - 1,193 - - - 3.0E-05 10 302 - - - 1,087 - - - 3.3E-05 30 943 - - - 3,448 - - - 1.0E-05 60 2,419 - - - 8,915 - - - 4.0E-06 100 5,085 - - - 1.8E+04 - - - 2.0E-06 100-1,000 5.4E+04 - - - 1.1E+05 - - - 3.2E-07 2,500 4.8E+05 - - - 2.0E+06 - - - 1.8E-08 5,000 1.4E+06 - - - 5.8E+06 - - - 6.2E-09 10,000 4.0E+06 - - - 1.7E+07 - - - 2.1E-09 Manufacturing 2 2 5 N/A 2.1E+10 155 56 N/A 3.2E+10 413 148 N/A 1.1E-12 8.7E-05 2.4E-04 10 N/A 1.3E+09 116 41 N/A 3.5E+09 306 109 N/A 1.0E-11 1.2E-04 3.3E-04 30 N/A 6.5E+06 330 118 N/A 2.5E+07 802 287 N/A 1.5E-09 4.5E-05 1.3E-04 60 N/A 5.9E+05 805 288 N/A 1.5E+06 1,997 715 N/A 2.4E-08 1.8E-05 5.0E-05 100 N/A 2.6E+05 1,704 610 N/A 6.7E+05 4,251 1,523 N/A 5.4E-08 8.5E-06 2.4E-05 100-1,000 N/A 7.5E+05 2.1E+04 7,472 N/A 1.6E+06 3.6E+04 1.3E+04 N/A 2.3E-08 1.0E-06 2.8E-06 2,500 N/A 3.0E+06 2.2E+05 8.1E+04 N/A 9.2E+06 6.8E+05 2.4E+05 N/A 3.9E-09 5.3E-08 1.5E-07 5,000 N/A 6.2E+06 5.7E+05 2.1E+05 N/A 2.0E+07 1.9E+06 6.9E+05 N/A 1.8E-09 1.9E-08 5.3E-08 10,000 N/A 1.4E+07 1.5E+06 5.3E+05 N/A 4.7E+07 5.2E+06 1.9E+06 N/A 7.6E-10 6.9E-09 1.9E-08 Other Uses- Cutting Oils 5 2 5 N/A 7.6E+09 721 157 N/A 1.4E+07 1,654 355 N/A 2.6E-09 2.2E-05 1.0E-04 10 N/A 4.1E+06 704 164 N/A 2.2E+06 1,441 321 N/A 1.6E-08 2.5E-05 1.1E-04 30 N/A 1.5E+05 2,179 545 N/A 5.4E+05 4,408 1,015 N/A 6.7E-08 8.2E-06 3.5E-05 60 N/A 3.4E+05 5,743 1,485 N/A 7.1E+05 1.2E+04 2,752 N/A 5.1E-08 3.1E-06 1.3E-05 100 N/A 6.8E+05 1.3E+04 3,352 N/A 1.4E+06 2.6E+04 6,166 N/A 2.5E-08 1.4E-06 5.8E-06 100-1,000 N/A 7.9E+06 1.8E+05 5.0E+04 N/A 1.4E+07 2.9E+05 7.7E+04 N/A 2.6E-09 1.2E-07 4.7E-07 2,500 N/A 8.2E+07 2.2E+06 6.6E+05 N/A 2.2E+08 5.1E+06 1.3E+06 N/A 1.7E-10 7.0E-09 2.7E-08 5,000 N/A 2.0E+08 6.7E+06 2.0E+06 N/A 5.8E+08 1.6E+07 4.2E+06 N/A 6.2E-11 2.3E-09 8.6E-09 10,000 N/A 5.0E+08 2.0E+07 5.8E+06 N/A 1.5E+09 4.9E+07 1.3E+07 N/A 2.4E-11 7.4E-10 2.8E-09 Page 85 of 204 ------- Public Comment Draft - Do Not Cite of Quote Occupational Exposure Scenario Number of TRI Facilities Distance from Facility (meters) Estimated MOE Estimated Cancer Risk Non-cancer Cancer (Benchmark 1E-06) Acute (Benchmark 100) Chronic (Benchmark 100) Total" w/ Risk Single Facility Min Risk* Mean Riskc Max Risk'' Single Facility Min Risk Mean Risk Max Risk Single Facility Min Risk Mean Risk Max Risk Processing as Reactant 1 1 5 606 - - - 1,662 - - - 2.2E-05 10 420 - - - 1,060 - - - 3.4E-05 30 984 - - - 2,609 - - - 1.4E-05 60 2,410 - - - 6,550 - - - 5.5E-06 100 5,172 - - - 1.4E+04 - - - 2.6E-06 100-1,000 7.3E+04 - - - 1.2E+05 - - - 3.0E-07 2,500 9.3E+05 - - - 3.1E+06 - - - 1.2E-08 5,000 2.8E+06 - - - 9.4E+06 - - - 3.8E-09 10,000 8.5E+06 - - - 2.9E+07 - - - 1.3E-09 Recycling and Disposal 2 1 5 N/A 2.2E+04 1.5E+04 1.2E+04 N/A 8.3E+04 5.7E+04 4.3E+04 N/A 4.3E-07 6.3E-07 8.3E-07 10 N/A 1.2E+04 8,578 6,674 N/A 4.1E+04 3.1E+04 2.5E+04 N/A 8.9E-07 1.2E-06 1.4E-06 30 N/A 2.3E+04 1.7E+04 1.3E+04 N/A 8.0E+04 6.2E+04 5.1E+04 N/A 4.5E-07 5.8E-07 7.1E-07 60 N/A 5.5E+04 3.9E+04 3.1E+04 N/A 2.0E+05 1.5E+05 1.2E+05 N/A 1.8E-07 2.4E-07 2.9E-07 100 N/A 1.1E+05 8.0E+04 6.3E+04 N/A 4.2E+05 3.1E+05 2.5E+05 N/A 8.5E-08 1.1E-07 1.4E-07 100-1,000 N/A 1.5E+06 1.1E+06 8.4E+05 N/A 3.3E+06 2.3E+06 1.7E+06 N/A 1.1E-08 1.6E-08 2.1E-08 2,500 N/A 1.7E+07 1.2E+07 9.6E+06 N/A 8.3E+07 5.7E+07 4.3E+07 N/A 4.4E-10 6.3E-10 8.3E-10 5,000 N/A 5.2E+07 3.7E+07 2.8E+07 N/A 2.5E+08 1.7E+08 1.3E+08 N/A 1.5E-10 2.1E-10 2.8E-10 10,000 N/A 1.5E+08 1.1E+08 8.9E+07 N/A 7.3E+08 5.1E+08 3.9E+08 N/A 4.9E-11 7.1E-11 9.3E-11 Repackaging 1 1 5 2,230 - - - 9,693 - - - 3.7E-06 10 1,563 - - - 7,389 - - - 4.9E-06 30 4,839 - - - 2.6E+04 - - - 1.4E-06 60 1.5E+04 - - - 8.0E+04 - - - 4.5E-07 100 4.2E+04 - - - 2.2E+05 - - - 1.6E-07 100-1,000 2.2E+06 - - - 3.3E+06 - - - 1.1E-08 2,500 8.8E+07 - - - 1.7E+08 - - - 2.2E-10 5,000 5.8E+08 - - - 4.3E+08 - - - 8.4E-11 10,000 4.9E+09 - - - 8.4E+08 - - - 4.3E-11 Page 86 of 204 ------- Public Comment Draft - Do Not Cite of Quote Occupational Exposure Scenario Number of TRI Facilities Distance from Facility (meters) Estimated MOE Estimated Cancer Risk Non-cancer Cancer (Benchmark 1E-06) Acute (Benchmark 100) Chronic (Benchmark 100) Total" w/ Risk Single Facility Min Risk* Mean Riskc Max Risk'' Single Facility Min Risk Mean Risk Max Risk Single Facility Min Risk Mean Risk Max Risk Spot Cleaner/ Stain Remover 5 N/A 5,825 3,896 2,956 N/A 2.8E+04 1.4E+04 8,902 N/A 1.3E-06 2.6E-06 4.0E-06 10 N/A 3,261 2,668 2,273 N/A 1.5E+04 9,564 6,928 N/A 2.4E-06 3.8E-06 5.2E-06 30 N/A 7,916 7,505 7,143 N/A 3.8E+04 3.0E+04 2.5E+04 N/A 9.6E-07 1.2E-06 1.5E-06 60 N/A 2.3E+04 2.2E+04 2.0E+04 N/A 1.0E+05 8.7E+04 7.6E+04 N/A 3.5E-07 4.1E-07 4.7E-07 100 N/A 6.2E+04 5.7E+04 5.3E+04 N/A 2.6E+05 2.3E+05 2.0E+05 N/A 1.4E-07 1.6E-07 1.8E-07 100-1,000 N/A 2.4E+06 2.2E+06 2.0E+06 N/A 3.6E+06 3.3E+06 2.9E+06 N/A 1.0E-08 1.1E-08 1.2E-08 2,500 N/A 6.4E+07 5.8E+07 5.1E+07 N/A 2.4E+08 1.8E+08 1.3E+08 N/A 1.5E-10 2.0E-10 2.8E-10 5,000 N/A 2.2E+08 2.1E+08 1.9E+08 N/A 8.8E+08 5.9E+08 4.1E+08 N/A 4.1E-11 6.1E-11 8.9E-11 10,000 N/A 6.3E+08 5.4E+08 4.9E+08 N/A 2.1E+09 1.5E+09 1.1E+09 N/A 1.7E-11 2.4E-11 3.4E-11 Spray Adhesives 5 3.6E+11 - - - 1.2E+11 - - - 3.0E-13 10 3.6E+08 - - - 9.3E+08 - - - 3.9E-11 30 6.3E+05 - - - 2.4E+06 - - - 1.5E-08 60 8.2E+04 - - - 2.6E+05 - - - 1.4E-07 100 4.5E+04 - - - 1.4E+05 - - - 2.6E-07 100-1,000 3.7E+05 - - - 5.8E+05 - - - 6.2E-08 2,500 6.7E+06 - - - 2.1E+07 - - - 1.7E-09 5,000 1.7E+07 - - - 5.4E+07 - - - 6.7E-10 10,000 3.7E+07 - - - 1.2E+08 - - - 3.0E-10 " When (-) is indicated for the total number of facilities, no facilities were identified via TRI reporting. The provided estimates are based on modeling of theoretical facilities. b The minimum risk value is associated with the maximum MOE and the maximum ADR. c The mean risk value is the arithmetic mean MOE. J The maximum risk value is associated with the minimum MOE and the minimum ADR. 3 4 Page 87 of 204 ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Public Comment Draft - Do Not Cite of Quote 3.1.5.1.1 Land Use Considerations EPA identified risk for 52 of the 64 real or surrogate facilities evaluated based on modeled air concentrations. GIS locations were available for 49 of the 52 facilities with risk. For each of these 49 facilities, EPA evaluated land use patterns to determine whether fenceline community exposures are reasonably anticipated at locations where risk is indicated. Details of this methodology are provided in Section 2.1.2.2. In short, EPA evaluated whether residential, industrial/commercial businesses, or other public spaces are present within those radial distances indicating risk (as opposed to uninhabited areas), as well as whether the radial distance lies outside the boundaries of the facility. Based on characterization of land use patterns, fenceline community exposures are anticipated for 35 of the 49 (71 percent) GIS-located facilities where risk is indicated based on modeled fenceline air concentrations. Table 3-10 summarizes the number of facilities in each OES for which risk is indicated and where fenceline community exposures are anticipated. Table 3-10. Summary of Fenceline Community Exposures Expected near Facilities Where Modeled Air Concentrations Indicated Risk for 1-BP OES" Total Number of Facilities Evaluated Number of Facilities with Risk Indicated Number of Facilities with Risk Indicated and Exposures Expected Percent of Total Facilities with Risk Indicated and Exposures Expected Degreasing 34 30 26 77% Formulation 11 9 6 55% Import 4 4 2 50% Other Uses- Cutting Oils 5 2 1 20% Manufacturing 2 2 0 0% Repackaging 1 1 0 0% Recycling and Disposal 2 1 0 0% a This table is limited to facilities with specific location information. It excludes surrogate facilities and OES for which TRI data were not available. 3.1.5.2 Co-resident Inhalation Risk EPA also calculated risk estimated for each of the endpoints in Table 3-2 based on modeling of co- residents living above or adjacent to dry cleaning facilities. See Section 2.1.2.3 for details on the exposure modeling methodology. All risk calculations are provided in Supplemental File SF_FLA_^4z> Pathway Co-Resident Exposure Results for 1-BP (Appendix B). Risks were indicated for all endpoints under all scenarios modeled at high-end exposures and for three of four scenarios at central tendency exposures. Page 88 of 204 ------- 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Public Comment Draft - Do Not Cite of Quote Table 3-11.1-BP Inhalation Risk for Co-residents of Dry Cleaning Facilities Estimated MOE Estimated Cancer Risk Building Type Method for Estimating Q12 Non-cancer Cancer Acute (Benchmark 100) Chronic (Benchmark 100) (Benchmark IE—06) cx« HE6 cx« HE6 cx« HE6 Risk Risk Risk Risk Risk Risk Building 1 Method 1 325 58 377 67 9.5E-05 5.4E-04 Method 2 82 14 97 17 3.7E-04 2.2E-03 Building 2 Method 1 5 1 6 1 5.7E-03 2.7E-02 Method 2 4 1 5 1 6.6E-03 2.7E-02 " CT = central tendency; risk estimates are based on the 50th percentile of exposure estimates. b HE = central tendency; risk estimates are based on the 95th percentile of exposure estimates. 3.1.6 Confidence and Risk Conclusions for 1-BP Case Study Results This section illustrates by example EPA's use of results from applying the proposed screening level methodology to make risk conclusions and does not represent final agency action. Any results or risk conclusions presented here are not intended to be used in support of risk management actions or rulemakings as presented. EPA identified risks relative to the benchmarks at fenceline air concentrations of 1-BP for 52 of the 64 real or surrogate facilities assessed, representing 13 of 14 OES. Based on characterization of land use patterns, fenceline community exposures are anticipated for 35 of the 49 GIS located facilities with risk. EPA also identified risk relative to the benchmarks from 1-BP inhalation for co-residents of dry cleaning facilities in all scenarios modeled. Risk estimates in Table 3-9 are based on the 95th percentile values of modeled exposure concentrations around individual facilities, and the range of risk estimates covers all facilities under an OES. The consideration of land use patterns also confirms that facilities indicating risk are likely of concern to an expected fenceline community cohort. Therefore, EPA determines that the proposed screening level methodology, as applied for this report, sufficiently captures expected risk to the fenceline communities around these facilities for the exposure pathways evaluated. 95th percentile values represent a conservative, screening-level analysis and may potentially overestimate chronic and/or lifetime cancer risks. However, analysis of risk estimates based on 10th and 50th percentile exposure concentrations in SF_FLA^//' Pathway Fall-Screen Results for 1-BP (Appendix B) demonstrates that for most facilities cancer risk is also present at lower percentiles, mitigating this uncertainty. 3.2 Methylene Chloride - Air and Water Pathways 3.2.1 Background for MC Methylene chloride (MC) is a highly volatile, liquid organohalogen. If released to surface water and soil, it will most likely volatilize and enter the atmosphere, where it is persistent and mobile over long ranges. Methylene chloride is also mobile in groundwater but will slowly hydrolyze (U.S. EPA 2020c). A summary of its physical-chemical properties can be found in TableApx A-l. Page 89 of 204 ------- 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 Public Comment Draft - Do Not Cite of Quote 3,2,2 Human Health Hazard Endpoints for MC All hazard values used to calculated risk for MC in this report are derived from the previously peer- reviewed PODs in the Final Risk Evaluation for Methylene Chloride (U.S. EPA. 2020c). In the Final Risk Evaluation, EPA utilized the endpoints shown in Table 3-1 for risk determination. For MC, human equivalent concentrations/doses (HECs/HEDs) for non-cancer endpoints were derived for use in occupational and consumer scenarios. Additionally, an inhalation unit risk (IUR) for lifetime cancer risk was applied for both occupational scenarios. Oral/dermal hazard values were extrapolated from inhalation PODs based on an assumed 1.25 m3/hr inhalation rate for occupational scenarios. Table 3-12. Hazard Values Used for Risk Estimation in the Methylene Chloride Risk Evaluation Scenario Endpoint Inhalation Hazard Value Oral/Dermal Hazard Value Benchmark Reference Acute Neurological: Decreased visual performance 696 mg/m3 [1.5-hr exposure] 16 mg/kg [1.5-hr exposure] 30 (Putz et al., )) Chronic Liver: Vacuolization and cell foci 17.2 mg/m3 2.15 mg/kg 10 (Nitscfake et al.. I«>S3) Cancer Lung and liver tumors 1.38E-06 per mg/m3 1. 1E-05 per mg/kg 1E-4 (occupational) (NIP. 1986) For the analyses in this report, EPA derived POD values for fenceline communities based on a continuous exposure scenario. The acute HEC was derived using the equation from (ten Beree et ai. 1986). Cn x T = K, where n = 2 based on the original study conditions of 1.5 hr exposure. This equation was used to derive a 24-hr HEC, although there is significant uncertainty associated with extrapolation to a significantly longer duration. The chronic liver HEC was derived through a PBPK model on a continuous exposure basis, so no adjustment was required. For cancer, the IUR value used in the Risk Evaluation was for occupational scenarios of 8 hr/day, 5 days/week. This value was adjusted for continuous exposure. Additionally, ADAFs were applied to cancer hazard values for younger lifestages based on the conclusion that MC is carcinogenic through a mutagenic mode of action ( 2020c). HEDs and slope factors were extrapolated from inhalation values similar to the risk evaluation, however for this analysis they were derived based on continuous exposure and 14.7 m3/day inhalation rate for the general population ( i). The adjusted POD values for fenceline communities are presented below in Table 3-13. Inhalation hazard values in the Final Risk Evaluation were presented primarily in units of mg/m3; however, for consistency in risk calculations they have also been converted to ppm using the following equation: ppm = mg/m3 x 0.2879. Page 90 of 204 ------- 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 115 Public Comment Draft - Do Not Cite of Quote Table 3-13. Hazard Values for MC Used in this Fenceline Analysis Scenario Endpoint Fenceline HEC/ IUR Fenceline HED/ SF Benchmark Reference Acute Neurological: Decreased visual performance 174 mg/m3 (50 ppm) 32 mg/kg 30 (Putz et al.. (° '*>) Chronic Liver: Vacuolization and Cell Foci 17.2 mg/m3 (5.0 ppm) 3 mg/kg 10 (Nitscfake et al.. I«>S3) Cancer Lung and liver tumors 5.8E-06 per mg/m3 (2.0E-05 per ppm) 4.6E-05 per mg/kg 1E-6 (NIP. 1986) 3.2.2.1 Assumptions and Uncertainties for MC Human Health Hazard There is some significant uncertainty in the acute POD by applying the (ten Berge et al. 1986) equation to extrapolate from a 1.5 hr study exposure to a 24-hr basis, however it is unknown whether this uncertainty may result in an overestimation or underestimation of toxicity. The chronic non-cancer POD is identical to what was applied in ( )20c). while the cancer IUR. is adjusted by traditional Haber's rule from an occupational to continuous exposure basis, so there is reduced uncertainty associated with those endpoints. Any other assumptions or uncertainties inherent to the human health hazard assessment in the Final Risk Evaluation for Methylene Chloride ( )c) are still applicable for this analysis. 3.2.3 Environmental Releases for MC This case study provides information specific to MC fenceline environmental release analysis that is not captured in the general methodology described in Section 2.1.1 and 2.2.1. 3.2.3.1 Step 1: Obtain TRI Data and DMR For MC, the 2019 TRI dataset used for the air emissions fenceline analysis includes a total of 244 sites that reported stack and fugitive air releases ( 2021). These data include 16 Form A submissions and 228 Form R submissions. For MC, the 2016 TRI dataset used for the water release fenceline analysis includes a total of 43 sites that reported water releases ( ). These data do not include Form A submissions (Form A submission assessed as having zero water releases). The 2016 DMR dataset used for the water release fenceline analysis includes a total of 76 sites that reported water releases (U.S. EPA. 2016a). 3.2.3.2 Step 2: Map TRI and DMR to OES EPA followed the methodology described in Section 2.1.1.2 to map the facilities in 2019 TRI to the OES in the published 2020 Methylene Chloride Risk Evaluation ( s20c) (see Appendix E). However, there were a few deviations from this general methodology that EPA encountered during the mapping of MC 2019 TRI sites to OES, which are described below. • The 2019 TRI data for MC includes many sites that report the TRI uses/sub-uses for "Ancillary or Other use - Cleaner" and "Ancillary or Other use - Degreaser" ( '21). EPA was unable to determine the specific types of cleaning or degreasing from the TRI uses/sub-uses, NAICS codes, or internet searches of the facilities. Therefore, for these facilities, EPA assigned the OES as "Cleaner/Degreaser - Unknown." This OES designation is a grouping of the Page 91 of 204 ------- 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 133 134 135 136 137 138 139 140 141 142 143 144 145 146 147 148 149 Public Comment Draft - Do Not Cite of Quote following COUs from the 2020 Methylene Chloride Risk Evaluation (1 c< « ^ \ J020c): Conveyorized Vapor Degreasing and Cold Cleaning. EPA did not include the OES for Commercial Aerosol Products (Aerosol Degreasing, Aerosol Lubricants, Automotive Care Products) in this grouping because facilities conducting these types of cleaning and degreasing are not expected to be captured in TRI because they likely use MC at quantities below the reporting threshold or do not use a NAICS code that is included in a TRI-covered industry sector. Batch-Open Top Vapor Degreasing was also not included in this grouping because it had one mapped entry in the 2019 TRI. • After mapping of the 2019 TRI data to CDR codes using the TRI-to-CDR Use Mapping crosswalk (see Appendix C), EPA found that many CDR codes could not be cleanly mapped to an OES. For these cases, mapping was performed using the primary NAICS code and an internet search of the facility. • TRI sub-use "Otherwise Use: As a chemical processing aid (Process Solvents)" was mapped to the CDR code U029 "Solvents (for cleaning or degreasing)." These facilities were mapped according to the NAICS code and an internet search of the facility name. • There were multiple sites in the methylene chloride 2019 TRI data that mapped to the COU for pharmaceutical use ( >21). These uses were not assessed in the 2020 Methylene Chloride Risk Evaluation (U.S. EPA. 2020c) and are not included in the fenceline analysis. • The 2020 Methylene Chloride Risk Evaluation is unique in that it contains an OES for "Miscellaneous Non-aerosol Industrial and Commercial Uses" ( )20c). Facilities that could not be classified into other OES were grouped into this miscellaneous category. The MC fenceline analysis spreadsheet, SF YLKJLnvironmental Releases to Ambient Air for MC (Appendix B), contains the rationale for the mapping of each facility in 2019 TRI to an OES. Refer to this spreadsheet for details of the mapping at the facility-level. EPA followed the methodology described in Section 2.2.1.2 to map the facilities in 2016 TRI (U.S. ) and 2016 DMR (U.S. EPA. 2016a) to the OES in the published 2020 Methylene Chloride Risk Evaluation (1, ^ \ :020c). 3.2.3.3 Step 3: Estimate Number of Release Days for Each OES EPA estimated the number of release days for each MC OES according to the methodology in Section 2.1.1.3 and 2.2.1.3. Specifically, the number of release days was assumed to be equal to the number of operating days, which were estimated for each OES as shown in Table 3-14. Table 3-14. Number of Release Days for Each MC OES Number of OES Release Days (days/yr) Basis for Number of Release Days Manufacturing 350 Number of release days for "Manufacture of Solvents" discussed in Section 2.1.1.3 Processing as a Reactant 350 Number of release days for "Processing as a Reactant" Processing - Incorporation into 300 Number of release days for "Other Formulation, Mixture, or Chemical Plant Scenarios" Reaction Product Repackaging 250 Number of release days for "All Other Scenarios" Page 92 of 204 ------- Public Comment Draft - Do Not Cite of Quote Number of OES Release Days (days/yr) Basis for Number of Release Days Batch Open-Top Vapor 260 Vapor Degreasing ESD (Organization for Degreasing Economic 2 'eloo.m.ent. 2017) Conveyorized Vapor Degreasing 260 Vaoor Degreasing ESD (Organization for Economic 2 'eloo.m.ent. 2017) Cold Cleaning 260 Vaoor Degreasing ESD (Organization for Economic 2 ''eloo.m.ent 2017) Commercial Aerosol Products 260 (low-end) and Brake Servicing Near-Field/Far-Field (Aerosol Degreasing, Aerosol 364 (high-end) Inhalation Exposure Model Lubricants, Automotive Care Products) Adhesives and Sealants 250 Number of release days for "All Other Scenarios" Paints and Coatings 250 Number of release days for "All Other Scenarios" Adhesive and Caulk Removers 250 Number of release days for "All Other Scenarios" Fabric Finishing 250 Number of release days for "All Other Scenarios" Spot Cleaning 289 (50th Spot Cleaning Near-Field/Far-Field percentile) and 307 Inhalation Exposure Model (95th percentile) Cellulose Triacetate Film 250 Number of release days for "All Other Production Scenarios" Flexible Polyurethane Foam 250 Number of release days for "All Other Manufacturing Scenarios" Laboratory Use 250 Number of release days for "All Other Scenarios" Plastic Product Manufacturing 250 Number of release days for "All Other Scenarios" Lithographic Printing Plate 250 Number of release days for "All Other Cleaning Scenarios" Miscellaneous Non-aerosol 250 Number of release days for "All Other Industrial and Commercial Uses Scenarios" Waste Handling, Disposal, 250 Number of release days for "All Other Treatment, and Recycling Scenarios" Paint Remover 250 Number of release days for "All Other Scenarios" 150 3.2.3.4 Step 4: Estimate Air Emissions for OES with No 2019 TRI Data and Water 151 Releases for OES with No TRI or DMR Data 152 A summary of the air emission assessment approaches for each MC OES is included in Table 3-15. Of 153 the 21 OES listed in Table 3-15, 16 have directly applicable 2019 TRI data that were used for air Page 93 of 204 ------- Public Comment Draft - Do Not Cite of Quote 154 155 156 157 158 emissions. For the remaining five OES without 2019 TRI data, EPA used the hierarchy of alternate air assessment approaches described in Section 2.1.1.4. Specifically, EPA estimated air releases with modeling (two OES) and surrogate OES data (three OES). Table 3-15. Summary of Air Release Estimation Approaches for Each MC OES OES Range of Annual Fugitive Air Release (kg/site-yr) Range of Annual Fugitive Air Release (kg/site-yr) Air Release Estimation Approach Notes Manufacturing 0 to 2,456abc d 0 to 5,767bcde 2019 TRI ru.s. EPA. 2021) 2019 TRI data are available for 11 sites (no Form As). Processing as a Reactant 0 to 4,128acdf 0 to 6,350acdf 2019 TRI ru.s. EPA. 2021) 2019 TRI data are available for 15 sites (no Form As). Processing - Incorporation into Formulation, Mixture, or Reaction Product 0 to 59,528bcdf 0 to 4,808abc def 2019 TRI ru.s. EPA. 2 ) 2019 TRI data are available for 50 sites (four Form As). Repackaging 0 to 331bcdf 0 to 723abcdf 2019 TRI ru.s. EPA. 2021) 2019 TRI data are available for 24 sites (9 Form As). Batch Open-Top Vapor Degreasing Oto ll,106fedf 0 to 21,870bdf 2019 TRI ru.s. EPA. 2021) 2019 TRI data are available for 1 site (not Form A). Conveyorized Vapor Degreasing Oto ll,106bdf Oto 12,175bdf 2019 TRI ru.s. EPA. 2 ) No sites were classified specifically as conveyorized vapor degreasing. 2019 TRI data are available for 16 sites (one Form A) under "Cleaner/Degreaser - unknown." Cold Cleaning Oto ll,106bdf Oto 12,175bdf 2019 TRI ru.s. EPA. 2021) No sites were classified specifically as cold cleaning. 2019 TRI data are available for 16 sites (one Form A) under "Cleaner/Degreaser - unknown." Commercial Aerosol Products (Aerosol Degreasing, Aerosol Lubricants, Automotive Care Products) 188 to 267 0 (all fugitive) Modeling 2019 TRI data are not available for this OES. EPA adapted the Brake Servicing Near-Field/Far-Field Inhalation Exposure Model and ran it to estimate daily and annual air emissions for this OES. Adhesives and Sealants Oto 113,359flbcdf 0 to 75,001bcdf Surrogate 2019 TRI No 2019 TRI data available for this OES. Industrial applications of this COU are Page 94 of 204 ------- Public Comment Draft - Do Not Cite of Quote OES Range of Annual Fugitive Air Release (kg/site-yr) Range of Annual Fugitive Air Release (kg/site-yr) Air Release Estimation Approach Notes (U.S. EPA. 2 ) already accounted for within the TRI sites in the "Miscellaneous Non-aerosol Industrial and Commercial Uses" OES and the commercial applications are not applicable for fenceline analysis. Paints and Coatings Oto 113,359flbcdf 0 to 75,001bcdf Surrogate 2019 TRI (U.S. EPA. 2 ) No 2019 TRI data available for this OES. Industrial applications of this COU are already accounted for within the TRI sites in the "Miscellaneous Non-aerosol Industrial and Commercial Uses" OES and the commercial applications are not applicable for fenceline analysis. Adhesive and Caulk Removers Oto 113,359abcdf 0 to 75,001bcdf Surrogate 2019 TRI (U.S. EPA. 2021) No 2019 TRI data available for this OES. Industrial applications of this COU are already accounted for within the TRI sites in the "Miscellaneous Non-aerosol Industrial and Commercial Uses" OES and the commercial applications are not applicable for fenceline analysis. Fabric Finishing 340b (1 site) 0 (all fugitive) 2019 TRI (U.S. EPA. 2021) 2019 TRI data are available for 1 site (not Form A). Spot Cleaning 35.6 to 38.4 0 (all fugitive) Modeling 2019 TRI data are not available for this OES. EPA adapted the Spot Cleaning Model and ran it to estimate daily air emissions for this OES. Cellulose Triacetate Film Production 20 to 13,438bd 0 to 630bd 2019 TRI (U.S. EPA. 2021) 2019 TRI data are available for 2 sites (no Form As). Flexible Polyurethane Foam Manufacturing Oto 102,743b 0 to 6,305bf 2019 TRI (U.S. EPA. 2021) 2019 TRI data are available for 2 sites (no Form As). Page 95 of 204 ------- 159 160 161 162 163 164 165 166 167 168 169 Public Comment Draft - Do Not Cite of Quote OES Range of Annual Fugitive Air Release (kg/site-yr) Range of Annual Fugitive Air Release (kg/site-yr) Air Release Estimation Approach Notes Laboratory Use 0 to 436' a b C f 55 to 7,200' ,b c d 2019 TRI (U.S. 0 2019 TRI data are available for 5 sites (no Form As). Plastic Product Manufacturing 0 to 54,431 bd Oto 18,144' bdf 2019 TRI (U.S L) 2019 TRI data are available for 7 sites (no Form As). Lithographic Printing Plate Cleaning 0 (all stack)b 2,295 (1 site) 2019 TRI (U.S l) 2019 TRI data are available for 1 site (not Form A). Miscellaneous Non- aerosol Industrial and Commercial Uses Oto 113,359 ,a b c d f 0 to 75,001bcdf 2019 TRI (U.S. 0 2019 TRI data are available for 33 sites (two Form As). Waste Handling, Disposal, Treatment, and Recycling 0 to 755 b C d f 0 to 7,058 b C d f 2019 TRI (U.S 0 2019 TRI data are available for 32 sites (no Form As). Paint Remover 0 to 7,467 feed 4,058 to 21,137" 2019 TRI (U.S l) 2019 TRI data are available for 3 sites (no Form As). a This range includes estimates based on periodic or random monitoring data or measurements. b This range includes estimates based on mass balance calculations, such as calculation of the amount of chemical in streams entering and leaving process equipment. c This range includes estimates s based on published emissions factors, such as those relating release quantity to through-put or equipment type (e.g., air emissions factors). This may include emissions factors in a trade association's publication or AP-42. d This range includes estimates based on other approaches such as engineering calculations (e.g., estimating volatilization using published mathematical formulas) or best engineering judgment. This would include applying estimated removal efficiency to a waste stream, even if the composition of the stream before treatment was fully identified through monitoring data. e This range includes estimates based on continuous monitoring data or measurements. f This range includes estimates based on site-specific emissions factors, such as those relating release quantity to through-put or equipment type (e.g., air emissions factors). This may include emissions factors that are developed for a specific piece of equipment and that consider climate conditions on-site. A summary of the water release assessment approaches for each MC OES is included in Table 3-16. Of the 20 OES listed in Table 3-16, 10 have directly applicable 2016 TRI or 2016 DMR data that were used for water releases. For the remaining 10 OES without TRI or DMR data, EPA used an alternative to the water release approaches described in Section 2.2.1.4. Specifically, EPA estimated water releases using a qualitative approach for all 10 OES without 2016 TRI or 2016 DMR data. Specifically, for the 10 OES where releases are expected but TRI and DMR data were not available, EPA included a qualitative discussion of potential release sources in the initial risk evaluation. Table 3-16. Summary of Water Release Estimation Approaches for Each Methylene Chloride OES OES Range of Water Releases (kg/site-yr) Water Release Estimation Approach Notes Manufacturing 0.1 to 76abcde 2016 TRI and 2016 DMR 2016 TRI data are available for 8 sites and Page 96 of 204 ------- Public Comment Draft - Do Not Cite of Quote OES Range of Water Releases (kg/site-yr) Water Release Estimation Approach Notes 2016 DMR data are available for 12 sites. Processing as a Reactant 0.1 to 213abe 2016 TRI and 2016 DMR 2016 TRI data are available for 2 sites and 2016 DMR data are available for 1 site. Processing - Incorporation into Formulation, Mixture, or Reaction Product 0.2 to 5,785acde 2016 TRI and 2016 DMR 2016 TRI data are available for 5 sites and 2016 DMR data are available for 4 sites. Repackaging 2.8E-2 to 144acde 2016 TRI and 2016 DMR 2016 TRI data are available for 3 sites and 2016 DMR data are available for 2 sites. Batch Open-Top Vapor Degreasing N/A Qualitative No quantitative assessment made. Conveyorized Vapor Degreasing N/A Qualitative No quantitative assessment made. Cold Cleaning N/A Qualitative No quantitative assessment made. Commercial Aerosol Products (Aerosol Degreasing, Aerosol Lubricants, Automotive Care Products) N/A None expected Due to the volatility of methylene chloride the majority of releases from the use of aerosol products will likely be to air as methylene chloride evaporates from the aerosolized mist and the substrate surface. Adhesives and Sealants N/A Qualitative No quantitative assessment made; majority of methylene chloride expected to be released to air. Paints and Coatings N/A Qualitative No quantitative assessment made; majority of methylene chloride expected to be released to air. Adhesive and Caulk Removers N/A Qualitative No quantitative assessment made; majority of methylene chloride expected to be released to air. Fabric Finishing N/A Qualitative No quantitative assessment made; Page 97 of 204 ------- Public Comment Draft - Do Not Cite of Quote OES Range of Water Water Release Notes Releases (kg/site-yr) Estimation Approach majority of methylene chloride expected to be released to air. Spot Cleaning 0.1 (1 site)f 2016 DMR 2016 DMR data are available for 1 site. Cellulose Triacetate Film 29 (1 site)f 2016 DMR 2016 DMR data are Production available for 1 site. Flexible Polyurethane Foam 2.3 (1 site)bf 2016 TRI 2016 TRI data are Manufacturing available for 1 site. Laboratory Use N/A Qualitative No quantitative assessment made, majority of methylene chloride expected to be released to air or disposed as hazardous waste. Plastic Product Manufacturing 2.3E-2 to 28ef 2016 TRI and 2016 DMR 2016 TRI data are available for 1 site and 2016 DMR data are available for 8 sites. Lithographic Printing Plate 9.3E-4 (1 site)f 2016 DMR 2016 DMR data are Cleaning available for 1 site. Miscellaneous Non-aerosol N/A Qualitative No quantitative Industrial and Commercial assessment made; Uses majority of methylene chloride expected to be released to air. Waste Handling, Disposal, 2.4E-2 to 115,059abde 2016 TRI and 2016 2016 TRI data are Treatment, and Recycling DMR available for 7 sites and 2016 DMR data are available for 6 sites. a This range includes both direct and indirect discharges. b This range includes TRI estimates based on continuous monitoring data or measurements. c This range includes TRI estimates based on mass balance calculations, such as calculation of the amount of chemical in streams entering and leaving process equipment. d This range includes TRI estimates based on other approaches such as engineering calculations (e.g., estimating volatilization using published mathematical formulas) or best engineering judgment. This would include applying estimated removal efficiency to a waste stream, even if the composition of the stream before treatment was fully identified through monitoring data. e This range includes TRI estimates based on periodic or random monitoring data or measurements. f This range includes direct discharges only. 170 3.2.3.5 Step 5: Prepare Air Emission and Water Release Summary for Ambient Air 171 and Water Exposure Modeling 172 Using the work completed in Steps 1 through 4, EPA compiled a summary of air releases on a per-site 173 basis for each MC OES, in the format of Table 2-1. See the supplemental fenceline analysis spreadsheet 174 SFFLA Environmental Releases to Ambient Air for MC (Appendix B) for this summary. To model 175 exposures resulting from these air emissions, EPA used the daily emissions, site identity and location 176 information, and release duration and pattern information from this summary. For water releases, EPA Page 98 of 204 ------- 177 178 179 180 181 182 183 184 185 186 187 188 189 190 191 192 193 194 195 196 197 198 199 Public Comment Draft - Do Not Cite of Quote used the same release estimates as those used in the risk evaluation report and no additional summary was created. Additional information on the modeled MC exposures is provided in the next section. 3,2,4 Exposures for MC 3.2.4.1 Air Pathway Pre-screening and full-screening level methodologies were utilized to evaluate potential exposures to fenceline communities for MC. Pre-screening Analysis Pre-screening work for MC is included in Appendix D. Inputs for all IIOAC model runs for all exposure scenarios are included in Supplemental File SF FLA Air Pathway Input Parameters for IIOAC for 1-BP andMC (Appendix B). Based on the pre-screening analysis, there is an indication of potential exposures and associated risks to fenceline communities and therefore EPA conducted a full-screening level analysis for MC. Screening Analysis A total of 17 OES were evaluated for MC as presented in Table 3-17. A total of 195 real facilities were modeled. Exposure modeling was also performed for those OES where releases were estimated, although there is no real facility associated with those estimates and therefore a "number of facilities" is not applicable for those OES. Inputs for all AERMOD model runs for all exposure scenarios are included in Supplemental File SF FLA Fenceline Air Pathway Input Parameters for AERMOD for 1- BP andMC (Appendix B). Table 3-17. Fenceline Community Exposure Scenarios for MC OES Release Data Source Number of Facilities in OES" Batch Open-Top Degreasing TRI (2019) 1 Cellulose Triacetate Film Production TRI (2019) 2 Cleaner/Degreaser - Unknown6 TRI (2019) 16 Commercial Aerosol Products (Aerosol Degreasing, Aerosol Lubricants, Automotive Care Products) Estimate N/A Fabric Finishing TRI (2019) 1 Flexible Polyurethane Foam Manufacturing TRI (2019) 1 Laboratory Use TRI (2019) 5 Lithographic Printing Plate Cleaning TRI (2019) 1 Manufacturing TRI (2019) 11 Miscellaneous Non-aerosol Industrial and Commercial Usesc TRI (2019) 31 Plastic Product Manufacturing TRI (2019) 7 Page 99 of 204 ------- 200 201 202 203 204 205 206 207 208 209 210 211 212 213 214 215 216 217 218 219 220 221 222 223 224 225 Public Comment Draft - Do Not Cite of Quote OES Release Data Source Number of Facilities in OES" Processing - Incorporation into Formulation, Mixture, or Reaction Product TRI (2019) 50 Processing as a Reactant TRI (2019) 14 Repackaging TRI (2019) 22 Spot Cleaning Estimate N/A Waste Handling, Disposal, Treatment, and Recycling TRI (2019) 30 Paint Remover TRI (2019) 3 Total 195 a N/A: No real facilities identified b This OES designation is a grouping of the following COUs from the 2020 Methylene Chloride Risk Evaluation: Conveyorized Vapor Degreasing and Cold Cleaning. See Section 3.2.3.2. c This OES designation includes a grouping of the following COUs from the 2020 Methylene Chloride Risk Evaluation: Adhesives and Sealants, Paints and Coatings, and Adhesive and Caulk Removers Modeling results for inhalation exposure concentrations are categorized by OES and presented by facility. Daily and annual average concentrations are summarized for three percentile concentrations (10th, 50th, 95th) to cover the range of exposure concentrations across all nine distances modeled (5; 10; 30; 60; 100; 100 to 1,000; 2,500; 5,000; and 10,000 meters) and can be found in Supplemental File SFFLA Air Pathway Full-Screen Results for MC (Appendix B). Exposure concentrations are presented as total concentration to inform the total exposure to a given receptor at each modeled distance from each releasing facility. EPA did not identify air monitoring data to which modeled concentrations could be compared at the distances modeled. EPA conducted a source attribution analysis which provides exposure concentrations from each release type (fugitive and stack) at each modeled distance for each facility in anticipation of informing future risk management actions and the potential need for a more detailed analyses if risks are identified. For facilities reporting both fugitive and stack releases within TRI, adding the exposure concentrations for each release type at each modeled distance provides the total concentration. EPA further distilled exposure results for the 95th percentile values across all facilities within each OES, at all nine distances modeled, and presents them in Table 3-18. The purpose of this further distillation is to present a smaller subset of results within the body of this report. The further distilled results presented here are carried into the risk characterization section of the body of this report for risk calculation purposes. The minimum and maximum concentrations in Table 3-18 represent the lowest and highest 95th percentile concentrations, respectively, among all facilities categorized into the respective OES at each distance modeled. The mean 95th percentile concentrations in Table 3-18 represent arithmetic averages across all facilities within the given OES at each distance modeled. Additionally, for certain OES, there are a variety of industry types and release points (stack, fugitive, stack and fugitive) categorized within an OES which may not be directly comparable. This results in a wide range of modeled exposure Page 100 of 204 ------- 226 227 228 229 230 231 232 233 234 235 236 237 Public Comment Draft - Do Not Cite of Quote concentrations which, in some cases, extends over many orders of magnitude. For example, in the Miscellaneous Non-aerosol Industrial and Commercial Uses OES, there are 31 facilities which may include a variety of industry types. Although releases within an industry type may be comparable, releases across industry types may have considerably different emission profiles and therefore may not be comparable. Further, looking at the release points, EPA found that fugitive releases do not have much lift or dispersion resulting in higher concentrations very close to facilities (around 10 meters) and lower concentrations further away (around 100 meters). In contrast, stack releases often have more lift and dispersion resulting in lower concentrations around 10 meters and higher concentrations around 100 meters. Even with these different concentration profiles, the modeled exposure concentrations from stacks are still several orders of magnitude lower than fugitive concentrations. This can skew the mean of the 95th percentile modeled concentrations across multiple facilities orders of magnitude lower, thus underestimating exposures and associated risks. Page 101 of 204 ------- Public Comment Draft - Do Not Cite of Quote 1 Table 3-18. 95th Percentile Exposure Concentration Summary across Facilities within Each PES for MC OES Number of TRI Facilities Evaluated" Distance from Facility (meters) Concentration (ppm) Daily Average Annual Average Single Facility Minimum Arithmetic Mean Maximum Single Facility Minimum Arithmetic Mean Maximum Batch Open-Top Degreasing 1 5 7.44E-04 - - - 1.84E-04 - - - 10 1.03E-03 - - - 2.52E-04 - - - 30 5.01E-04 - - - 1.20E-04 - - - 60 1.20E-03 - - - 3.30E-04 - - - 100 2.10E-03 - - - 5.63E-04 - - - 100-1,000 4.78E-04 - - - 1.99E-04 - - - 2,500 7.78E-05 - - - 1.65E-05 - - - 5,000 2.88E-05 - - - 6.28E-06 - - - 10,000 1.05E-05 - - - 2.33E-06 - - - Cellulose Triacetate Film Production 2 5 - 3.86E-04 1.63E-01 3.25E-01 - 1.64E-04 7.11E-02 1.42E-01 10 - 4.77E-04 2.14E-01 4.27E-01 - 2.24E-04 9.46E-02 1.89E-01 30 - 1.72E-04 7.11E-02 1.42E-01 - 8.20E-05 2.88E-02 5.76E-02 60 - 8.49E-05 2.66E-02 5.31E-02 - 4.06E-05 9.87E-03 1.97E-02 100 - 7.06E-05 1.18E-02 2.36E-02 - 3.02E-05 4.08E-03 8.13E-03 100-1,000 - 1.80E-05 7.14E-04 1.41E-03 - 9.36E-06 3.81E-04 7.53E-04 2,500 - 3.33E-06 5.82E-05 1.13E-04 - 1.48E-06 1.89E-05 3.64E-05 5,000 - 1.21E-06 1.91E-05 3.70E-05 - 5.33E-07 6.22E-06 1.19E-05 10,000 - 4.02E-07 6.15E-06 1.19E-05 - 1.81E-07 2.06E-06 3.93E-06 Page 102 of 204 ------- Public Comment Draft - Do Not Cite of Quote OES Number of TRI Facilities Evaluated" Distance from Facility (meters) Concentration (ppm) Daily Average Annual Average Single Facility Minimum Arithmetic Mean Maximum Single Facility Minimum Arithmetic Mean Maximum Cleaner/Degreaser - Unknown b 16 5 - 4.81E-12 4.00E-02 1.54E-01 - 8.00E-12 1.30E-02 5.86E-02 10 - 3.55E-10 5.16E-02 2.49E-01 - 2.20E-10 1.67E-02 6.74E-02 30 - 6.51E-07 1.84E-02 1.07E-01 - 2.69E-07 5.64E-03 2.45E-02 60 - 1.12E-05 7.10E-03 4.23E-02 - 2.91E-06 2.14E-03 9.47E-03 100 - 2.39E-05 3.42E-03 1.91E-02 - 5.93E-06 1.01E-03 4.35E-03 100-1,000 - 4.83E-06 2.41E-04 9.98E-04 - 2.03E-06 1.24E-04 5.16E-04 2,500 - 6.47E-07 2.21E-05 6.33E-05 - 1.55E-07 6.36E-06 2.20E-05 5,000 - 2.49E-07 7.71E-06 1.98E-05 - 6.95E-08 2.31E-06 7.32E-06 10,000 - 8.98E-08 2.72E-06 6.69E-06 - 2.97E-08 8.63E-07 2.55E-06 Commercial Aerosol Products (Aerosol Degreasing, Aerosol Lubricants, Automotive Care Products) - 5 - 1.93E-03 3.38E-03 5.08E-03 - 3.98E-04 9.23E-04 1.58E-03 10 - 3.40E-03 4.87E-03 6.53E-03 - 7.24E-04 1.29E-03 1.99E-03 30 - 1.38E-03 1.71E-03 2.04E-03 - 2.86E-04 4.10E-04 5.52E-04 60 - 4.69E-04 5.89E-04 7.20E-04 - 1.04E-04 1.40E-04 1.79E-04 100 - 1.74E-04 2.23E-04 2.77E-04 - 4.08E-05 5.35E-05 6.64E-05 100-1,000 - 4.53E-06 5.59E-06 6.73E-06 - 2.76E-06 3.49E-06 4.21E-06 2,500 - 1.71E-07 2.14E-07 2.60E-07 - 4.25E-08 6.48E-08 1.07E-07 5,000 - 4.71E-08 5.98E-08 7.26E-08 - 1.18E-08 2.00E-08 3.48E-08 10,000 - 1.51E-08 2.24E-08 3.01E-08 - 5.11E-09 8.23E-09 1.38E-08 Page 103 of 204 ------- Public Comment Draft - Do Not Cite of Quote Number of TRI Facilities Evaluated" Distance from Facility (meters) Concentration (ppm) OES Daily Average Annual Average Single Facility Minimum Arithmetic Mean Maximum Single Facility Minimum Arithmetic Mean Maximum 5 6.33E-03 - - - 1.98E-03 - - - 10 7.84E-03 - - - 2.85E-03 - - - 30 2.89E-03 - - - 1.12E-03 - - - 60 1.14E-03 - - - 4.39E-04 - - - Fabric Finishing 1 100 5.27E-04 - - - 1.99E-04 - - - 100-1,000 3.25E-05 - - - 1.86E-05 - - - 2,500 2.50E-06 - - - 8.56E-07 - - - 5,000 8.07E-07 - - - 2.66E-07 - - - 10,000 2.64E-07 - - - 8.46E-08 - - - 5 2.89E+00 - - - 1.09E+00 - - - 10 3.76E+00 - - - 1.30E+00 - - - 30 1.25E+00 - - - 4.75E-01 - - - Flexible Polyurethane Foam Manufacturing 60 4.94E-01 - - - 1.90E-01 - - - 1 100 2.30E-01 - - - 8.75E-02 - - - 100-1,000 1.47E-02 - - - 8.51E-03 - - - 2,500 1.27E-03 - - - 4.70E-04 - - - 5,000 4.11E-04 - - - 1.53E-04 - - - 10,000 1.36E-04 - - - 4.99E-05 - - - Page 104 of 204 ------- Public Comment Draft - Do Not Cite of Quote Number of TRI Facilities Evaluated" Distance from Facility (meters) Concentration (ppm) OES Daily Average Annual Average Single Facility Minimum Arithmetic Mean Maximum Single Facility Minimum Arithmetic Mean Maximum 5 - 4.34E-10 1.54E-03 5.05E-03 - 4.35E-10 6.00E-04 1.96E-03 10 - 6.11E-08 2.65E-03 9.80E-03 - 1.41E-08 1.01E-03 3.76E-03 30 - 5.22E-06 1.29E-03 5.20E-03 - 1.67E-06 4.16E-04 1.68E-03 60 - 2.52E-05 6.00E-04 2.25E-03 - 1.69E-05 1.91E-04 6.95E-04 Laboratory Use 5 100 - 3.49E-05 3.70E-04 1.13E-03 - 1.98E-05 1.25E-04 3.42E-04 100-1,000 - 3.13E-06 4.96E-05 1.28E-04 - 1.97E-06 2.68E-05 6.97E-05 2,500 - 4.91E-07 1.09E-05 3.87E-05 - 2.49E-07 3.57E-06 1.30E-05 5,000 - 2.56E-07 5.71E-06 2.16E-05 - 1.26E-07 1.89E-06 7.40E-06 10,000 - 1.17E-07 2.80E-06 1.12E-05 - 5.58E-08 8.85E-07 3.61E-06 5 1.62E-11 - - - 2.76E-11 - - - 10 3.26E-09 - - - 4.08E-09 - - - 30 4.49E-06 - - - 1.64E-06 - - - Lithographic Printing Plate Cleaning 60 7.20E-05 - - - 3.07E-05 - - - 1 100 1.62E-04 - - - 6.64E-05 - - - 100-1,000 6.29E-05 - - - 2.43E-05 - - - 2,500 1.19E-05 - - - 2.47E-06 - - - 5,000 4.72E-06 - - - 9.70E-07 - - - 10,000 1.77E-06 - - - 3.81E-07 - - - Page 105 of 204 ------- Public Comment Draft - Do Not Cite of Quote OES Number of TRI Facilities Evaluated" Distance from Facility (meters) Concentration (ppm) Daily Average Annual Average Single Facility Minimum Arithmetic Mean Maximum Single Facility Minimum Arithmetic Mean Maximum Manufacturing 11 5 - 2.78E-15 9.34E-03 2.93E-02 - 2.72E-15 4.22E-03 1.46E-02 10 - 7.58E-14 1.55E-02 5.34E-02 - 5.75E-14 7.20E-03 2.78E-02 30 - 2.54E-11 7.11E-03 2.66E-02 - 1.09E-11 3.23E-03 1.36E-02 60 - 3.92E-10 3.04E-03 1.15E-02 - 2.70E-10 1.37E-03 5.78E-03 100 - 9.85E-10 1.58E-03 5.78E-03 - 6.08E-10 7.08E-04 2.87E-03 100-1,000 - 4.06E-10 1.61E-04 4.94E-04 - 2.11E-10 9.22E-05 3.07E-04 2,500 - 6.73E-11 2.06E-05 5.04E-05 - 2.21E-11 7.81E-06 2.15E-05 5,000 - 2.83E-11 8.28E-06 2.10E-05 - 8.55E-12 3.09E-06 9.18E-06 10,000 - 1.15E-11 3.18E-06 8.24E-06 - 3.15E-12 1.15E-06 3.51E-06 Miscellaneous Non- aerosol Industrial and Commercial Uses0 31 5 - 6.27E-12 1.27E-01 3.88E+00 - 8.96E-12 5.85E-02 1.82E+00 10 - 7.68E-10 1.42E-01 4.20E+00 - 9.99E-10 6.81E-02 2.07E+00 30 - 4.42E-07 4.83E-02 1.36E+00 - 1.75E-07 2.16E-02 6.35E-01 60 - 6.63E-06 1.89E-02 5.20E-01 - 2.95E-06 8.25E-03 2.37E-01 100 - 1.19E-05 9.08E-03 2.36E-01 - 4.26E-06 3.87E-03 1.06E-01 100-1,000 - 2.63E-06 7.20E-04 1.48E-02 - 1.07E-06 4.30E-04 9.96E-03 2,500 - 5.87E-07 7.93E-05 1.23E-03 - 1.74E-07 2.85E-05 5.09E-04 5,000 - 2.13E-07 2.97E-05 3.97E-04 - 9.23E-08 1.02E-05 1.64E-04 10,000 - 7.27E-08 1.07E-05 1.33E-04 - 3.31E-08 3.58E-06 5.39E-05 Page 106 of 204 ------- Public Comment Draft - Do Not Cite of Quote OES Number of TRI Facilities Evaluated" Distance from Facility (meters) Concentration (ppm) Daily Average Annual Average Single Facility Minimum Arithmetic Mean Maximum Single Facility Minimum Arithmetic Mean Maximum Plastic Product Manufacturing 7 5 - 8.69E-13 2.32E-01 9.13E-01 - 1.59E-11 7.31E-02 2.88E-01 10 - 4.36E-10 4.07E-01 1.51E+00 - 1.92E-09 1.31E-01 4.71E-01 30 - 5.63E-06 1.91E-01 6.61E-01 - 1.90E-06 6.34E-02 2.32E-01 60 - 2.39E-06 8.09E-02 2.80E-01 - 7.67E-07 2.66E-02 9.86E-02 100 - 1.19E-06 3.99E-02 1.40E-01 - 3.72E-07 1.31E-02 4.98E-02 100-1,000 - 9.80E-08 3.10E-03 1.14E-02 - 4.75E-08 1.52E-03 5.35E-03 2,500 - 1.02E-08 2.88E-04 1.11E-03 - 2.72E-09 7.76E-05 3.18E-04 5,000 - 3.86E-09 1.02E-04 4.00E-04 - 9.43E-10 2.63E-05 1.10E-04 10,000 - 1.38E-09 3.50E-05 1.40E-04 - 3.24E-10 8.88E-06 3.75E-05 Processing - Incorporation into Formulation, Mixture, or Reaction Product 50 5 - 2.10E-13 3.10E-02 9.23E-01 - 6.95E-13 1.31E-02 3.92E-01 10 - 6.12E-11 4.36E-02 1.51E+00 - 3.52E-11 1.81E-02 6.07E-01 30 - 1.22E-08 1.80E-02 6.66E-01 - 4.41E-09 6.86E-03 2.39E-01 60 - 8.19E-08 7.41E-03 2.79E-01 - 4.98E-08 2.74E-03 9.64E-02 100 - 1.56E-07 3.54E-03 1.33E-01 - 8.59E-08 1.29E-03 4.50E-02 100-1,000 - 5.61E-08 2.59E-04 9.29E-03 - 2.70E-08 1.53E-04 5.56E-03 2,500 - 1.03E-08 2.29E-05 7.70E-04 - 3.46E-09 7.54E-06 2.35E-04 5,000 - 3.76E-09 7.81E-06 2.50E-04 - 1.22E-09 2.54E-06 7.61E-05 10,000 - 1.28E-09 2.68E-06 8.22E-05 - 4.19E-10 8.63E-07 2.49E-05 Page 107 of 204 ------- Public Comment Draft - Do Not Cite of Quote OES Number of TRI Facilities Evaluated" Distance from Facility (meters) Concentration (ppm) Daily Average Annual Average Single Facility Minimum Arithmetic Mean Maximum Single Facility Minimum Arithmetic Mean Maximum Processing as a Reactant 14 5 - 7.33E-12 1.11E-02 1.05E-01 - 1.51E-12 4.22E-03 3.96E-02 10 - 1.14E-10 1.55E-02 1.41E-01 - 3.75E-11 5.92E-03 5.34E-02 30 - 3.60E-08 5.71E-03 4.95E-02 - 7.96E-09 2.32E-03 2.04E-02 60 - 4.53E-07 2.37E-03 2.03E-02 - 1.58E-07 9.52E-04 8.22E-03 100 - 1.01E-06 1.19E-03 9.73E-03 - 4.14E-07 4.78E-04 3.94E-03 100-1,000 - 3.99E-07 1.19E-04 8.51E-04 - 1.90E-07 6.72E-05 5.03E-04 2,500 - 1.01E-07 1.47E-05 9.25E-05 - 3.69E-08 4.82E-06 3.07E-05 5,000 - 4.87E-08 6.27E-06 3.85E-05 - 1.52E-08 1.88E-06 1.16E-05 10,000 - 1.93E-08 2.53E-06 1.55E-05 - 5.68E-09 7.22E-07 4.40E-06 Repackaging 22 5 - 6.55E-20 2.15E-03 7.95E-03 - 1.14E-15 5.18E-04 1.85E-03 10 - 1.80E-13 3.10E-03 8.22E-03 - 3.73E-12 6.87E-04 1.95E-03 30 - 3.47E-07 1.02E-03 3.03E-03 - 2.25E-07 1.99E-04 5.50E-04 60 - 6.98E-06 3.51E-04 1.06E-03 - 1.34E-06 6.90E-05 1.83E-04 100 - 2.55E-06 1.50E-04 4.42E-04 - 4.90E-07 3.05E-05 8.35E-05 100-1,000 - 5.02E-08 5.03E-06 1.88E-05 - 3.71E-08 3.30E-06 1.15E-05 2,500 - 1.25E-09 1.56E-07 6.20E-07 - 4.75E-10 5.93E-08 2.12E-07 5,000 - 2.04E-10 3.19E-08 1.64E-07 - 1.61E-10 2.05E-08 7.67E-08 10,000 - 3.14E-11 9.67E-09 5.44E-08 - 7.62E-11 9.57E-09 3.60E-08 Page 108 of 204 ------- Public Comment Draft - Do Not Cite of Quote OES Number of TRI Facilities Evaluated" Distance from Facility (meters) Concentration (ppm) Daily Average Annual Average Single Facility Minimum Arithmetic Mean Maximum Single Facility Minimum Arithmetic Mean Maximum Spot Cleaning - 5 - 3.53E-04 5.31E-04 7.05E-04 - 7.25E-05 1.52E-04 2.34E-04 10 - 6.31E-04 7.76E-04 9.17E-04 - 1.35E-04 2.16E-04 3.00E-04 30 - 2.60E-04 2.76E-04 2.91E-04 - 5.49E-05 6.92E-05 8.42E-05 60 - 8.85E-05 9.55E-05 1.03E-04 - 2.02E-05 2.38E-05 2.74E-05 100 - 3.29E-05 3.61E-05 3.97E-05 - 8.05E-06 9.16E-06 1.02E-05 100-1,000 - 8.73E-07 9.45E-07 1.02E-06 - 5.71E-07 6.27E-07 7.22E-07 2,500 - 3.22E-08 3.58E-08 4.04E-08 - 8.64E-09 1.16E-08 1.60E-08 5,000 - 9.48E-09 1.01E-08 1.09E-08 - 2.35E-09 3.50E-09 5.14E-09 10,000 - 3.29E-09 3.80E-09 4.23E-09 - 9.67E-10 1.38E-09 1.94E-09 Waste Handling, Disposal, Treatment, and Recycling 30 5 - 9.98E-11 2.73E-03 3.85E-02 - 1.95E-10 1.14E-03 1.96E-02 10 - 1.08E-08 3.50E-03 3.24E-02 - 2.66E-08 1.46E-03 1.81E-02 30 - 1.15E-06 1.40E-03 8.63E-03 - 3.80E-07 5.54E-04 4.86E-03 60 - 4.70E-07 5.83E-04 3.67E-03 - 1.58E-07 2.21E-04 1.70E-03 100 - 2.33E-07 2.98E-04 1.81E-03 - 7.81E-08 1.09E-04 7.53E-04 100-1,000 - 2.10E-08 2.86E-05 2.07E-04 - 1.03E-08 1.43E-05 8.11E-05 2,500 - 2.74E-09 3.20E-06 3.17E-05 - 7.52E-10 9.68E-07 8.38E-06 5,000 - 1.21E-09 1.15E-06 1.13E-05 - 3.26E-10 3.36E-07 2.95E-06 10,000 - 4.59E-10 3.99E-07 3.82E-06 - 1.34E-10 1.16E-07 1.01E-06 Page 109 of 204 ------- Public Comment Draft - Do Not Cite of Quote OES Number of TRI Facilities Evaluated" Distance from Facility (meters) Concentration (ppm) Daily Average Annual Average Single Facility Minimum Arithmetic Mean Maximum Single Facility Minimum Arithmetic Mean Maximum Paint Remover 3 5 - 1.2E-09 5.74E-02 1.58E-01 - 1.42E-09 2.43E-02 6.81E-02 10 - 2.84E-07 9.50E-02 2.63E-01 - 9.30E-08 4.47E-02 1.26E-01 30 - 5.30E-05 4.23E-02 1.18E-01 - 3.48E-05 2.00E-02 5.65E-02 60 - 3.65E-04 1.77E-02 4.76E-02 - 2.35E-04 8.32E-03 2.29E-02 100 - 6.72E-04 9.31E-03 2.23E-02 - 3.42E-04 4.23E-03 1.07E-02 100-1,000 - 2.08E-04 9.66E-04 1.47E-03 - 1.37E-04 4.87E-04 8.10E-04 2,500 - 3.90E-05 1.61E-04 3.22E-04 - 2.37E-05 5.96E-05 1.01E-04 5,000 - 1.48E-05 7.04E-05 1.57E-04 - 8.59E-06 2.62E-05 5.21E-05 10,000 - 5.22E-06 2.94E-05 7.02E-05 - 2.94E-06 1.05E-05 2.26E-05 " When (-) is indicated for the total number of facilities, no facilities were identified via TRI reporting. The provided estimates are based on modeling of theoretical facilities. b This OES designation is a grouping of the following COUs from the 2020 Methylene Chloride Risk Evaluation: Conveyorized Vapor Degreasing and Cold Cleaning. See Section 3.2.3.2. 0 This OES designation includes a grouping of the following COUs from the 2020 Methylene Chloride Risk Evaluation: Adhesives and Sealants, Paints and Coatings, and Adhesive and Caulk Removers. 2 3 Page 110 of 204 ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Public Comment Draft - Do Not Cite of Quote 3.2.4.2 Water Pathway 3.2.4.2.1 Ambient Water Monitoring Results Available monitored and measured ambient surface water information was evaluated as part of the original risk evaluation for MC to assess environmental risk (U.S. EPA. 2020c) by evaluating two principal sources of information: (1) extract submitted data to EPA's Water Quality Portal and (2) conduct a systematic review of surface water concentrations in peer reviewed and grey literature. Full description of these results are available in 020c). No new information was found during this evaluation. As described in 320c). WQP data ranged from ND to 29 jug/L for the years 2013 to 2017. Measured concentrations from published literature within the United States was found in two studies. A nation-wide survey of 375 samples collected between 1999 and 2000 found a single detectable value of 2.6 |.ig/L (USGS. 2003). In another study conducted between 1979 to 1981, MC was detected in 93 percent of samples collected from the Eastern Pacific Ocean with values ranging from below detection limit to 0.008 |ig/L, with a mean of 0.003 1 |ig/L (Singh V). For measured published values outside the United States, concentrations between the years of 1993 to 2013 ranged from below detection limit to 134 |ig/L. 3.2.4.2.2 Drinking Water Monitoring Results The retrieved six-year review dataset for MC contained 371,905 entries for sample years 2006 through 2011 (See Section 2.2.2.1 for description of dataset). Observations were made in 48 states, the District of Columbia, and American Samoa at 55,712 unique monitoring sites, with 1 to 10,539 samples collected per site (Table 3-19). For the entire dataset (all years combined), the detection frequency was 0.55% and the reported detection limits ranged from 5.0x10-05 to 1,000 |ig/L (or 2.5x10-05 to 500 [j,g/L when using one-half the detection limit). Since one-half of the detection limit is used in the statistical analysis and some of the samples had reported detection limits that were greater than measured concentrations in other samples, the concentrations ranged from ND (< 2,5x ] 0 05 (J,g/L) to ND (<500 |ig/L). For the sample concentrations from sample residues detected above the detection limit, concentrations ranged from 5.0x10-04 to 326 [^g/L (1.0x10-03 to 100 (J,g/L in 2006, 5.0x10-04 to 23 (J,g/L in 2007, 1.3x10-03 to 54 ng/L in 2008, 1.4x10-02 to 290 ng/L in 2009, 0.14 to 326 ng/L in 2010, and 0.10 to 88 [j,g/L in 2011) with an average concentration of 3.0 [j,g/L and a standard deviation of 16 |ig/L (Table 3-19). The percentage of detections above methylene chloride's maximum contaminant level (MCL) of 5 [j,g/L was calculated by dividing the number of sample concentrations greater than 5 [j,g/L by the number of samples with detected values greater than the detection limit. Overall, the percentage of detections exceeding the MCL is 6.2 percent. Each year, the evaluated datasets contained between 60,436 and 64,738 drinking water samples collected from 23,229 to 27,168 unique monitoring stations from one of three source water types. The three source water types are groundwater under direct influence of surface water (GU), groundwater (GW), and surface water (SW). When looking at the most current 2011 data set, the detection frequency ranged from 0.31% (SW) to 1.1% (GU). For all 2011 samples, the number of samples ranged from 554 (GU) to 52,124 (GW), with contractions ranging from ND (<2.5x 10-04 (J,g/L) to ND (<500 (J,g/L), both Page 111 of 204 ------- Public Comment Draft - Do Not Cite of Quote 47 from GW. When only looking at the sample concentrations from samples detected above the detection 48 limit in 2011, concentrations ranged from 0.10 [j,g/L (GW) to 88 [j,g/L (GW) with an overall average 49 concentration of 1.9 [j,g/L and a standard deviation of 6.1 (J,g/L. The percentage of detections above 50 methylene chloride's MCL ranged from 0% (GU) to 21% (SW). Each source water type percentage 51 calculation was based on the number of samples with detections above the detection limit representing 52 that water type and not water types combined. 53 54 Page 112 of 204 ------- Public Comment Draft - Do Not Cite of Quote 1 Table 3-19. Measured Concentrations of MC in Drinking Water Obtainec Detection Frcquencv (%) Concentration in All Samples (fig/L) Concentrations Only in Samples above the Detection Limit (ug/L) Year Source Water Type No. of Samples (No. of Stations) Rangeh Average ± Standard No. of Samples (No. Rangeh Average ± Standard Percentage of Detects > MCL Deviation of Stations) Deviation (5 jig/L) Groundwater Under 0 543 ND (<5.0E-02) ND {<0211) 0 - - - Direct Infl. of Surf. (270) to ND (<1.2) ±0.14 (0) Water (GU) Groundwater (GW) 0.62 50,636 ND (<2.5E-04) 0.30 ±3.0 315 1.0E-03 to 2.6 ±7.5 7.9% 2006 (21,033) to ND c (<250) (240) 100 Surface Water 0.43 9,257 ND (<2.5E-03) 0.30 ±2.6 40 0.21 to 17 2.4 ±3.6 10% (SW) (3,054) to ND c (<250) (35) All Types 0.59 6,0436 (24,357) ND (<2.5E-04) to NDC (<250) 0.31 ±2.9 355 (275) 1.0E-03 to 100 2.6 ±7.1 8.2% Groundwater Under 0.20 500 ND (<5.0E-02) 0.27 ±0.11 1 6.0E-02 6.0E-02 0% Direct Influence of (239) to 1.0 (1) Surf. Water (GU) Groundwater (GW) 0.87 52,083 ND (<2.5E-04) 0.30 ±2.9 451 5.0E-04 to 21 1.5 ±2.2 3.8% 2007 (21,417) to ND c (<250) (253) Surface Water 0.59 8,937 ND (<2.5E-04) 0.27 ±0.29 53 6.0E-02 to 23 1.9 ±3.2 3.8% (SW) (3,048) to 23 (41) All Types 0.82 61,520 (24,704) ND (<2.5E-04) to ND c (<250) 0.29 ±2.7 505 (295) 5.0E-04 to 23 1.5 ±2.4 3.8% Groundwater Under 1.2 561 ND (<5.0E-02) 0.31 ±0.72 7 0.38 to 17 3.1 ±6.2 14% Direct Influence of (264) to 17 (4) Surf. Water (GU) Groundwater (GW) 0.58 52,850 ND (<2.5E-05) 0.33 ±4.1 306 1.3E-03 to 54 1.8 ±4.4 4.9% 2008 (20,206) to ND c (<250) (208) Surface Water 0.59 9,100 ND (<2.5E-04) 0.32 ±3.7 54 0.34 to 24 1.8 ±3.2 3.7% (SW) (3,276) to NDC (<250) (31) All Types 0.59 62,511 (23,746) ND (<2.5E-05) to ND c (<250) 0.33 ±4.0 367 (243) 1.3E-03 to 54 1.8 ±4.3 4.9% from the Six-Year Review Data (2006-2011)" Page 113 of 204 ------- Public Comment Draft - Do Not Cite of Quote Detection Frequency (%) Concentration in All Samples (fig/L) Concentrations Only in Samples above the Detection Limit (ug/L) Year Source Water Type No. of Samples (No. of Stations) Rangeh Average ± Standard Deviation No. of Samples (No. of Stations) Rangeh Average ± Standard Deviation Percentage of Detects > MCL (5 ju.g/L) Groundwater Under Direct Influence of Surf. Water (GU) 0.53 571 (282) ND (<2.5E-04) to 9.8 0.28 ±0.44 3 (3) 0.99 to 9.8 4.3 ±4.8 33% 2009 Groundwater (GW) 0.48 5,1423 (21,180) ND (<2.5E-04) to 290 0.28 ±2.2 247 (195) 1.4E-02 to 290 4.3 ±21 7.3% Surface Water (SW) 0.56 8,605 (3,059) ND (<2.5E-04) to NDC (<250) 0.29 ±2.7 00 -t m 0.34 to 11 1.9 ±2.4 10% All Types 0.49 60,599 (24,521) ND (<2.5E-04) to 290 0.29 ±2.3 298 (235) 1.4E-02 to 290 3.9 ± 19 8.1% Groundwater Under Direct Influence of Surf. Water (GU) 0.38 527 (265) ND (<2.5E-04) to 4.0 0.26 ±0.17 2 (1) 0.79 to 4.0 2.4 ±2.3 0% 2010 Groundwater (GW) 0.43 55,211 (23,793) ND (<2.5E-04) to 326 0.29 ±2.6 240 (195) 0.14 to 326 8.5 ±39 8.3% Surface Water (SW) 0.27 9,000 (3,110) ND (<2.5E-02) to NDC (<250) 0.33 ±4.0 24 (18) 0.50 to 137 6.9 ±28 4.2% All Types 0.41 64,738 (27,168) ND (<2.5E-04) to 326 0.29 ±2.8 266 (214) 0.14 to 326 8.3 ±38 7.9% Groundwater Under Direct Influence of Surf. Water (GU) 1.1 554 (274) ND (<5.0E-02) to 4.1 0.27 ±0.18 6 (6) 0.14 to 4.1 1.3 ± 1.5 0% 2011 Groundwater (GW) 0.40 52,124 (19,606) ND (<2.5E-04) to ND c (<500) 0.27 ±2.2 207 (172) 0.10 to 88 1.7 ±6.2 4.3% Surface Water (SW) 0.31 9423 (3,349) ND (<2.5E-04) to 18 0.25 ±0.35 29 (20) 0.50 to 18 3.7 ±5.3 21% All Types 0.39 62,101 (23,229) ND (<2.5E-04) to NDC (<500) 0.27 ±2.0 242 (198) 0.10 to 88 1.9 ±6.1 6.2% Groundwater Under Direct Influence of Surf. Water (GU) 0.58 3,256 (451) ND (<2.5E-04) to 17 0.28 ±0.37 19 (11) 6.0E-02 to 17 2.5 ±4.2 11% All 6 Years Groundwater (GW) 0.56 314,327 (51,283) ND (<2.5E-05) to NDC (<500) 0.30 ±2.9 1,766 (1,100) 5.0E-04 to 326 3.1 ± 17 5.9% Surface Water (SW) 0.46 54,322 (3,978) ND (<2.5E-04) to ND c (<250) 0.29 ±2.7 248 (149) 6.0E-02 to 137 2.6 ±9.2 8.1% All Types 0.55 37,1905 (55,712) ND (<2.5E-05) to ND c (<500) 0.30 ±2.9 2,033 (1,260) 5.0E-04 to 326 3.0 ± 16 6.2% Page 114 of 204 ------- Public Comment Draft - Do Not Cite of Quote Year Source Water Type Detection Frequency (%) Concentration in All Samples (jig/L) Concentrations Only in Samples above the Detection Limit (ug/L) No. of Samples (No. of Stations) Rangeh Average ± Standard Deviation No. of Samples (No. of Stations) Rangeh Average ± Standard Deviation Percentage of Detects > MCL (5 ju.g/L) "Data were downloaded from tlie SYR3 website (bix-1 ecu .Rev icw j ^unipiidiiwc iviumiunuK L/aia in uo iir « ) oil September 8, 2021. h ND = Not Detected. Value in parentheses represents one-half the reported detection limit or '/? the average overall detection limit for non-detect samples without reported detection limits (overall average detection limit is 0.561 |ig/L and one-half overall average is 0.28 |ig/L). Reported Detection Limits ranged from 5.0E-05 to 1.0E+03 |ig/L. c Maximum value represents Vi detection limit which was greater than the maximum detected value for all samples. 2 Page 115 of 204 ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Public Comment Draft - Do Not Cite of Quote 3.2.4.2.3 Modeled Drinking Water Modeled drinking water estimates are summarized by OES category in Table 3-20 for the 20-day release scenario and in Table 3-21 for the maximum days of release scenario. Results are presented for the adult and infant age class, but complete by facility results across all age classes for all evaluated releases are available in SFFLA Water Pathway Exposure Data for MC (Appendix B). For the 20-day release scenario, a total of 66 releases were modeled across all OES with drinking water ADRs across both age classes ranging from 5.0x10-10 to 8.7x10-03 mg/kg-day, ADDs ranging from 2.4x10-12 to 2.2x10-05 mg/kg-day and LADDs ranging from 3.1x10-14 to 2.8x10-07 mg/kg-day. For the maximum days of release scenario, a total of 87 releases were modeled across all OES with drinking water ADRs across both age classes ranging from 4.0x10-11 to 1.5 mg/kg-day, ADDs ranging from 2.4x10-12 to 6.8x10-02 mg/kg-day, and LADDs ranging from 3.1x10-14 to 8.8x10-04 mg/kg-day. In all cases, estimated exposures were highest in the infant age class in the 20-day release scenarios. Page 116 of 204 ------- Public Comment Draft - Do Not Cite of Quote 1 Table 3-20. Summary of MC Drinking Water Exposure by PES for 20 Days of Release Scenarios OES No. of Releases Modeled Age Group ADR (mg/kg-day) ADD (mg/kg-day) LADD (mg/kg-day) Min Exp." Mean Exp.6 Max Exp.c Min Exp." Mean Exp.6 Max Exp.c Min Exp." Mean Exp.6 Max Exp.c Manufacturing 12 Adult (21+) 7.8E-09 1.2E-04 1.3E-03 4.3E-11 3.0E-07 3.0E-06 1.8E-11 1.3E-07 1.3E-06 Infant (birth to <1) 2.8E-08 4.4E-04 4.6E-03 1.1E-10 7.6E-07 7.8E-06 1.4E-12 9.7E-09 1.0E-07 Import and Repackaging 2 Adult (21+) 4.4E-06 8.7E-06 1.3E-05 2.1E-08 4.4E-08 6.6E-08 9.1E-09 1.9E-08 2.8E-08 Infant (birth to <1) 1.6E-05 3.0E-05 4.5E-05 5.5E-08 1.1E-07 1.7E-07 7.0E-10 1.4E-09 2.2E-09 Processing as a Reactant 2 Adult (21+) 5.4E-05 7.7E-05 1.0E-04 3.5E-07 3.6E-07 3.7E-07 1.5E-07 1.5E-07 1.6E-07 Infant (birth to <1) 1.9E-04 2.7E-04 3.5E-04 8.9E-07 9.2E-07 9.4E-07 1.1E-08 1.2E-08 1.2E-08 Processing: Formulation 5 Adult (21+) 3.0E-08 5.0E-04 2.5E-03 1.6E-10 6.4E-07 3.2E-06 6.9E-11 2.7E-07 1.3E-06 Infant (birth to <1) 1.0E-07 1.8E-03 8.7E-03 4.2E-10 1.6E-06 8.1E-06 5.3E-12 2.1E-08 1.0E-07 Polyurethane Foam 1 Adult (21+) 3.3E-04 3.3E-04 3.3E-04 1.5E-06 1.5E-06 1.5E-06 6.5E-07 6.5E-07 6.5E-07 Infant (birth to <1) 1.2E-03 1.2E-03 1.2E-03 3.9E-06 3.9E-06 3.9E-06 5.0E-08 5.0E-08 5.0E-08 Plastics Manufacturing 9 Adult (21+) 1.8E-08 2.7E-04 1.3E-03 9.6E-11 1.3E-06 5.8E-06 4.1E-11 5.4E-07 2.5E-06 Infant (birth to <1) 6.2E-08 9.6E-04 4.4E-03 2.5E-10 3.2E-06 1.5E-05 3.2E-12 4.2E-08 1.9E-07 CTA Film Manufacturing 1 Adult (21+) 3.8E-05 3.8E-05 3.8E-05 2.4E-07 2.4E-07 2.4E-07 1.0E-07 1.0E-07 1.0E-07 Infant (birth to <1) 1.3E-04 1.3E-04 1.3E-04 6.2E-07 6.2E-07 6.2E-07 7.9E-09 7.9E-09 7.9E-09 Lithographic Printer Cleaner 1 Adult (21+) 1.7E-08 1.7E-08 1.7E-08 9.3E-11 9.3E-11 9.3E-11 3.9E-11 3.9E-11 3.9E-11 Infant (birth to <1) 6.0E-08 6.0E-08 6.0E-08 2.4E-10 2.4E-10 2.4E-10 3.0E-12 3.0E-12 3.0E-12 Spot Cleaner 1 Adult (21+) 1.9E-06 1.9E-06 1.9E-06 3.2E-09 3.2E-09 3.2E-09 1.4E-09 1.4E-09 1.4E-09 Infant (birth to <1) 6.6E-06 6.6E-06 6.6E-06 8.2E-09 8.2E-09 8.2E-09 1.1E-10 1.1E-10 1.1E-10 Recycling and Disposal 5 Adult (21+) 3.7E-06 5.0E-04 1.9E-03 1.8E-08 1.1E-06 2.7E-06 7.8E-09 4.8E-07 1.2E-06 Infant (birth to <1) 1.3E-05 1.8E-03 6.7E-03 4.7E-08 2.9E-06 7.0E-06 6.0E-10 3.7E-08 9.0E-08 Other 10 Adult (21+) 1.4E-10 5.0E-06 3.0E-05 9.5E-13 1.4E-08 9.0E-08 4.0E-13 6.1E-09 3.8E-08 Infant (birth to <1) 5.0E-10 1.7E-05 1.0E-04 2.4E-12 3.7E-08 2.3E-07 3.1E-14 4.7E-10 3.0E-09 DOD 1 Adult (21+) 6.3E-07 6.3E-07 6.3E-07 4.0E-09 4.0E-09 4.0E-09 1.7E-09 1.7E-09 1.7E-09 Infant (birth to <1) 2.2E-06 2.2E-06 2.2E-06 1.0E-08 1.0E-08 1.0E-08 1.3E-10 1.3E-10 1.3E-10 WWTP 16 Adult (21+) 4.0E-08 1.3E-04 4.7E-04 2.9E-10 1.5E-06 8.6E-06 1.2E-10 6.5E-07 3.6E-06 Infant (birth to <1) 1.4E-07 4.4E-04 1.7E-03 7.5E-10 3.9E-06 2.2E-05 9.6E-12 5.1E-08 2.8E-07 Overall 66 Adult (21+) 1.4E-10 1.8E-04 2.5E-03 9.5E-13 7.8E-07 8.6E-06 4.0E-13 3.3E-07 3.6E-06 Infant (birth to <1) 5.0E-10 6.2E-04 8.7E-03 2.4E-12 2.0E-06 2.2E-05 3.1E-14 2.5E-08 2.8E-07 a The minimum exposure for the identified days of release, within the identified OES, and for the identified age group. h The arithmetic mean exposure for the identified days of release, within the identified OES, and for the identified age group. cThe maximum exposure for the identified days of release, within the identified OES, and for the identified age group. 2 Page 117 of 204 ------- Public Comment Draft - Do Not Cite of Quote Table 3-21. Summary of MC Drinking Water Exposure by PES for Maximum Days of Release Scenarios No. of ADR (mg/kg-day) ADD (mg/kg-day) LADD (mg/kg-day) OES Releases Age Group Min Mean Max Min Mean Max Min Mean Max Modeled Exp." Exp.6 Exp.c Exp.fl Exp.6 Exp.c Exp." Exp.6 Exp.c Manufacturing 16 Adult (21+) 4.5E-10 5.7E-06 7.4E-05 4.3E-11 2.5E-07 3.1E-06 1.8E-11 1.0E-07 1.3E-06 Infant (birth to <1) 1.6E-09 2.0E-05 2.6E-04 1.1E-10 6.3E-07 7.8E-06 1.4E-12 8.0E-09 1.0E-07 Import and 5 Adult (21+) 1.6E-09 1.6E-04 8.1E-04 1.1E-10 1.0E-05 5.1E-05 4.8E-11 4.3E-06 2.1E-05 Repackaging Infant (birth to <1) 5.8E-09 5.7E-04 2.8E-03 2.9E-10 2.6E-05 1.3E-04 3.7E-12 3.4E-07 1.7E-06 Processing as 3 Adult (21+) 4.6E-07 3.1E-06 5.6E-06 3.9E-08 2.5E-07 3.7E-07 1.7E-08 1.1E-07 1.5E-07 a Reactant Infant (birth to <1) 1.6E-06 1.1E-05 2.0E-05 1.0E-07 6.4E-07 9.3E-07 1.3E-09 8.2E-09 1.2E-08 Processing: 9 Adult (21+) 9.3E-11 4.3E-03 3.8E-02 7.6E-12 2.7E-04 2.4E-03 3.2E-12 1.1E-04 1.0E-03 Formulation Infant (birth to <1) 3.2E-10 1.5E-02 0.14 1.9E-11 6.8E-04 6.1E-03 2.5E-13 8.7E-06 7.8E-05 Polyurethane 1 Adult (21+) 2.7E-05 2.7E-05 2.7E-05 1.5E-06 1.5E-06 1.5E-06 6.4E-07 6.4E-07 6.4E-07 Foam Infant (birth to <1) 9.3E-05 9.3E-05 9.3E-05 3.8E-06 3.8E-06 3.8E-06 4.9E-08 4.9E-08 4.9E-08 Plastics 9 Adult (21+) 1.4E-09 2.2E-05 1.0E-04 9.6E-11 1.3E-06 5.9E-06 4.0E-11 5.4E-07 2.5E-06 Manufacturing Infant (birth to <1) 4.9E-09 7.7E-05 3.6E-04 2.4E-10 3.2E-06 1.5E-05 3.1E-12 4.2E-08 1.9E-07 CTA Film 1 Adult (21+) 3.0E-06 3.0E-06 3.0E-06 2.4E-07 2.4E-07 2.4E-07 1.0E-07 1.0E-07 1.0E-07 Manufacturing Infant (birth to <1) 1.1E-05 1.1E-05 1.1E-05 6.2E-07 6.2E-07 6.2E-07 7.9E-09 7.9E-09 7.9E-09 Lithographic 1 Adult (21+) 1.4E-09 1.4E-09 1.4E-09 9.2E-11 9.2E-11 9.2E-11 3.9E-11 3.9E-11 3.9E-11 Printer Cleaner Infant (birth to <1) 4.8E-09 4.8E-09 4.8E-09 2.3E-10 2.3E-10 2.3E-10 3.0E-12 3.0E-12 3.0E-12 Spot Cleaner 1 Adult (21+) 1.5E-07 1.5E-07 1.5E-07 3.2E-09 3.2E-09 3.2E-09 1.4E-09 1.4E-09 1.4E-09 Infant (birth to <1) 5.3E-07 5.3E-07 5.3E-07 8.2E-09 8.2E-09 8.2E-09 1.1E-10 1.1E-10 1.1E-10 Recycling and 12 Adult (21+) 1.0E-07 3.6E-02 0.43 1.4E-08 2.3E-03 2.7E-02 5.8E-09 9.6E-04 1.1E-02 Disposal Infant (birth to <1) 3.6E-07 0.13 1.5 3.5E-08 5.8E-03 6.8E-02 4.5E-10 7.4E-05 8.8E-04 Other 12 Adult (21+) 1.1E-11 2.0E-05 2.4E-04 9.5E-13 1.3E-06 1.5E-05 4.0E-13 5.3E-07 6.2E-06 Infant (birth to <1) 4.0E-11 7.1E-05 8.3E-04 2.4E-12 3.2E-06 3.8E-05 3.1E-14 4.1E-08 4.8E-07 DOD 1 Adult (21+) 5.0E-08 5.0E-08 5.0E-08 4.0E-09 4.0E-09 4.0E-09 1.7E-09 1.7E-09 1.7E-09 Infant (birth to <1) 1.8E-07 1.8E-07 1.8E-07 1.0E-08 1.0E-08 1.0E-08 1.3E-10 1.3E-10 1.3E-10 WWTP 16 Adult (21+) 2.2E-09 6.9E-06 2.6E-05 2.9E-10 1.5E-06 8.7E-06 1.2E-10 6.6E-07 3.7E-06 Infant (birth to <1) 7.7E-09 2.4E-05 9.0E-05 7.5E-10 4.0E-06 2.2E-05 9.6E-12 5.1E-08 2.8E-07 Overall 87 Adult (21+) 1.1E-11 5.4E-03 0.43 9.5E-13 3.4E-04 2.7E-02 4.0E-13 1.4E-04 1.1E-02 Infant (birth to <1) 4.0E-11 1.9E-02 1.5 2.4E-12 8.7E-04 6.8E-02 3.1E-14 1.1E-05 8.8E-04 a The minimum exposure for t le identified days of release, within the identified OES, and for the identified age group. h The arithmetic mean exposure for the identified days of release, within the identified OES, and for the identified age group c The maximum exposure for the identified days of release, within the identified OES, and for the identified age group. Page 118 of 204 ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Public Comment Draft - Do Not Cite of Quote 3.2.4.2.4 Incidental Oral for MC Modeled incidental oral estimates are summarized by OES category in Table 3-22 for the 20-day release scenario and in Table 3-23 for the maximum days of release scenario. Results are presented for the adult and youth (11-15 years) age class, but complete by facility results across all age classes for all evaluated releases are available in SFFLA Water Pathway Exposure Data for MC (Appendix B). For the 20-day release scenario, a total of 82 releases were modeled across all OES with incidental oral ingestion exposure ADRs across both age groups ranging from 1.2x10-11 to 3.1x10-02 mg/kg-day and ADDs ranging from 3.0x10-13 to 1.7x10-03 mg/kg-day. For the maximum days of release scenario, a total of 106 releases were modeled across all OES with incidental oral ingestion exposure ADRs across both age groups ranging from 9.7x10-13 to 5.7x10-02 mg/kg-day and ADDs ranging from 3.0x10-13 to 1.3x10-02 mg/kg-day. Youths (11 to 15 years) had higher exposures than their adult counterparts due to this age class's higher weighted incidental daily ingestion rate (Table 2-6). Results here were compared to an alternative method for evaluating incidental oral exposure ( 2019d). Due to methodological differences between to the two methods, in t; S 1T \ 12019d) the 6 to 10 year age class has the highest estimated exposures as compared to the 11 to 15 year age class in the presented method. Weighted incidental daily ingestion rates between the two methods for the highest exposure age class between the two models are 6.6x10-03 L/kg-day and 5.4x10-03 L/kg-day respectively, resulting in slightly higher, but comparable overall exposure values. Using the U.S. EPA. (2019d) method, the 20-day scenario had a maximum ADR of 3.9 10 02 mg/kg-day and ADD of 2.1 x 10-03 mg/kg-day, while the maximum days of release scenario had a maximum ADR of 7.Ox 10-02 mg/kg-day and ADD of 1.6x10-02 mg/kg-day. These results are comparable between the two methodologies and supports confidence in the presented estimated exposures. Complete results for evaluation of incidental oral ingestion using the '2019d) method are available in SF FLA Water Pathway Exposure Data for MC (Appendix B). Page 119 of 204 ------- Public Comment Draft - Do Not Cite of Quote 1 Table 3-22. Summary of MC Incidental Oral Ingestion Exposure by PES for 20 Days of Release Scenarios OES No. of Releases Modeled Ajje Group ADR (mg/kg-day) ADD (mg/kg-day) Min Exposure" Mean Exposure* Max Exposure' Min Exposure" Mean Exposure'' Max Exposure' Manufacturing 14 Adult (21+) 6.7E-10 3.2E-05 2.9E-04 1.3E-11 1.3E-06 1.6E-05 Youth (11-15) 1.0E-09 4.9E-05 4.4E-04 2.1E-11 2.0E-06 2.4E-05 Import and Repackaging 2 Adult (21+) 3.8E-07 7.4E-07 1.1E-06 6.7E-09 1.4E-08 2.1E-08 Youth (11-15) 5.9E-07 1.2E-06 1.7E-06 1.0E-08 2.1E-08 3.2E-08 Processing as a Reactant 2 Adult (21+) 4.6E-06 6.6E-06 8.6E-06 1.1E-07 1.1E-07 1.2E-07 Youth (11-15) 7.2E-06 1.0E-05 1.3E-05 1.7E-07 1.7E-07 1.8E-07 Processing: Formulation 5 Adult (21+) 2.5E-09 4.3E-05 2.1E-04 5.1E-11 2.0E-07 9.9E-07 Youth (11-15) 4.0E-09 6.6E-05 3.3E-04 7.9E-11 3.1E-07 1.5E-06 Polyurethane Foam 1 Adult (21+) 2.8E-05 2.8E-05 2.8E-05 4.8E-07 4.8E-07 4.8E-07 Youth (11-15) 4.4E-05 4.4E-05 4.4E-05 7.4E-07 7.4E-07 7.4E-07 Plastics Manufacturing 9 Adult (21+) 1.5E-09 2.4E-05 1.1E-04 3.0E-11 4.0E-07 1.8E-06 Youth (11-15) 2.3E-09 3.7E-05 1.7E-04 4.7E-11 6.2E-07 2.8E-06 CTA Film Manufacturing 1 Adult (21+) 3.2E-06 3.2E-06 3.2E-06 7.6E-08 7.6E-08 7.6E-08 Youth (11-15) 5.0E-06 5.0E-06 5.0E-06 1.2E-07 1.2E-07 1.2E-07 Lithographic Printer Cleaner 1 Adult (21+) 1.5E-09 1.5E-09 1.5E-09 2.9E-11 2.9E-11 2.9E-11 Youth (11-15) 2.3E-09 2.3E-09 2.3E-09 4.5E-11 4.5E-11 4.5E-11 Spot Cleaner 1 Adult (21+) 1.6E-07 1.6E-07 1.6E-07 1.0E-09 1.0E-09 1.0E-09 Youth (11-15) 2.5E-07 2.5E-07 2.5E-07 1.6E-09 1.6E-09 1.6E-09 Recycling and Disposal 6 Adult (21+) 3. IE—07 2.4E-04 1.2E-03 5.8E-09 1.4E-06 6.7E-06 Youth (11-15) 4.9E-07 3.7E-04 1.9E-03 9.0E-09 2.2E-06 1.0E-05 Other 10 Adult (21+) 1.2E-11 4.3E-07 2.6E-06 3.0E-13 4.5E-09 2.8E-08 Youth (11-15) 1.9E-11 6.6E-07 4.0E-06 4.6E-13 7.0E-09 4.4E-08 DOD 1 Adult (21+) 5.4E-08 5.4E-08 5.4E-08 1.2E-09 1.2E-09 1.2E-09 Youth (11-15) 8.4E-08 8.4E-08 8.4E-08 1.9E-09 1.9E-09 1.9E-09 WWTP 29 Adult (21+) 3.4E-09 7.2E-04 2.0E-02 9.2E-11 3.9E-05 1.1E-03 Youth (11-15) 5.3E-09 1.1E-03 3.1E-02 1.4E-10 6.1E-05 1.7E-03 Overall 82 Adult (21+) 1.2E-11 2.8E-04 2.0E-02 3.0E-13 1.4E-05 1.1E-03 Youth (11-15) 1.9E-11 4.4E-04 3.1E-02 4.6E-13 2.2E-05 1.7E-03 " The minimum exposure for the identified days of release, within the identified OES, and for the identified age group. b The arithmetic mean exposure for the identified days of release, within the identified OES, and for the identified age group. c The maximum exposure for the identified days of release, within the identified OES, and for the identified age group. Page 120 of 204 ------- Public Comment Draft - Do Not Cite of Quote 2 Table 3-23. Summary of MC Incidental Oral Ingestion Exposure by PES for Maximum Days of Release Scenarios OES No. of Releases Modeled Ajje Group ADR (mg/kg-day) ADD (mg/kg-day) Min Exposure" Mean Exposure6 Max Exposure' Min Exposure" Mean Exposure6 Max Exposure' Manufacturing 20 Adult (21+) 3.8E-11 1.3E-06 1.6E-05 1.3E-11 9.2E-07 1.6E-05 Youth (11-15) 5.9E-11 2.0E-06 2.5E-05 2.1E-11 1.4E-06 2.4E-05 Import and Repackaging 5 Adult (21+) 1.4E-10 1.4E-05 6.9E-05 3.5E-11 3.2E-06 1.6E-05 Youth (11-15) 2.2E-10 2.2E-05 1.1E-04 5.5E-11 5.0E-06 2.5E-05 Processing as a Reactant 3 Adult (21+) 4.0E-08 2.6E-07 4.8E-07 1.2E-08 7.9E-08 1.1E-07 Youth (11-15) 6.2E-08 4.1E-07 7.5E-07 1.9E-08 1.2E-07 1.8E-07 Processing: Formulation 9 Adult (21+) 7.9E-12 3.7E-04 3.3E-03 2.4E-12 8.4E-05 7.5E-04 Youth (11-15) 1.2E-11 5.7E-04 5.1E-03 3.7E-12 1.3E-04 1.2E-03 Polyurethane Foam 1 Adult (21+) 2.3E-06 2.3E-06 2.3E-06 4.7E-07 4.7E-07 4.7E-07 Youth (11-15) 3.5E-06 3.5E-06 3.5E-06 7.3E-07 7.3E-07 7.3E-07 Plastics Manufacturing 9 Adult (21+) 1.2E-10 1.9E-06 8.7E-06 3.0E-11 4.0E-07 1.8E-06 Youth (11-15) 1.9E-10 2.9E-06 1.3E-05 4.7E-11 6.2E-07 2.9E-06 CTA Film Manufacturing 1 Adult (21+) 2.6E-07 2.6E-07 2.6E-07 7.6E-08 7.6E-08 7.6E-08 Youth (11-15) 4.0E-07 4.0E-07 4.0E-07 1.2E-07 1.2E-07 1.2E-07 Lithographic Printer Cleaner 1 Adult (21+) 1.2E-10 1.2E-10 1.2E-10 2.9E-11 2.9E-11 2.9E-11 Youth (11-15) 1.8E-10 1.8E-10 1.8E-10 4.5E-11 4.5E-11 4.5E-11 Spot Cleaner 1 Adult (21+) 1.3E-08 1.3E-08 1.3E-08 1.0E-09 1.0E-09 1.0E-09 Youth (11-15) 2.0E-08 2.0E-08 2.0E-08 1.6E-09 1.6E-09 1.6E-09 Recycling and Disposal 14 Adult (21+) 8.8E-09 2.7E-03 3.7E-02 4.3E-09 6.1E-04 8.4E-03 Youth (11-15) 1.4E-08 4.1E-03 5.7E-02 6.7E-09 9.5E-04 1.3E-02 Other 12 Adult (21+) 9.7E-13 1.7E-06 2.0E-05 3.0E-13 4.0E-07 4.6E-06 Youth (11-15) 1.5E-12 2.7E-06 3.1E-05 4.6E-13 6.1E-07 7.2E-06 DOD 1 Adult (21+) 4.3E-09 4.3E-09 4.3E-09 1.2E-09 1.2E-09 1.2E-09 Youth (11-15) 6.7E-09 6.7E-09 6.7E-09 1.9E-09 1.9E-09 1.9E-09 WWTP 29 Adult (21+) 1.9E-10 4.0E-05 1.1E-03 9.2E-11 4.0E-05 1.1E-03 Youth (11-15) 2.9E-10 6.2E-05 1.7E-03 1.4E-10 6.1E-05 1.7E-03 Overall 106 Adult (21+) 9.7E-13 4.0E-04 3.7E-02 3.0E-13 9.9E-05 8.4E-03 Youth (11-15) 1.5E-12 6.1E-04 5.7E-02 4.6E-13 1.5E-04 1.3E-02 " The minimum exposure for the identified days of release, within the identified OES, and for the identified age group. b The arithmetic mean exposure for the identified days of release, within the identified OES, and for the identified age group. c The maximum exposure for the identified days of release, within the identified OES, and for the identified age group. Page 121 of 204 ------- 1 2 3 4 5 6 7 8 9 10 11 Public Comment Draft - Do Not Cite of Quote 3.2.4.2.5 Incidental Dermal for MC Modeled incidental dermal estimates are summarized by OES category in Table 3-24 for the 20-day release scenario and in Table 3-25 for the maximum days of release scenario. Results are presented for the adult (21+ years) age class, but complete by facility results across all age classes for all evaluated releases are available in SFFLA Water Pathway Exposure Data for MC (Appendix B). For the 20-day release scenario, a total of 82 releases were modeled across all OES with incidental dermal exposure ADRs ranging from 1.9x10-11 to 3.1x10-02 mg/kg-day and ADDs ranging from 4.5x10-13 to 1.7x10-03 mg/kg-day. For the maximum release scenario, a total of 106 releases were modeled across all OES with incidental dermal exposure ADRs ranging from 1.5x10-12 to 5.6x10-02 mg/kg-day and ADDs ranging from 4.5x10-13 to 1.3x10-02 mg/kg-day. Page 122 of 204 ------- Public Comment Draft - Do Not Cite of Quote Table 3-24. Summary of MC Incidental Dermal Exposure by PES for 20 Days of Release Scenarios OES No. of Releases Modeled Age Group A OR (mg/kg-day) A DD (mg/kg-day) Min Exposure" Mean Exposure'' Max Exposure'' Min Exposure" Mean Exposure'' Max Exposure'' Manufacturing 14 Adult (21+) 1.0E-09 4.8E-05 4.3E-04 2.1E-11 2.0E-06 2.4E-05 Import and Repackaging 2 Adult (21+) 5.8E-07 1.1E-06 1.7E-06 1.0E-08 2.1E-08 3.2E-08 Processing as a Reactant 2 Adult (21+) 7.0E-06 1.0E-05 1.3E-05 1.7E-07 1.7E-07 1.8E-07 Processing: Formulation 5 Adult (21+) 3.9E-09 6.5E-05 3.2E-04 7.8E-11 3.0E-07 1.5E-06 Polyurethane Foam 1 Adult (21+) 4.3E-05 4.3E-05 4.3E-05 7.3E-07 7.3E-07 7.3E-07 Plastics Manufacturing 9 Adult (21+) 2.3E-09 3.6E-05 1.6E-04 4.6E-11 6.1E-07 2.8E-06 CTA Film Manufacturing 1 Adult (21+) 4.9E-06 4.9E-06 4.9E-06 1.1E-07 1.1E-07 1.1E-07 Lithographic Printer Cleaner 1 Adult (21+) 2.2E-09 2.2E-09 2.2E-09 4.4E-11 4.4E-11 4.4E-11 Spot Cleaner 1 Adult (21+) 2.4E-07 2.4E-07 2.4E-07 1.5E-09 1.5E-09 1.5E-09 Recycling and Disposal 6 Adult (21+) 4.8E-07 3.6E-04 1.9E-03 8.8E-09 2.1E-06 1.0E-05 Other 10 Adult (21+) 1.9E-11 6.5E-07 3.9E-06 4.5E-13 6.8E-09 4.3E-08 DOD 1 Adult (21+) 8.2E-08 8.2E-08 8.2E-08 1.9E-09 1.9E-09 1.9E-09 WWTP 29 Adult (21+) 5.2E-09 1.1E-03 3.1E-02 1.4E-10 6.0E-05 1.7E-03 Overall 82 Adult (21+) 1.9E-11 4.3E-04 3.1E-02 4.5E-13 2.2E-05 1.7E-03 a The minimum exposure for the identified days of release, wit b The arithmetic exposure ADR for the identified days of relea c The maximum exposure for the identified days of release, wii lin the identified OES, and for the identified age group, sc. within the identified OES, and for the identified age group, thin the identified OES, and for the identified age group. Page 123 of 204 ------- Public Comment Draft - Do Not Cite of Quote Table 3-25. Summary of Methylene Chloride Incidenta Dermal Exposure by PES for Maximum Days of Release Scenarios OES No. of Releases Modeled Age Group A OR (mg/kg-day) A] 0D (mg/kg-day) Min Exposure" Mean Exposure'' Max Exposure'' Min Exposure" Mean Exposure'' Max Exposure'' Manufacturing 20 Adult (21+) 5.8E-11 2.0E-06 2.5E-05 2.1E-11 1.4E-06 2.4E-05 Import and Repackaging 5 Adult (21+) 2.1E-10 2.1E-05 1.1E-04 5.4E-11 4.9E-06 2.4E-05 Processing as a Reactant 3 Adult (21+) 6.0E-08 4.0E-07 7.3E-07 1.9E-08 1.2E-07 1.7E-07 Processing: Formulation 9 Adult (21+) 1.2E-11 5.6E-04 5.0E-03 3.6E-12 1.3E-04 1.1E-03 Polyurethane Foam 1 Adult (21+) 3.5E-06 3.5E-06 3.5E-06 7.2E-07 7.2E-07 7.2E-07 Plastics Manufacturing 9 Adult (21+) 1.8E-10 2.9E-06 1.3E-05 4.6E-11 6.1E-07 2.8E-06 CTA Film Manufacturing 1 Adult (21+) 3.9E-07 3.9E-07 3.9E-07 1.1E-07 1.1E-07 1.1E-07 Lithographic Printer Cleaner 1 Adult (21+) 1.8E-10 1.8E-10 1.8E-10 4.4E-11 4.4E-11 4.4E-11 Spot Cleaner 1 Adult (21+) 2.0E-08 2.0E-08 2.0E-08 1.5E-09 1.5E-09 1.5E-09 Recycling and Disposal 14 Adult (21+) 1.3E-08 4.0E-03 5.6E-02 6.6E-09 9.3E-04 1.3E-02 Other 12 Adult (21+) 1.5E-12 2.6E-06 3.1E-05 4.5E-13 6.0E-07 7.0E-06 DOD 1 Adult (21+) 6.6E-09 6.6E-09 6.6E-09 1.9E-09 1.9E-09 1.9E-09 WWTP 29 Adult (21+) 2.9E-10 6.0E-05 1.7E-03 1.4E-10 6.0E-05 1.7E-03 Overall 106 Adult (21+) 1.5E-12 6.0E-04 5.6E-02 4.5E-13 1.5E-04 1.3E-02 a The minimum exposure for the identified days of release, within the identified OES, and for the identified age group. b The arithmetic exposure ADR for the identified days of release, within the identified OES, and for the identified age group. c The maximum exposure for the identified days of release, within the identified OES, and for the identified age group. Page 124 of 204 ------- 1 2 3 4 5 6 7 8 9 10 11 12 3.2,5 Public Comment Draft - Risk Characterization for MC Do Not Cite or Quote 3.2.5.1 Risk Characterization for the Air Pathway EPA calculated risk estimates for each of the endpoints in Table 3-13 across all known TRI reporters and other modeled facilities under each OES. EPA calculated risk estimates for each facility using the 10th, 50th, and 95th percentile of modeled exposure concentrations around the releasing facility. The 95th percentile estimates were then further distilled across facilities within each OES to present the range from minimum to maximum risk. Based on the 95th percentile values, risks were indicated for at least one facility relative to benchmark for 8 of 17 OES. Risks were not indicated for any OES beyond 100 meters from a facility. These results are summarized below in Table 3-26. Results for 10th and 50th percentile measurements along with facility-specific results are provided in SFFLA Air Pathway Full-Screen Results for MC (Appendix B). Page 125 of 204 ------- Public Comment Draft - Do Not Cite or Quote 1 Table 3-26. MC Inhalation Risk across OES at Various Distances from Releasing Facility (Based on 95th percentile exposure 2 Conce Occupational Exposure Scenario Number of TRI Facilities Distance from Facility (meters) Estimated MOE Estimated Cancer Risk Non-cancer Cancer (Benchmark 1E-06) Acute (Benchmark 30) Chronic (Benchmark 10) Total w/ Risk Single Facility Min Risk* Mean Riskc Max Riskrf Single Facility Min Risk Mean Risk Max Risk Single Facility Min Risk Mean Risk Max Risk Batch Open- Top Degreasing 1 0 5 6.7E+04 - - - 2.7E+04 - - - 3.7E-09 - - - 10 4.9E+04 - - - 2.0E+04 - - - 5.0E-09 - - - 30 1.0E+05 - - - 4.2E+04 - - - 2.4E-09 - - - 60 4.2E+04 - - - 1.5E+04 - - - 6.6E-09 - - - 100 2.4E+04 - - - 88,881 - - - 1.1E-08 - - - 100-1,000 1.0E+05 - - - 2.5E+04 - - - 4.0E-09 - - - 2,500 6.4E+05 - - - 3.0E+05 - - - 3.3E-10 - - - 5,000 1.7E+06 - - - 8.0E+05 - - - 1.3E-10 - - - 10,000 4.8E+06 - - - 2.1E+06 - - - 4.7E-11 - - - Cellulose Triacetate Film Production 2 1 5 N/A 1.3E+05 307 154 N/A 3.0E+04 70 35 N/A 3.3E-09 1.4E-06 2.8E-06 10 N/A 1.0E+05 234 117 N/A 2.2E+04 53 26 N/A 4.5E-09 1.9E-06 3.8E-06 30 N/A 2.9E+05 703 352 N/A 6.1E+04 173 87 N/A 1.6E-09 5.8E-07 1.2E-06 60 N/A 5.9E+05 1,880 942 N/A 1.2E+05 507 254 N/A 8.1E-10 2.0E-07 3.9E-07 100 N/A 7.1E+05 4,225 2,119 N/A 1.7E+05 1,225 615 N/A 6.0E-10 8.2E-08 1.6E-07 100-1,000 N/A 2.8E+06 7.0E+04 3.5E+04 N/A 5.3E+05 1.3E+04 6,640 N/A 1.9E-10 7.6E-09 1.5E-08 2,500 N/A 1.5E+07 8.6E+05 4.4E+05 N/A 3.4E+06 2.6E+05 1.4E+05 N/A 3.0E-11 3.8E-10 7.3E-10 5,000 N/A 4.1E+07 2.6E+06 1.4E+06 N/A 9.4E+06 8.0E+05 4.2E+05 N/A 1.1E—11 1.2E-10 2.4E-10 10,000 N/A 1.2E+08 8.1E+06 4.2E+06 N/A 2.8E+07 2.4E+06 1.3E+06 N/A 3.6E-12 4.1E-11 7.9E-11 Cleaner/ Degreaser - Unknowne 16 3 5 N/A 1.0E+13 1,250 325 N/A 6.3E+11 384 85 N/A 1.6E-16 2.6E-07 1.2E-06 10 N/A 1.4E+11 968 201 N/A 2.3E+10 300 74 N/A 4.4E-15 3.3E-07 1.3E-06 30 N/A 7.7E+07 2,721 467 N/A 1.9E+07 887 204 N/A 5.4E-12 1.1E-07 4.9E-07 60 N/A 4.5E+06 7,046 1,182 N/A 1.7E+06 2,332 528 N/A 5.8E-11 4.3E-08 1.9E-07 100 N/A 2.1E+06 1.5E+04 2,618 N/A 8.4E+05 4,940 1,149 N/A 1.2E-10 2.0E-08 8.7E-08 100-1,000 N/A 1.0E+07 2.1E+05 5.0E+04 N/A 2.5E+06 4.0E+04 9,690 N/A 4.1E-11 2.5E-09 1.0E-08 2,500 N/A 7.7E+07 2.3E+06 7.9E+05 N/A 3.2E+07 7.9E+05 2.3E+05 N/A 3.1E-12 1.3E-10 4.4E-10 5,000 N/A 2.0E+08 6.5E+06 2.5E+06 N/A 7.2E+07 2.2E+06 6.8E+05 N/A 1.4E-12 4.6E-11 1.5E-10 Page 126 of 204 ------- Public Comment Draft - Do Not Cite or Quote Occupational Exposure Scenario Number of TRI Facilities Distance from Facility (meters) Estimated MOE Estimated Cancer Risk Non-cancer Cancer (Benchmark 1E-06) Acute (Benchmark 30) Chronic (Benchmark 10) Total w/ Risk Single Facility Min Risk* Mean Riskc Max Riskrf Single Facility Min Risk Mean Risk Max Risk Single Facility Min Risk Mean Risk Max Risk 10,000 N/A 5.6E+08 1.8E+07 7.5E+06 N/A 1.7E+08 5.8E+06 2.0E+06 N/A 5.9E-13 1.7E-11 5.1E-11 Commercial Aerosol Products (Aerosol Degreasing, Aerosol Lubricants, Automotive Care Products) a - 5 N/A 2.6E+04 1.5E+04 9,843 N/A 1.3E+04 5,415 3,165 N/A 8.0E-09 1.8E-08 3.2E-08 10 N/A 1.5E+04 1.0E+04 7,657 N/A 6,906 3,862 2,513 N/A 1.4E-08 2.6E-08 4.0E-08 30 N/A 3.6E+04 2.9E+04 2.5E+04 N/A 1.7E+04 1.2E+04 9,058 N/A 5.7E-09 8.2E-09 1.1E-08 60 N/A 1.1E+05 8.5E+04 6.9E+04 N/A 4.8E+04 3.6E+04 2.8E+04 N/A 2.1E-09 2.8E-09 3.6E-09 100 N/A 2.9E+05 2.2E+05 1.8E+05 N/A 1.2E+05 9.4E+04 7.5E+04 N/A 8.2E-10 1.1E-09 1.3E-09 100-1,000 N/A 1.1E+07 9.0E+06 7.4E+06 N/A 1.8E+06 1.4E+06 1.2E+06 N/A 5.5E-11 7.0E-11 8.4E-11 2,500 N/A 2.9E+08 2.3E+08 1.9E+08 N/A 1.2E+08 7.7E+07 4.7E+07 N/A 8.5E-13 1.3E-12 2.1E-12 5,000 N/A 1.1E+09 8.4E+08 6.9E+08 N/A 4.2E+08 2.5E+08 1.4E+08 N/A 2.4E-13 4.0E-13 7.0E-13 10,000 N/A 3.3E+09 2.2E+09 1.7E+09 N/A 9.8E+08 6.1E+08 3.6E+08 N/A 1.0E-13 1.6E-13 2.8E-13 Fabric Finishing l 0 5 7,899 - - - 2,525 - - - 4.0E-08 - - - 10 6,378 - - - 1,754 - - - 5.7E-08 - - - 30 1.7E+04 - - - 4,464 - - - 2.2E-08 - - - 60 4.4E+04 - - - 1.1E+04 - - - 8.8E-09 - - - 100 9.5E+04 - - - 2.5E+04 - - - 4.0E-09 - - - 100-1,000 1.5E+06 - - - 2.7E+05 - - - 3.7E-10 - - - 2,500 2.0E+07 - - - 5.8E+06 - - - 1.7E-11 - - - 5,000 6.2E+07 - - - 1.9E+07 - - - 5.3E-12 - - - 10,000 1.9E+08 - - - 5.9E+07 - - - 1.7E-12 - - - Flexible Polyurethane Foam Manufacturing l 1 5 17 - - - 5 - - - 2.2E-05 - - - 10 13 - - - 4 - - - 2.6E-05 - - - 30 40 - - - 11 - - - 9.5E-06 - - - 60 101 - - - 26 - - - 3.8E-06 - - - 100 217 - - - 57 - - - 1.8E-06 - - - 100-1,000 3,401 - - - 588 - - - 1.7E-07 - - - 2,500 3.9E+04 - - - 1.1E+04 - - - 9.4E-09 - - - 5,000 1.2E+05 - - - 3.3E+04 - - - 3.1E-09 - - - 10,000 3.7E+05 - - - 1.0E+05 - - - 1.0E-09 - - - Page 127 of 204 ------- Public Comment Draft - Do Not Cite or Quote Occupational Exposure Scenario Number of TRI Facilities Distance from Facilitv (meters) Estimated MOE Estimated Cancer Risk Non-cancer Cancer (Benchmark 1E-06) Acute (Benchmark 30) Chronic (Benchmark 10) Total w/ Risk Single Facilitv Min Risk6 Mean Risk' Max Risk'' Single Facilitv Min Risk Mean Risk Max Risk Single Facilitv Min Risk Mean Risk Max Risk Laboratory Use 5 0 5 N/A 1.2E+11 3.2E+04 9,901 N/A 1.1E+10 8,335 2,551 N/A 8.7E-15 1.2E-08 3.9E-08 10 N/A 8.2E+08 1.9E+04 5,102 N/A 3.5E+08 4,942 1,330 N/A 2.8E-13 2.0E-08 7.5E-08 30 N/A 9.6E+06 3.9E+04 9,615 N/A 3.0E+06 1.2E+04 2,976 N/A 3.3E-11 8.3E-09 3.4E-08 60 N/A 2.0E+06 8.3E+04 2.2E+04 N/A 3.0E+05 2.6E+04 7,194 N/A 3.4E-10 3.8E-09 1.4E-08 100 N/A 1.4E+06 1.4E+05 4.4E+04 N/A 2.5E+05 4.0E+04 1.5E+04 N/A 4.0E-10 2.5E-09 6.8E-09 100-1,000 N/A 1.6E+07 1.0E+06 3.9E+05 N/A 2.5E+06 1.9E+05 7.2E+04 N/A 3.9E-11 5.4E-10 1.4E-09 2,500 N/A 1.0E+08 4.6E+06 1.3E+06 N/A 2.0E+07 1.4E+06 3.8E+05 N/A 5.0E-12 7.1E-11 2.6E-10 5,000 N/A 2.0E+08 8.8E+06 2.3E+06 N/A 4.0E+07 2.7E+06 6.8E+05 N/A 2.5E-12 3.8E-11 1.5E-10 10,000 N/A 4.3E+08 1.8E+07 4.5E+06 N/A 9.0E+07 5.7E+06 1.4E+06 N/A 1.1E—12 1.8E-11 7.2E-11 Lithographic Printing Plate Cleaning 1 0 5 3.1E+12 - - - 1.8E+11 - - - 5.5E-16 - - - 10 1.5E+10 - - - 1.2E+09 - - - 8.2E-14 - - - 30 1.1E+07 - - - 3.0E+06 - - - 3.3E-11 - - - 60 6.9E+05 - - - 1.6E+05 - - - 6.1E-10 - - - 100 3.1E+05 - - - 7.5E+04 - - - 1.3E-09 - - - 100-1,000 7.9E+05 - - - 2.1E+05 - - - 4.9E-10 - - - 2,500 4.2E+06 - - - 2.0E+06 - - - 4.9E-11 - - - 5,000 1.1E+07 - - - 5.2E+06 - - - 1.9E-11 - - - 10,000 2.8E+07 - - - 1.3E+07 - - - 7.6E-12 - - - Manufacturing 11 0 5 N/A 1.8E+16 5,354 1,706 N/A 1.8E+15 1,185 342 N/A 5.4E-20 8.4E-08 2.9E-07 10 N/A 6.6E+14 3,235 936 N/A 8.7E+13 694 180 N/A 1.2E-18 1.4E-07 5.6E-07 30 N/A 2.0E+12 7,032 1,880 N/A 4.6E+11 1,548 368 N/A 2.2E-16 6.5E-08 2.7E-07 60 N/A 1.3E+11 1.6E+04 4,348 N/A 1.9E+10 3,646 865 N/A 5.4E-15 2.7E-08 1.2E-07 100 N/A 5.1E+10 3.2E+04 8,651 N/A 8.2E+09 7,061 1,742 N/A 1.2E-14 1.4E-08 5.7E-08 100-1,000 N/A 1.2E+11 3.1E+05 1.0E+05 N/A 2.4E+10 5.4E+04 1.6E+04 N/A 4.2E-15 1.8E-09 6.1E-09 2,500 N/A 7.4E+11 2.4E+06 9.9E+05 N/A 2.3E+11 6.4E+05 2.3E+05 N/A 4.4E-16 1.6E-10 4.3E-10 5,000 N/A 1.8E+12 6.0E+06 2.4E+06 N/A 5.8E+11 1.6E+06 5.4E+05 N/A 1.7E-16 6.2E-11 1.8E-10 10,000 N/A 4.3E+12 1.6E+07 6.1E+06 N/A 1.6E+12 4.3E+06 1.4E+06 N/A 6.3E-17 2.3E-11 7.0E-11 Page 128 of 204 ------- Public Comment Draft - Do Not Cite or Quote Occupational Exposure Scenario Number of TRI Facilities Distance from Facility (meters) Estimated MOE Estimated Cancer Risk Non-cancer Cancer (Benchmark 1E-06) Acute (Benchmark 30) Chronic (Benchmark 10) Total w/ Risk Single Facility Min Risk* Mean Riskc Max Riskrf Single Facility Min Risk Mean Risk Max Risk Single Facility Min Risk Mean Risk Max Risk Miscellaneous Non-aerosol Industrial and Commercial Uses f 31 2 5 N/A 8.0E+12 394 13 N/A 5.6E+11 85 3 N/A 1.8E-16 1.2E-06 3.6E-05 10 N/A 6.5E+10 351 12 N/A 5.0E+09 73 2 N/A 2.0E-14 1.4E-06 4.1E-05 30 N/A 1.1E+08 1,036 37 N/A 2.9E+07 232 8 N/A 3.5E-12 4.3E-07 1.3E-05 60 N/A 7.5E+06 2,642 96 N/A 1.7E+06 606 21 N/A 5.9E-11 1.6E-07 4.7E-06 100 N/A 4.2E+06 5,506 212 N/A 1.2E+06 1,293 47 N/A 8.5E-11 7.7E-08 2.1E-06 100-1,000 N/A 1.9E+07 6.9E+04 3,378 N/A 4.7E+06 1.2E+04 502 N/A 2.1E-11 8.6E-09 2.0E-07 2,500 N/A 8.5E+07 6.3E+05 4.1E+04 N/A 2.9E+07 1.8E+05 9,823 N/A 3.5E-12 5.7E-10 1.0E-08 5,000 N/A 2.3E+08 1.7E+06 1.3E+05 N/A 5.4E+07 4.9E+05 3.0E+04 N/A 1.8E-12 2.0E-10 3.3E-09 10,000 N/A 6.9E+08 4.7E+06 3.8E+05 N/A 1.5E+08 1.4E+06 9.3E+04 N/A 6.6E-13 7.2E-11 1.1E-09 Plastic Product Manufacturing 7 2 5 N/A 5.8E+13 215 55 N/A 3.1E+11 68 17 N/A 3.2E-16 1.5E-06 5.8E-06 10 N/A 1.1E+11 123 33 N/A 2.6E+09 38 11 N/A 3.8E-14 2.6E-06 9.4E-06 30 N/A 8.9E+06 261 76 N/A 2.6E+06 79 22 N/A 3.8E-11 1.3E-06 4.6E-06 60 N/A 2.1E+07 618 179 N/A 6.5E+06 188 51 N/A 1.5E-11 5.3E-07 2.0E-06 100 N/A 4.2E+07 1,253 357 N/A 1.3E+07 380 100 N/A 7.4E-12 2.6E-07 1.0E-06 100-1000 N/A 5.1E+08 1.6E+04 4,386 N/A 1.1E+08 3,297 935 N/A 9.5E-13 3.0E-08 1.1E-07 2,500 N/A 4.9E+09 1.7E+05 4.5E+04 N/A 1.8E+09 6.4E+04 1.6E+04 N/A 5.4E-14 1.6E-09 6.4E-09 5,000 N/A 1.3E+10 4.9E+05 1.3E+05 N/A 5.3E+09 1.9E+05 4.5E+04 N/A 1.9E-14 5.3E-10 2.2E-09 10,000 N/A 3.6E+10 1.4E+06 3.6E+05 N/A 1.5E+10 5.6E+05 1.3E+05 N/A 6.5E-15 1.8E-10 7.5E-10 Processing - Incorporation into Formulation, Mixture, or Reaction Product 50 3 5 N/A 2.4E+14 1,615 54 N/A 7.2E+12 382 13 N/A 1.4E-17 2.6E-07 7.8E-06 10 N/A 8.2E+11 1,148 33 N/A 1.4E+11 276 8 N/A 7.0E-16 3.6E-07 1.2E-05 30 N/A 4.1E+09 2,780 75 N/A 1.1E+09 728 21 N/A 8.8E-14 1.4E-07 4.8E-06 60 N/A 6.1E+08 6,745 179 N/A 1.0E+08 1,826 52 N/A 1.0E-12 5.5E-08 1.9E-06 100 N/A 3.2E+08 1.4E+04 376 N/A 5.8E+07 3,887 111 N/A 1.7E-12 2.6E-08 9.0E-07 100-1000 N/A 8.9E+08 1.9E+05 5,382 N/A 1.9E+08 3.3E+04 899 N/A 5.4E-13 3.1E-09 1.1E-07 2500 N/A 4.9E+09 2.2E+06 6.5E+04 N/A 1.4E+09 6.6E+05 2.1E+04 N/A 6.9E-14 1.5E-10 4.7E-09 5000 N/A 1.3E+10 6.4E+06 2.0E+05 N/A 4.1E+09 2.0E+06 6.6E+04 N/A 2.4E-14 5.1E-11 1.5E-09 10000 N/A 3.9E+10 1.9E+07 6.1E+05 N/A 1.2E+10 5.8E+06 2.0E+05 N/A 8.4E-15 1.7E-11 5.0E-10 Page 129 of 204 ------- Public Comment Draft - Do Not Cite or Quote Occupational Exposure Scenario Number of TRI Facilities Distance from Facilitv (meters) Estimated MOE Estimated Cancer Risk Non-cancer Cancer (Benchmark 1E-06) Acute (Benchmark 30) Chronic (Benchmark 10) Total w/ Risk Single Facilitv Min Risk6 Mean Risk' Max Risk'' Single Facilitv Min Risk Mean Risk Max Risk Single Facilitv Min Risk Mean Risk Max Risk Processing as a Reactant 14 1 5 N/A 6.8E+12 4,502 476 N/A 3.3E+12 1.184 126 N/A 3.0E-17 8.4E-08 7.9E-07 10 N/A 4.4E+11 3,236 355 N/A 1.3E+11 845 94 N/A 7.5E-16 1.2E-07 1.1E-06 30 N/A 1.4E+09 8,755 1,010 N/A 6.3E+08 2,152 245 N/A 1.6E-13 4.6E-08 4.1E-07 60 N/A 1.1E+08 2.1E+04 2,463 N/A 3.2E+07 5,250 608 N/A 3.2E-12 1.9E-08 1.6E-07 100 N/A 5.0E+07 4.2E+04 5,139 N/A 1.2E+07 1.0E+04 1,269 N/A 8.3E-12 9.6E-09 7.9E-08 100-1,000 N/A 1.3E+08 4.2E+05 5.9E+04 N/A 2.6E+07 7.4E+04 9,940 N/A 3.8E-12 1.3E-09 1.0E-08 2,500 N/A 5.0E+08 3.4E+06 5.4E+05 N/A 1.4E+08 1.0E+06 1.6E+05 N/A 7.4E-13 9.6E-11 6.1E-10 5,000 N/A 1.0E+09 8.0E+06 1.3E+06 N/A 3.3E+08 2.7E+06 4.3E+05 N/A 3.0E-13 3.8E-11 2.3E-10 10000 N/A 2.6E+09 2.0E+07 3.2E+06 N/A 8.8E+08 6.9E+06 1.1E+06 N/A 1.1E—13 1.4E-11 8.8E-11 Repackaging 22 0 5 N/A 7.6E+20 2.3E+04 6,289 N/A 4.4E+15 9,658 2,703 N/A 2.3E-20 1.0E-08 3.7E-08 10 N/A 2.8E+14 1.6E+04 6,083 N/A 1.3E+12 7,279 2,564 N/A 7.5E-17 1.4E-08 3.9E-08 30 N/A 1.4E+08 4.9E+04 1.7E+04 N/A 2.2E+07 2.5E+04 9,091 N/A 4.5E-12 4.0E-09 1.1E-08 60 N/A 7.2E+06 1.4E+05 4.7E+04 N/A 3.7E+06 7.2E+04 2.7E+04 N/A 2.7E-11 1.4E-09 3.7E-09 100 N/A 2.0E+07 3.3E+05 1.1E+05 N/A 1.0E+07 1.6E+05 6.0E+04 N/A 9.8E-12 6.1E-10 1.7E-09 100-1,000 N/A 1.0E+09 9.9E+06 2.7E+06 N/A 1.3E+08 1.5E+06 4.3E+05 N/A 7.4E-13 6.6E-11 2.3E-10 2,500 N/A 4.0E+10 3.2E+08 8.1E+07 N/A 1.1E+10 8.4E+07 2.4E+07 N/A 9.5E-15 1.2E-12 4.2E-12 5,000 N/A 2.5E+11 1.6E+09 3.0E+08 N/A 3.1E+10 2.4E+08 6.5E+07 N/A 3.2E-15 4.1E-13 1.5E-12 10,000 N/A 1.6E+12 5.2E+09 9.2E+08 N/A 6.6E+10 5.2E+08 1.4E+08 N/A 1.5E-15 1.9E-13 7.2E-13 Spot Cleaning - - 5 N/A 1.4E+05 9.4E+04 7.1E+04 N/A 6.9E+04 3.3E+04 2.1E+04 N/A 1.5E-09 3.0E-09 4.7E-09 10 N/A 7.9E+04 6.4E+04 5.5E+04 N/A 3.7E+04 2.3E+04 1.7E+04 N/A 2.7E-09 4.3E-09 6.0E-09 30 N/A 1.9E+05 1.8E+05 1.7E+05 N/A 9.1E+04 7.2E+04 5.9E+04 N/A 1.1E-09 1.4E-09 1.7E-09 60 N/A 5.6E+05 5.2E+05 4.9E+05 N/A 2.5E+05 2.1E+05 1.8E+05 N/A 4.0E-10 4.8E-10 5.5E-10 100 N/A 1.5E+06 1.4E+06 1.3E+06 N/A 6.2E+05 5.5E+05 4.9E+05 N/A 1.6E-10 1.8E-10 2.0E-10 100-1,000 N/A 5.7E+07 5.3E+07 4.9E+07 N/A 8.8E+06 8.0E+06 6.9E+06 N/A LIE—11 1.3E-11 1.4E-11 2,500 N/A 1.6E+09 1.4E+09 1.2E+09 N/A 5.8E+08 4.3E+08 3.1E+08 N/A 1.7E-13 2.3E-13 3.2E-13 5,000 N/A 5.3E+09 5.0E+09 4.6E+09 N/A 2.1E+09 1.4E+09 9.7E+08 N/A 4.7E-14 7.0E-14 1.0E-13 10,000 N/A 1.5E+10 1.3E+10 1.2E+10 N/A 5.2E+09 3.6E+09 2.6E+09 N/A 1.9E-14 2.8E-14 3.9E-14 Page 130 of 204 ------- Public Comment Draft - Do Not Cite or Quote Occupational Exposure Scenario Number of TRI Facilities Distance from Facility (meters) Estimated MOE Estimated Cancer Risk Non-cancer Cancer (Benchmark 1E-06) Acute (Benchmark 30) Chronic (Benchmark 10) Total w / Risk Single Facility Min Risk* Mean Riskc Max Riskrf Single Facility Min Risk Mean Risk Max Risk Single Facility Min Risk Mean Risk Max Risk Waste Handling, Disposal, Treatment, and Recycling 30 0 5 N/A 5.0E+11 1.8E+04 1,299 N/A 2.6E+10 4,384 255 N/A 3.9E-15 2.3E-08 3.9E-07 10 N/A 4.6E+09 1.4E+04 1,543 N/A 1.9E+08 3,425 276 N/A 5.3E-13 2.9E-08 3.6E-07 30 N/A 4.3E+07 3.6E+04 5,794 N/A 1.3E+07 9,023 1,029 N/A 7.6E-12 1.1E-08 9.7E-08 60 N/A 1.1E+08 8.6E+04 1.4E+04 N/A 3.2E+07 2.3E+04 2,941 N/A 3.2E-12 4.4E-09 3.4E-08 100 N/A 2.1E+08 1.7E+05 2.8E+04 N/A 6.4E+07 4.6E+04 6,640 N/A 1.6E-12 2.2E-09 1.5E-08 100-1,000 N/A 2.4E+09 1.7E+06 2.4E+05 N/A 4.9E+08 3.5E+05 6.2E+04 N/A 2.1E-13 2.9E-10 1.6E-09 2,500 N/A 1.8E+10 1.6E+07 1.6E+06 N/A 6.6E+09 5.2E+06 6.0E+05 N/A 1.5E-14 1.9E-11 1.7E-10 5,000 N/A 4.1E+10 4.3E+07 4.4E+06 N/A 1.5E+10 1.5E+07 1.7E+06 N/A 6.5E-15 6.7E-12 5.9E-11 10,000 N/A 1.1E+11 1.3E+08 1.3E+07 N/A 3.7E+10 4.3E+07 5.0E+06 N/A 2.7E-15 2.3E-12 2.0E-11 Paint Remover 3 1 5 N/A 4.2E+10 871 316 N/A 3.5E+09 206 73 N/A 2.8E-14 4.9E-07 1.4E-06 10 N/A 1.8E+08 526 190 N/A 5.4E+07 112 40 N/A 1.9E-12 8.9E-07 2.5E-06 30 N/A 9.4E+05 1,181 424 N/A 1.4E+05 249 88 N/A 7.0E-10 4.0E-07 1.1E-06 60 N/A 1.5E+05 2,826 1,050 N/A 2.14E+04 601 218 N/A 4.7E-09 1.7E-07 4.6E-07 100 N/A 7.4E+04 5,372 2,242 N/A 1.5E+04 1,183 467 N/A 6.8E-09 8.5E-08 2.1E-07 100-1,000 N/A 2.4E+04 5.2E+04 3.4E+04 N/A 3.6E+04 1.0E+04 6,173 N/A 2.7E-09 9.7E-09 1.6E-08 2,500 N/A 1.3E+06 3.1E+05 1.6E+05 N/A 2.1E+05 8.4E+04 5.0E+04 N/A 4.7E-10 1.2E-09 2.0E-09 5,000 N/A 3.4E+06 7.1E+05 3.2E+05 N/A 5.8E+05 1.9E+05 9.6E+04 N/A 1.7E-10 5.2E-10 1.0E-09 10,000 N/A 9.6E+06 1.7E+06 7.1E+05 N/A 1.7E+06 4.7E+05 2.2E+05 N/A 5.9E-11 2.1E-10 4.5E-10 " When (-) is indicated for the total number of facilities, no facilities were identified via TRI reporting. The provided estimates are based on modeling of theoretical facilities. h The minimum risk value is associated with the maximum MOE and the maximum ADR. c The mean risk value is the arithmetic mean MOE. ''The maximum risk value is associated with the minimum MOE and the minimum ADR. e This OES designation is a grouping of the following COUs from the 2020 Methylene Chloride Risk Evaluation: Conveyorized Vapor Degreasing and Cold Cleaning. See Section 3.2.3.2. f This OES designation includes a grouping of the following COUs from the 2020 Methylene Chloride Risk Evaluation: Adhesives and Sealants, Paints and Coatings, and Adhesive and Caulk Removers. 3 4 Page 131 of 204 ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Public Comment Draft - Do Not Cite or Quote 3.2.5.1.1 Land Use Considerations EPA identified risk for 14 of the 248 facilities evaluated based on modeled air concentrations. GIS locations were available for all 14 facilities with risk. For each of these 14 facilities, EPA evaluated land use patterns to determine whether fenceline community exposures are reasonably anticipated at locations where risk is indicated. Details of this methodology are provided in Section 2.1.2.2. In short, EPA evaluated whether residential, industrial/commercial businesses, or other public spaces are present within those radial distances indicating risk (as opposed to uninhabited areas), as well as whether the radial distance lies outside the boundaries of the facility. Based on characterization of land use patterns, fenceline community exposures are reasonably anticipated for 2 of the 14 facilities (14 percent) where risk is indicated based on modeled fenceline air concentrations. Table 3-28 summarizes the number of facilities in each OES for which risk is indicated and where fenceline community exposures are reasonably anticipated. Table 3-27. Summary of Fenceline Community Exposures Expected near Facilities Where Modeled Air Concentrations Indicated Risk for M< OES Total Number of Facilities Evaluated Number of Facilities with Risk Indicated Number of Facilities with Risk Indicated and Exposures Expected Percent of Total Facilities with Risk Indicated and Exposures Expected Miscellaneous Non-aerosol 31 2 1 3% Cellulose 2 1 0 0% Processing - Incorporation into Formulation, Mixture or Reaction Product 50 3 0 0% Flexible Polyurethane Foam Manufacturing 1 1 1 100% Plastic Product Manufacturing 7 2 0 0% Processing- Reactant 14 1 0 0% Cleaner/Degreaser 16 3 0 0% Paint Remover 3 1 0 0% Page 132 of 204 ------- Public Comment Draft - Do Not Cite or Quote 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 3.2.5.2 Risk Characterization for the Water Pathway 3.2.5.2.1 Drinking Water Risk for MC EPA calculated risk estimates for each of the endpoints in Table 3-13 across all known facilities and modeled release scenarios under each OES. These estimates were then summarized across facilities to present the range from minimum to maximum risk for multiple lifestages under each OES. For cancer, total lifetime cancer risk across lifestages was calculated by integrating partial risk for each lifestage based on differential exposure and consideration of age-dependent adjustment factors (ADAFs, Qj.S. •05)). For MC, ADAFs were applied for younger lifestages based on the conclusion that MC is carcinogenic through a mutagenic mode of action ( 2020c). For the maximum days of release scenario, acute but not chronic non-cancer risks (Table 3-30) and cancer risks (Table 3-31) were indicated relative to the benchmarks for MC for at least one facility in the recycling and disposal OES. Risks relative to benchmark for MC were not indicated for any OES for the 20-day release scenario (Table 3-28, Table 3-29). Table 3-28. Summary of Non-cancer Risk Estimates for Drinking Water Exposures by OES under OES No. of Releases Modeled Age Group Acute MOE (Benchmark = 30) Chronic MOE (Benchmark = 30) Min Risk" Mean Risk* Max Riskc Min Risk2 Mean Risk* Max Risk' Manufacturing 12 Adult (21+) 4.1E+09 9.6E+08 2.5E+04 7.0E+10 1.9E+10 9.9E+05 Infant (birth to <1) 1.2E+09 2.7E+08 7,012 2.7E+10 7.4E+09 3.9E+05 Import and Repackaging 2 Adult (21+) 7.2E+06 4.9E+06 2.5E+06 1.4E+08 9.3E+07 4.5E+07 Infant (birth to <1) 2.1E+06 1.4E+06 7.1E+05 5.5E+07 3.6E+07 1.8E+07 Processing as a Reactant 2 Adult (21+) 5.9E+05 4.6E+05 3.2E+05 8.6E+06 8.4E+06 8.2E+06 Infant (birth to <1) 1.7E+05 1.3E+05 9.1E+04 3.4E+06 3.3E+06 3.2E+06 Processing: Formulation 5 Adult (21+) 1.1E+09 2.5E+08 1.3E+04 1.8E+10 4.5E+09 9.5E+05 Infant (birth to <1) 3.1E+08 7.3E+07 3,660 7.2E+09 1.8E+09 3.7E+05 Polyurethane Foam 1 Adult (21+) 9.7E+04 9.7E+04 9.7E+04 2.0E+06 2.0E+06 2.0E+06 Infant (birth to <1) 2.8E+04 2.8E+04 2.8E+04 7.7E+05 7.7E+05 7.7E+05 Plastics Manufacturing 9 Adult (21+) 1.8E+09 2.5E+08 2.5E+04 3.1E+10 4.2E+09 5.2E+05 Infant (birth to <1) 5.2E+08 7.3E+07 7,232 1.2E+10 1.6E+09 2.0E+05 CTA Film Manufacturing 1 Adult (21+) 8.5E+05 8.5E+05 8.5E+05 1.2E+07 1.2E+07 1.2E+07 Infant (birth to <1) 2.4E+05 2.4E+05 2.4E+05 4.9E+06 4.9E+06 4.9E+06 Lithographic Printer Cleaner 1 Adult (21+) 1.9E+09 1.9E+09 1.9E+09 3.2E+10 3.2E+10 3.2E+10 Infant (birth to <1) 5.3E+08 5.3E+08 5.3E+08 1.3E+10 1.3E+10 1.3E+10 Spot Cleaner 1 Adult (21+) 1.7E+07 1.7E+07 1.7E+07 9.3E+08 9.3E+08 9.3E+08 Infant (birth to <1) 4.9E+06 4.9E+06 4.9E+06 3.7E+08 3.7E+08 3.7E+08 Recycling and Disposal 5 Adult (21+) 8.7E+06 2.6E+06 1.7E+04 1.6E+08 4.9E+07 1.1E+06 Infant (birth to <1) 2.5E+06 7.5E+05 4,749 6.4E+07 1.9E+07 4.3E+05 Other 10 Adult (21+) 2.3E+11 2.3E+10 1.1E+06 3.2E+12 3.2E+11 3.3E+07 Infant (birth to <1) 6.4E+10 6.5E+09 3.1E+05 1.2E+12 1.2E+11 1.3E+07 DOD 1 Adult (21+) 5.1E+07 5.1E+07 5.1E+07 7.5E+08 7.5E+08 7.5E+08 Infant (birth to <1) 1.4E+07 1.4E+07 1.4E+07 2.9E+08 2.9E+08 2.9E+08 WWTP 16 Adult (21+) 8.0E+08 5.2E+07 6.8E+04 1.0E+10 6.7E+08 3.5E+05 Infant (birth to <1) 2.3E+08 1.5E+07 1.9E+04 4.0E+09 2.6E+08 1.4E+05 Page 133 of 204 ------- Public Comment Draft - Do Not Cite or Quote OES No. of Releases Modeled Age Group Acute MOE (Benchmark = 30) Chronic MOE (Benchmark = 30) Min Risk a Mean Risk* Max Riskc Min Risk" Mean Risk* Max Risk' Overall 66 Adult (21+) 2.3E+11 3.7E+09 1.3E+04 3.2E+12 5.3E+10 3.5E+05 Infant (birth to <1) 6.4E+10 1.1E+09 3,660 1.2E+12 2.1E+10 1.4E+05 " The minimum risk value is associated with the maximum MOE and the maximum ADR. h The mean risk value is the arithmetic mean MOE. c The maximum risk value is associated with the minimum MOE and the minimum ADR. 34 35 Table 3-29. Summary of Cancer Risk Estimates from Drinking Water Exposure by OES under 20 36 Days of Release Scenarios for MC OES No. of Releases Modeled Ajjc Group Cancer Risk Min Risk Mean Risk Max Risk Manufacturing 12 Adult (21+) 8.4E-16 5.8E-12 5.9E-11 Total Lifetime 6.0E-14 4.2E-10 4.2E-09 Import and Repackaging 2 Adult (21+) 4.2E-13 8.5E-13 1.3E-12 Total Lifetime 3.0E-11 6.1E-11 9.2E-11 Processing as a Reactant 2 Adult (21+) 6.8E-12 7.0E-12 7.2E-12 Total Lifetime 4.9E-10 5.0E-10 5.1E-10 Processing: Formulation 5 Adult (21+) 3.2E-15 1.2E-11 6.2E-11 Total Lifetime 2.3E-13 8.9E-10 4.4E-09 Polyurethane Foam 1 Adult (21+) 3.0E-11 3.0E-11 3.0E-11 Total Lifetime 2.1E-09 2.1E-09 2.1E-09 Plastics Manufacturing 9 Adult (21+) 1.9E-15 2.5E-11 1.1E—10 Total Lifetime 1.3E-13 1.8E-09 8.1E-09 CTA Film Manufacturing 1 Adult (21+) 4.7E-12 4.7E-12 4.7E-12 Total Lifetime 3.4E-10 3.4E-10 3.4E-10 Lithographic Printer Cleaner 1 Adult (21+) 1.8E-15 1.8E-15 1.8E-15 Total Lifetime 1.3E-13 1.3E-13 1.3E-13 Spot Cleaner 1 Adult (21+) 6.2E-14 6.2E-14 6.2E-14 Total Lifetime 4.5E-12 4.5E-12 4.5E-12 Recycling and Disposal 5 Adult (21+) 3.6E-13 2.2E-11 5.3E-11 Total Lifetime 2.6E-11 1.6E-09 3.8E-09 Other 10 Adult (21+) 1.8E-17 2.8E-13 1.8E-12 Total Lifetime 1.3E-15 2.0E-11 1.3E-10 DOD 1 Adult (21+) 7.8E-14 7.8E-14 7.8E-14 Total Lifetime 5.6E-12 5.6E-12 5.6E-12 WWTP 16 Adult (21+) 5.7E-15 3.0E-11 1.7E-10 Total Lifetime 4.1E-13 2.2E-09 1.2E-08 Overall 66 Adult (21+) 1.8E-17 1.5E-11 1.7E-10 Total Lifetime 1.3E-15 1.1E-09 1.2E-08 37 Page 134 of 204 ------- Public Comment Draft - Do Not Cite or Quote Table 3-30. Summary of Risk Estimates for Drinking Water Exposures by OES under Maximum Days of Release Scenarios for MC OES No. of Releases Modeled Age Group Acute MOE (Benchmark = 30) Chronic MOE (Benchmark = 30) Min Risk" Mean Risk* Max Riskc Min Risk" Mean Risk* Max Riskc Manufacturing 16 Adult (21+) 7.2E+10 1.4E+10 4.3E+05 7.0E+10 1.6E+10 9.8E+05 Infant (birth to <1) 2.0E+10 4.1E+09 1.2E+05 2.7E+10 6.2E+09 3.8E+05 Import and Repackaging 5 Adult (21+) 1.9E+10 3.9E+09 4.0E+04 2.7E+10 5.4E+09 5.9E+04 Infant (birth to <1) 5.5E+09 1.1E+09 1.1E+04 1.0E+10 2.1E+09 2.3E+04 Processing as a Reactant 3 Adult (21+) 6.9E+07 2.8E+07 5.7E+06 7.7E+07 3.1E+07 8.2E+06 Infant (birth to <1) 2.0E+07 8.1E+06 1.6E+06 3.0E+07 1.2E+07 3.2E+06 Processing: Formulation 9 Adult (21+) 3.5E+11 4.1E+10 831 3.9E+11 4.6E+10 1,252 Infant (birth to <1) 9.9E+10 1.2E+10 237 1.5E+11 1.8E+10 490 Polyurethane Foam 1 Adult (21+) 1.2E+06 1.2E+06 1.2E+06 2.0E+06 2.0E+06 2.0E+06 Infant (birth to <1) 3.4E+05 3.4E+05 3.4E+05 7.8E+05 7.8E+05 7.8E+05 Plastics Manufacturing 9 Adult (21+) 2.3E+10 3.2E+09 3.2E+05 3.1E+10 4.2E+09 5.1E+05 Infant (birth to <1) 6.6E+09 9.2E+08 9.0E+04 1.2E+10 1.6E+09 2.0E+05 CTA Film Manufacturing 1 Adult (21+) 1.1E+07 1.1E+07 1.1E+07 1.2E+07 1.2E+07 1.2E+07 Infant (birth to <1) 3.0E+06 3.0E+06 3.0E+06 4.9E+06 4.9E+06 4.9E+06 Lithographic Printer Cleaner 1 Adult (21+) 2.3E+10 2.3E+10 2.3E+10 3.3E+10 3.3E+10 3.3E+10 Infant (birth to <1) 6.7E+09 6.7E+09 6.7E+09 1.3E+10 1.3E+10 1.3E+10 Spot Cleaner 1 Adult (21+) 2.1E+08 2.1E+08 2.1E+08 9.3E+08 9.3E+08 9.3E+08 Infant (birth to <1) 6.1E+07 6.1E+07 6.1E+07 3.7E+08 3.7E+08 3.7E+08 Recycling and Disposal 12 Adult (21+) 3.1E+08 5.2E+07 75 2.2E+08 5.0E+07 112 Infant (birth to <1) 8.9E+07 1.5E+07 21 8.5E+07 2.0E+07 44 Other 12 Adult (21+) 2.8E+12 2.4E+11 1.4E+05 3.2E+12 2.6E+11 2.0E+05 Infant (birth to <1) 8.0E+11 6.7E+10 3.9E+04 1.2E+12 1.0E+11 8.0E+04 DOD 1 Adult (21+) 6.4E+08 6.4E+08 6.4E+08 7.6E+08 7.6E+08 7.6E+08 Infant (birth to <1) 1.8E+08 1.8E+08 1.8E+08 3.0E+08 3.0E+08 3.0E+08 WWTP 16 Adult (21+) 1.5E+10 9.5E+08 1.2E+06 1.0E+10 6.7E+08 3.5E+05 Infant (birth to <1) 4.2E+09 2.7E+08 3.5E+05 4.0E+09 2.6E+08 1.4E+05 Overall 87 Adult (21+) 2.8E+12 4.0E+10 75 3.2E+12 4.6E+10 112 Infant (birth to <1) 8.0E+11 1.2E+10 21 1.2E+12 1.8E+10 44 " The minimum risk value is associated with the maximum MOE and the maximum ADR. h The mean risk value is the arithmetic mean MOE. c The maximum risk value is associated with the minimum MOE and the minimum ADR. The risk identified represents the results of one facility within the OES. Page 135 of 204 ------- 41 42 43 44 45 46 47 48 49 50 51 52 53 Public Comment Draft - Do Not Cite or Quote Table 3-31. Summary of Cancer Risk Estimates from Drinking Water Exposure by OES under Maximum Days of Release Scenarios for MC OES No. of Releases Modeled Ajje Group Cancer Risk Min Risk Mean Risk Max Risk Manufacturing 16 Adult (21+) 8.4E-16 4.8E-12 6.0E-11 Total Lifetime 3.4E-15 2.0E-11 2.4E-10 Import and Repackaging 5 Adult (21+) 2.2E-15 2.0E-10 9.9E-10 Total Lifetime 1.3E-14 1.1E-09 5.7E-09 Processing as a Reactant 3 Adult (21+) 7.6E-13 4.9E-12 7.1E-12 Total Lifetime 3. IE-12 2.0E-11 2.9E-11 Processing: Formulation 9 Adult (21+) 1.5E-16 5.2E-09 4.7E-08 Total Lifetime 7.1E-16 2.5E-08 2.2E-07 Polyurethane Foam 1 Adult (21+) 2.9E-11 2.9E-11 2.9E-11 Total Lifetime 1.7E-10 1.7E-10 1.7E-10 Plastics Manufacturing 9 Adult (21+) 1.9E-15 2.5E-11 1.1E—10 Total Lifetime 1.1E-14 1.4E-10 6.6E-10 CTA Film Manufacturing 1 Adult (21+) 4.7E-12 4.7E-12 4.7E-12 Total Lifetime 2.7E-11 2.7E-11 2.7E-11 Lithographic Printer Cleaner 1 Adult (21+) 1.8E-15 1.8E-15 1.8E-15 Total Lifetime 1.0E-14 1.0E-14 1.0E-14 Spot Cleaner 1 Adult (21+) 6.3E-14 6.3E-14 6.3E-14 Total Lifetime 3.6E-13 3.6E-13 3.6E-13 Recycling and Disposal 12 Adult (21+) 2.7E-13 4.4E-08 5.2E-07 Total Lifetime 1.5E-12 2.5E-07 3.0 E—06 Other 12 Adult (21+) 1.8E-17 2.5E-11 2.9E-10 Total Lifetime 1.1E-16 1.4E-10 1.6E-09 DOD 1 Adult (21+) 7.7E-14 7.7E-14 7.7E-14 Total Lifetime 4.4E-13 4.4E-13 4.4E-13 WWTP 16 Adult (21+) 5.7E-15 3.0E-11 1.7E-10 Total Lifetime 2.2E-14 1.2E-10 6.6E-10 Overall 87 Adult (21+) 1.8E-17 6.7E-09 5.2E-07 Total Lifetime 1.1E-16 3.8E-08 3.0F-06 3.2.5.2.2 Incidental Swimming Risk for MC EPA calculated risk estimates from incidental swimming for each of the endpoints in Table 3-13 across all known facilities and modeled release scenarios under each OES. These estimates were then summarized across facilities to present the range from minimum to maximum risk for multiple lifestages under each OES. Aggregate risk from incidental ingestion and dermal contact during recreational contact with water are not presented. Risk estimates calculated for each route of exposure independently are at least an order of magnitude from the benchmarks, indicating that aggregating risk across these routes would not result in different risk conclusions. Cancer risk was not estimated for this scenario because regular, repeated exposures from incidental swimming in a particular water body are not expected to continue across a lifetime. Page 136 of 204 ------- Public Comment Draft - Do Not Cite or Quote 54 55 56 57 58 59 60 61 62 Oral Ingestion For exposures associated with incidental oral ingestion, risk estimates are shown for adults as well as 11 to 15 years old, the age group with the greatest estimated incidental exposures. Risks relative to benchmark for MC were not indicated for either 20-day (Table 3-32) or maximum (Table 3-33) release scenarios, with all risk estimates greater than an order of magnitude from benchmarks. Therefore, oral ingestion risk from incidental swimming is not expected to result from releases of MC facilities. Table 3-32. Summary of Non-cancer Risk Estimates for Incidental Oral Ingestion Exposures by OES No. of Releases Modeled Ajjc Group Acute MOE (Benchmark = 30) Chronic MOE (Benchmark = 10) Min Riska Mean Risk* Max Riskc Min Risk" Mean Risk* Max Risk' Manufacturing 14 Adult (21+) 4.8E+10 9.6E+09 1.1E+05 2.2E+11 5.2E+10 1.9E+05 Youth (11- lS) 3.1E+10 6.2E+09 7.2E+04 1.4E+11 3.3E+10 1.2E+05 Import and Repackaging 2 Adult (21+) 8.4E+07 5.7E+07 2.9E+07 4.5E+08 3.0E+08 1.4E+08 Youth (11- lS) 5.4E+07 3.7E+07 1.9E+07 2.9E+08 1.9E+08 9.3E+07 Processing as a Reactant 2 Adult (21+) 6.9E+06 5.3E+06 3.7E+06 2.7E+07 2.7E+07 2.6E+07 Youth (11- lS) 4.5E+06 3.4E+06 2.4E+06 1.8E+07 1.7E+07 1.7E+07 Processing: Formulation 5 Adult (21+) 1.3E+10 3.0E+09 1.5E+05 5.9E+10 1.4E+10 3.0E+06 Youth (11- lS) 8.1E+09 1.9E+09 9.7E+04 3.8E+10 9.3E+09 1.9E+06 Polyurethane Foam 1 Adult (21+) 1.1E+06 1.1E+06 1.1E+06 6.2E+06 6.2E+06 6.2E+06 Youth (11- lS) 7.3E+05 7.3E+05 7.3E+05 4.0E+06 4.0E+06 4.0E+06 Plastics Manufacturing 9 Adult (21+) 2.1E+10 3.0E+09 3.0E+05 9.9E+10 1.3E+10 1.6E+06 Youth (11- lS) 1.4E+10 1.9E+09 1.9E+05 6.4E+10 8.6E+09 1.1E+06 CTA Film Manufacturing 1 Adult (21+) 9.9E+06 9.9E+06 9.9E+06 4.0E+07 4.0E+07 4.0E+07 Youth (11- lS) 6.4E+06 6.4E+06 6.4E+06 2.6E+07 2.6E+07 2.6E+07 Lithographic Printer Cleaner 1 Adult (21+) 2.2E+10 2.2E+10 2.2E+10 1.0E+11 1.0E+11 1.0E+11 Youth (11- lS) 1.4E+10 1.4E+10 1.4E+10 6.6E+10 6.6E+10 6.6E+10 Spot Cleaner 1 Adult (21+) 2.0E+08 2.0E+08 2.0E+08 3.0E+09 3.0E+09 3.0E+09 Youth (11- lS) 1.3E+08 1.3E+08 1.3E+08 1.9E+09 1.9E+09 1.9E+09 Recycling and Disposal 6 Adult (21+) 1.0E+08 2.6E+07 2.6E+04 5.2E+08 1.3E+08 4.5E+05 Youth (11- lS) 6.6E+07 1.6E+07 1.7E+04 3.3E+08 8.4E+07 2.9E+05 Other 10 Adult (21+) 2.6E+12 2.6E+11 1.3E+07 1.0E+13 1.0E+12 1.1E+08 Youth (11- lS) 1.7E+12 1.7E+11 8.1E+06 6.5E+12 6.6E+11 6.8E+07 DOD 1 Adult (21+) 5.9E+08 5.9E+08 5.9E+08 2.4E+09 2.4E+09 2.4E+09 Youth (11- lS) 3.8E+08 3.8E+08 3.8E+08 1.5E+09 1.5E+09 1.5E+09 WWTP 29 Adult (21+) 9.3E+09 3.6E+08 1,584 3.3E+10 1.2E+09 2,709 Youth (11- lS) 6.0E+09 2.3E+08 1,021 2.1E+10 7.8E+08 1,747 Page 137 of 204 ------- Public Comment Draft - Do Not Cite or Quote OES No. of Releases Modeled Ajjc Group Acute MOE (Benchmark = 30) Chronic MOE (Benchmark = 10) Min Risk" Mean Risk* Max Riskc Min Risk" Mean Risk* Max Risk' Overall 82 Adult (21+) 2.6E+12 3.5E+10 1,584 1.0E+13 1.4E+11 2,709 Youth (11- lS) 1.7E+12 2.2E+10 1,021 6.5E+12 8.8E+10 1,747 " The minimum risk value is associated with the maximum MOE and the maximum ADR. b The mean risk value is the arithmetic mean MOE. c The maximum risk value is associated with the minimum MOE and the minimum ADR. Table 3-33. Summary of Non-cancer Risk Estimates for Incidental Oral Ingestion Exposures by OES No. of Releases Modeled Age Group Acute MOE (Benchmark = 30) Chronic MOE (Benchmark = 10) Mill Risk" Mean Risk* Max Riskc Min Risk" Mean Risk* Max Risk' Manufacturing 20 Adult (21+) 8.4E+11 1.3E+11 2.0E+06 2.2E+11 4.1E+10 1.9E+05 Youth (11-15) 5.4E+11 8.7E+10 1.3E+06 1.4E+11 2.6E+10 1.2E+05 Import and Repackaging 5 Adult (21+) 2.3E+11 4.6E+10 4.6E+05 8.5E+10 1.7E+10 1.9E+05 Youth (11-15) 1.5E+11 2.9E+10 3.0E+05 5.5E+10 1.1E+10 1.2E+05 Processing as a Reactant 3 Adult (21+) 8.1E+08 3.3E+08 6.6E+07 2.4E+08 9.9E+07 2.6E+07 Youth (11-15) 5.2E+08 2.1E+08 4.3E+07 1.6E+08 6.4E+07 1.7E+07 Processing: Formulation 9 Adult (21+) 4.0E+12 4.7E+11 9,695 1.3E+12 1.5E+11 3,991 Youth (11-15) 2.6E+12 3.1E+11 6,250 8.1E+11 9.5E+10 2,573 Polyurethane Foam 1 Adult (21+) 1.4E+07 1.4E+07 1.4E+07 6.3E+06 6.3E+06 6.3E+06 Youth (11-15) 9.1E+06 9.1E+06 9.1E+06 4.1E+06 4.1E+06 4.1E+06 Plastics Manufacturing 9 Adult (21+) 2.7E+11 3.7E+10 3.7E+06 1.0E+11 1.3E+10 1.6E+06 Youth (11-15) 1.7E+11 2.4E+10 2.4E+06 6.4E+10 8.6E+09 1.0E+06 CTA Film Manufacturing 1 Adult (21+) 1.2E+08 1.2E+08 1.2E+08 4.0E+07 4.0E+07 4.0E+07 Youth (11-15) 8.0E+07 8.0E+07 8.0E+07 2.6E+07 2.6E+07 2.6E+07 Lithographic Printer Cleaner 1 Adult (21+) 2.7E+11 2.7E+11 2.7E+11 1.0E+11 1.0E+11 1.0E+11 Youth (11-15) 1.8E+11 1.8E+11 1.8E+11 6.7E+10 6.7E+10 6.7E+10 Spot Cleaner 1 Adult (21+) 2.5E+09 2.5E+09 2.5E+09 3.0E+09 3.0E+09 3.0E+09 Youth (11-15) 1.6E+09 1.6E+09 1.6E+09 1.9E+09 1.9E+09 1.9E+09 Recycling and Disposal 14 Adult (21+) 3.7E+09 6.6E+08 875 6.9E+08 1.7E+08 357 Youth (11-15) 2.4E+09 4.2E+08 564 4.5E+08 1.1E+08 230 Other 12 Adult (21+) 3.3E+13 2.8E+12 1.6E+06 1.0E+13 8.4E+11 6.5E+05 Youth (11-15) 2.1E+13 1.8E+12 1.0E+06 6.5E+12 5.4E+11 4.2E+05 DOD 1 Adult (21+) 7.4E+09 7.4E+09 7.4E+09 2.4E+09 2.4E+09 2.4E+09 Youth (11-15) 4.8E+09 4.8E+09 4.8E+09 1.6E+09 1.6E+09 1.6E+09 WWTP 29 Adult (21+) 1.7E+11 6.6E+09 2.9E+04 3.3E+10 1.2E+09 2,699 Youth (11-15) 1.1E+11 4.2E+09 1.9E+04 2.1E+10 7.9E+08 1,740 Overall 106 Adult (21+) 3.3E+13 3.9E+11 875 1.0E+13 1.2E+11 357 Youth (11-15) 2.1E+13 2.5E+11 564 6.5E+12 7.7E+10 230 " The minimum risk value is associated with the maximum MOE and the maximum ADR. h The mean risk value is the arithmetic mean MOE. c The maximum risk value is associated with the minimum MOE and the minimum ADR. 66 67 Dermal Page 138 of 204 ------- Public Comment Draft - Do Not Cite or Quote 68 For exposures associated with incidental dermal exposure, risk estimates are shown for adults, the age 69 group with the highest relative exposure. Risks relative to benchmarks for MC were not indicated for 70 either 20-day (Table 3-34) or maximum (Table 3-35) release scenarios, with all risk estimates greater 71 than an order of magnitude from the benchmark. Therefore, dermal risk from incidental swimming is not 72 expected to result from releases of MC facilities. 73 74 Table 3-34. Summary of Non-cancer Risk Estimates for Incidental Dermal Exposures by OES 75 under 20 Days of Release Scenarios for MC OES No. of Releases Modeled Ajje Group Aeute MOE (Benchmark = 30) Chronic MOE (Benchmark = 10) Min Risk" Mean Riskh Max Risk' Min Risk" Mean Riskh Max Risk' Manufacturing 14 Adult (21+) 3.1E+10 6.3E+09 7.4E+04 1.5E+11 3.4E+10 1.3E+05 Import and Repackaging 2 Adult (21+) 5.5E+07 3.7E+07 1.9E+07 2.9E+08 1.9E+08 9.5E+07 Processing as a Reactant 2 Adult (21+) 4.6E+06 3.5E+06 2.4E+06 1.8E+07 1.8E+07 1.7E+07 Processing: Formulation 5 Adult (21+) 8.3E+09 2.0E+09 9.9E+04 3.9E+10 9.5E+09 2.0E+06 Polyurethane Foam 1 Adult (21+) 7.4E+05 7.4E+05 7.4E+05 4.1E+06 4.1E+06 4.1E+06 Plastics Manufacturing 9 Adult (21+) 1.4E+10 2.0E+09 1.9E+05 6.5E+10 8.7E+09 1.1E+06 CTA Film Manufacturing 1 Adult (21+) 6.5E+06 6.5E+06 6.5E+06 2.6E+07 2.6E+07 2.6E+07 Lithographic Printer Cleaner 1 Adult (21+) 1.4E+10 1.4E+10 1.4E+10 6.8E+10 6.8E+10 6.8E+10 Spot Cleaner 1 Adult (21+) 1.3E+08 1.3E+08 1.3E+08 2.0E+09 2.0E+09 2.0E+09 Recycling and Disposal 6 Adult (21+) 6.7E+07 1.7E+07 1.7E+04 3.4E+08 8.6E+07 3.0E+05 Other 10 Adult (21+) 1.7E+12 1.7E+11 8.2E+06 6.7E+12 6.7E+11 7.0E+07 DOD 1 Adult (21+) 3.9E+08 3.9E+08 3.9E+08 1.6E+09 1.6E+09 1.6E+09 WWTP 29 Adult (21+) 6.1E+09 2.4E+08 1,042 2.1E+10 8.0E+08 1,783 Overall 82 Adult (21+) 1.7E+12 2.3E+10 1,042 6.7E+12 9.0E+10 1,783 " The minimum risk value is associated with the maximum MOE and the maximum ADR. b The mean risk value is the arithmetic mean MOE. c The maximum risk value is associated with the minimum MOE and the minimum ADR. 76 77 Page 139 of 204 ------- 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 Public Comment Draft - Do Not Cite or Quote Table 3-35. Summary of Non-cancer Risk Estimates for Incidental Dermal Exposures by OES under Maximum Days of Release Scenarios for MC OES No. of Releases Modeled Age Group Aeute MOE (Bcnehmark = 30) Chronie MOE (Benehmark = 10) Min Risk" Mean Riskh Max Risk' Min Risk" Mean Riskh Max Risk' Manufacturing 20 Adult (21+) 5.5E+11 8.9E+10 1.3E+06 1.5E+11 2.7E+10 1.3E+05 Import and Repackaging 5 Adult (21+) 1.5E+11 3.0E+10 3.0E+05 5.6E+10 1.1E+10 1.2E+05 Processing as a Reactant 3 Adult (21+) 5.3E+08 2.2E+08 4.4E+07 1.6E+08 6.5E+07 1.7E+07 Processing: Formulation 9 Adult (21+) 2.7E+12 3.1E+11 6,380 8.2E+11 9.7E+10 2,626 Polyurethane Foam 1 Adult (21+) 9.2E+06 9.2E+06 9.2E+06 4.2E+06 4.2E+06 4.2E+06 Plastics Manufacturing 9 Adult (21+) 1.8E+11 2.5E+10 2.4E+06 6.6E+10 8.8E+09 1.1E+06 CTA Film Manufacturing 1 Adult (21+) 8.2E+07 8.2E+07 8.2E+07 2.6E+07 2.6E+07 2.6E+07 Lithographic Printer Cleaner 1 Adult (21+) 1.8E+11 1.8E+11 1.8E+11 6.8E+10 6.8E+10 6.8E+10 Spot Cleaner 1 Adult (21+) 1.6E+09 1.6E+09 1.6E+09 2.0E+09 2.0E+09 2.0E+09 Recycling and Disposal 14 Adult (21+) 2.4E+09 4.3E+08 576 4.6E+08 1.1E+08 235 Other 12 Adult (21+) 2.2E+13 1.8E+12 1.0E+06 6.6E+12 5.6E+11 4.3E+05 DOD 1 Adult (21+) 4.9E+09 4.9E+09 4.9E+09 1.6E+09 1.6E+09 1.6E+09 WWTP 29 Adult (21+) 1.1E+11 4.3E+09 1.9E+04 2.2E+10 8.0E+08 1,776 Overall 106 Adult (21+) 2.2E+13 2.5E+11 576 6.6E+12 7.8E+10 235 " The minimum risk value is associated with the maximum MOE and the maximum ADR. h The mean risk value is the arithmetic mean MOE. c The maximum risk value is associated with the minimum MOE and the minimum ADR. 3.2.5.2.3 Ambient and Drinking Water Monitoring Information for MC Ambient surface water monitoring information (Section 3.2.4.2.1) was evaluated as part of the original MC risk evaluation for ecological exposures and no new sources of information were found during this evaluation. The three modeled releases with coincident monitoring data described in the original risk evaluation had no detectable levels of MC in proximate monitored results and showed no drinking water, incidental oral, or incidental dermal risk in this evaluation. The one modeled release indicating risk in this evaluation had no nearby monitoring information that could be used to ground-truth that modeled estimate. Available monitored drinking water information (Section 3.2.4.2.2) was collected for the years 2006 to 2011 and was therefore not coincident in time with modeled releases. Relating the physical location of the evaluated monitored results was beyond the scope of this fenceline evaluation. Additionally, these monitoring results represent concentrations measured at the point of distribution into drinking water systems, making relating these concentrations to modeled results difficult. These results show that although the majority of sampled results show measures of MC to be below detectable levels, there are instances of detectable levels of MC in water being used for drinking water and in some cases greater than the MCL of 5 (J,g/L. Page 140 of 204 ------- 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 133 134 135 136 137 138 139 140 141 142 Public Comment Draft - Do Not Cite or Quote 3,2.6 Confidence and Risk Conclusions for MC Case Study Results This section illustrates by example EPA's use of results from applying the proposed screening level methodology to make risk conclusions and does not represent final agency action. Any results or risk conclusions presented here are not intended to be used in support of risk management actions or rulemakings as presented. EPA identified risk relative to the benchmarks from fenceline air concentrations of MC for 14 of the 248 facilities assessed, representing 8 of 17 OES. Based on characterization of land use patterns, fenceline community exposures are reasonably anticipated for 2 of the 14 facilities where EPA identified risk. Risk estimates in Table 3-26 are based on the 95th percentile of modeled exposure concentrations around individual facilities, and the range of risk estimates covers all facilities under an OES. The consideration of land use patterns also confirms that facilities indicating risk are likely of concern to an expected fenceline community cohort. Therefore, EPA determines that the proposed screening level methodology, as applied for this report, sufficiently captures expected risk to the fenceline communities around these facilities for the exposure pathways evaluated. Ninety-fifth percentile values represent a conservative, screening-level analysis and may potentially overestimate chronic and/or lifetime cancer risks. However, analysis of risk estimates based on 10th and 50th percentile release measurements in SFFLA Air Pathway Ful-Screen Results for MC (Appendix B) demonstrates that risk is also indicated at lower percentiles for 7 out of the 14 facilities demonstrating cancer risk based on 95 percent values. These seven facilities indicating risk at lower percentile exposure concentrations include both facilities with expected general population exposures in Table 3-28, therefore mitigating this uncertainty. EPA identified acute non-cancer and cancer risks relative to the benchmarks from fenceline exposure to MC through drinking water for at least one facility in the recycling and disposal OES under the maximum days of release scenario. Risks are not expected for adults, however acute non-cancer risks to infants and total lifetime cancer risk were identified. EPA did not identify risks from fenceline exposure to MC through recreational contact with water. The use of surface water concentration estimates based on the point of release are likely to result in a higher-end estimate of fenceline community exposure from drinking water and incidental swimming (Section 2.4.4). When also considering the inclusion of more sensitive lifestages and risk estimates based on maximum releases across all facilities, these risk conclusions incorporate health-protective assumptions based on the parameters used in these analyses. 3.3 n-Methylpyrrolidone (Water Pathway) 3.3.1 Background for NMP N-Methylpyrrolidone (NMP) is a polar, liquid solvent that is fully miscible in water. Because of its high water solubility and low volatility, NMP is most likely to partition to water. It is subject to aerobic biodegradation in surface water and oxidative degradation in the atmosphere, and is therefore unlikely to persist in either medium ( :020d). TableApx A-1 contains a summary of NMP's physical- chemical properties. 3.3.2 Human Health Hazard Endpoints for NMP All hazard values used to calculated risk in this report are derived from the previously peer-reviewed PODs published in the Final Risk Evaluation for n-Methylpyrrolidone ( )20d). In the Final Risk Evaluation, EPA utilized the endpoints shown in Table 3-36 for risk determination. For NMP, internal PODs for non-cancer endpoints were derived using a PBPK model. External oral equivalents were also calculated from the internal rodent doses based on the original study conditions. Cancer risk is not evaluated because EPA concluded that the reasonably available data was insufficient to support a quantitative evaluation of cancer risks from NMP. Page 141 of 204 ------- 143 144 145 146 147 148 149 150 151 152 153 154 155 156 157 158 159 160 161 162 163 164 165 166 167 168 169 170 Public Comment Draft - Do Not Cite or Quote Table 3-36. lazard Values Used for Risk Estimation in the n-IV ethylpyrrolidone Risk Evaluation Scenario Endpoint Hazard Value Benchmark Reference(s) Acute Developmental: Resorptions/fetal mortality 437 mg/L Cmax (418 mg/kg) 30 (Saillenfait et al.. 2003; Saillenfait et al.. 2002) Chronic Reproductive: Decreased male fertility 183 hr-mg/L AUC (28 mg/kg) 30 (Exxon. 1991) The existing human PBPK model is not readily applicable to general population/fenceline exposure scenarios and is not designed to predict internal doses resulting from drinking water exposures. Therefore, to evaluate risks to fenceline communities, EPA converted the internal dose PODs to external dose PODs (presented in parentheses in Table 3-36). For the analyses in this report, EPA derived POD values for fenceline communities based on a continuous exposure scenario. All of the studies used for the above PODs involved continuous exposure and therefore no duration adjustment was required for application to fenceline communities. The external oral equivalent PODs as published in the Risk Evaluation were based on the rat PBPK model. Therefore, allometric scaling was applied to those values based on EPA guidance on body weight scaling (\ v « « \ JO I I h). Based on the study conditions, the acute POD was adjusted using the measured body weight value for Sprague-Dawley rats (0.259 kg) from (Saillenfait et ai. 2003; Saillenfait et al. 2002) and an estimated body weight of 65.9 kg for pregnant adolescent human females (the body weight assumed for derivation of internal dose PODs in (U.S. EPA. 2020d. see Table 2-77)). The chronic POD was adjusted using the average of male and female subchronic body weight for Sprague-Dawley rat adults (0.2355 kg, value taken from ( |)) and the default adult human body weight of 80 kg. The resulting dosimetric adjustment factors were 0.25 and 0.23 for acute and chronic PODs, respectively, applied to the external dose PODs from Table 3-36. Table 3-37. Hazard Values for NMP Used in this Fenceline Analysis Scenario Endpoint Fenceline HED Benchmark Reference(s) Acute Developmental: Resorptions/fetal mortality 105 mg/kg 30fl (Saillenfait et al., 2003; Saillenfait et al., 2002) Chronic Reproductive: Decreased male fertility 6.5 mg/kg 30fl (Exxon. 1991) " In the Final Risk Evaluation for ii-Methvlpvrrolidone (U.S. EPA, 2020d). EPA applied a benchmark MOE of 30 to the risk estimates for incidental ingestion and dermal exposure. Upon reanalysis, EPA determined that those oral equivalent values were rodent-specific and should have used a benchmark MOE of 100. The allometrically scaled values presented above are applied to the correct benchmark MOE of 30. 3.3.2.1 Assumptions and Uncertainties for NMP Human Health Hazard The HEDs were derived based on allometric scaling in accordance with EPA guidance (U.S. EPA. 2X ). Allometric scaling reduces the overall uncertainty in the resulting HED compared to using standard uncertainty factors, however it is less precise than the internal PBPK-modeled PODs. Body weight for the acute endpoint was specific to the susceptible subpopulation of pregnant females, and the more health-protective body weight for a younger pregnant woman was used. Page 142 of 204 ------- 171 172 173 174 175 176 177 178 179 180 181 182 183 184 185 186 187 188 189 190 191 192 193 194 195 196 197 198 199 200 201 202 203 204 205 206 207 Public Comment Draft - Do Not Cite or Quote The endpoint for decreased male fertility was observed in a multigenerational study, so it is unknown if any particular lifestage is particularly susceptible to this effect. Both fetal and childhood exposure, and potentially also adult exposure, are considered relevant for this health effect. In the absence of more information on the most susceptible lifestage, HEDs were derived via allometric scaling based on conservatively comparing younger rats to average adults. The acute developmental toxicity endpoint is assumed to only be relevant to pregnant females since it represents an in utero outcome. For the chronic effect of decreased male fertility, the sensitive exposure lifestage is unknown because the effect was observed in a 2-generation reproductive toxicity study. In this study male reproductive toxicity may have resulted from in utero exposure, exposure during postnatal development, or as an adult prior to/during mating. Therefore, this endpoint is considered applicable to both pregnant women and all male lifestages. Any other assumptions or uncertainties inherent to the human health hazard assessment in the Final Risk Evaluation for n-M ethyl pyrrol i done ( 2020d) are still applicable for this analysis. 3,3.3 Environmental Releases for NMP In Appendix E of the Final Risk Evaluation for NMP (U.S. EPA. 2020(f). EPA presented a "first-tier" aquatic exposure assessment for NMP by using TRI data for facilities with the highest NMP discharges. Specifically, 2015 and 2018 TRI data on direct and indirect environmental releases were used to estimate NMP concentrations in surface water (I v « « \ 2019b. 201 ). The DMR database does not contain NMP data. To capture "high-end" surface water concentrations, EPA compiled the release data for nine facilities that reported the largest NMP direct water releases. This represented 100 % of the total volume of NMP reported as a direct discharge to surface water during the 2015 and 2018 TRI reporting periods. Since there were many more facilities reporting indirect releases of NMP to surface water, seven of the facilities reporting the largest indirect water releases (representing ~11 percent of the total number of facilities reporting indirect discharges) were compiled. The volume of NMP released from these facilities encompassed more than 87 percent of the total volume of NMP reported as an indirect discharge to surface water (U.S. EPA. 2020d). A summary of the water releases for each NMP OES is included in Table 3-38. This summary uses the same release data used for the first-tier assessment in Appendix E of the Final Risk Evaluation for NMP (I J020d). Of the 17 OES listed in Table 3-38, six have directly applicable 2015 and/or 2018 TRI data that were used for water releases in the first-tier assessment. For the remaining 11 OES without TRI data, EPA did not estimate releases for the first-tier assessment. Table 3-38. Summary ol 'Water Release Estimation Approaches for Each NMP OES OES Range of Water Releases (kg/site-yr) Water Release Estimation Approach Notes Manufacturing N/A N/A No assessment was made for this OES in the first-tier assessment. Repackaging N/A N/A No assessment was made for this OES in the first-tier assessment. Chemical Processing, Excluding Formulation 0.91 to434,458fle/g;! 2015 and 2018 TRI (U.S. EPA. 2019b. 2017) 2015 TRI data are available for 8 sites and 2018 TRI data are available for 10 sites. Page 143 of 204 ------- Public Comment Draft - Do Not Cite or Quote Range of Water Water Release v,^ I_i»3 Releases (kg/site-yr) Estimation Approach i> ores Incorporation into 10 to 20"e 2015 and 2018 TRI 2015 TRI data and 2018 TRI data Formulation, Mixture, or (U.S. EPA. 2019b. are available for 1 site (the same Reaction Product 2017) site). Metal Finishing 0.91 (one site)fe/ 2015 TRI (I S EPA. 2015 TRI data are available for 1 2017) site. Application of Paints, N/A N/A No assessment was made for this Coatings, Adhesives and OES in the first-tier assessment. Sealants Recycling and Disposal 179,246 (one site)cd 2018 TRI (U.S. EPA. 2018 TRI data are available for 1 2019b) site. Removal of Paints, N/A N/A No assessment was made for this Coatings, Adhesives and OES in the first-tier assessment. Sealants Other Electronics 6.4 to 308,443aefg 2015 and 2018 TRI 2015 TRI data are available for 2 Manufacturing (U.S. EPA. 2019b. sites and 2018 TRI data are 2017) available for 5 sites. Semiconductor N/A N/A No assessment was made for this Manufacturing OES in the first-tier assessment. Printing and Writing N/A N/A No assessment was made for this OES in the first-tier assessment. Soldering N/A N/A No assessment was made for this OES in the first-tier assessment. Commercial Automotive N/A N/A No assessment was made for this Servicing OES in the first-tier assessment. Laboratory Use N/A N/A No assessment was made for this OES in the first-tier assessment. Lithium-Ion Cell N/A N/A No assessment was made for this Manufacturing OES in the first-tier assessment. Cleaning 65,622 (one site)ce 2018 TRI ( i, 2018 TRI data are available for 1 2019b) site. Fertilizer Application N/A N/A No assessment was made for this OES in the first-tier assessment. a This range includes both c irect and indirect discharges. b This range includes direct discharges only. c This range includes indirect discharges only. This range includes TRI estimates based on continuous monitoring data or measurements. " This range includes TRI estimates based on periodic or random monitoring data or measurements. 'This range includes TRI estimates based on mass balance calculations, such as calculation of the amount of chemical in streams entering and leaving process equipment. 8 This range includes TRI estimates based on published emissions factors, such as those relating release quantity to through-put or equipment type. This range includes TRI estimates based on other approaches such as engineering calculations (e.g., estimating volatilization using published mathematical formulas) or best engineering judgment. This would include applying estimated removal efficiency to a waste stream, even if the composition of the stream before treatment was fully identified through monitoring data. Page 144 of 204 ------- 208 209 210 211 212 213 214 215 216 217 218 219 220 221 Public Comment Draft - Do Not Cite or Quote 3,3,4 Exposures for NMP 3.3.4.1 Drinking Water for NMP Modeled drinking water estimates are summarized by OES category in Table 3-39 for the 12-day release scenario and in Table 3-40 for the maximum days of release scenario. Results are presented for the adult, pregnant female, and infant age class, but complete by facility results across all age classes for all evaluated releases are available in SF FLA Water Pathway Exposure Data for NMP (Appendix B). For the 12-day release scenario, a total of 9 releases were modeled across all OES with drinking water ADRs across all presented age classes ranging from 2.0x10-07 to 1.9x10-02 mg/kg-day, ADDs ranging from 1.2x10-09 to 4.3x10-05 mg/kg-day andLADDs ranging from 3.9x10-11 to 1.1x10-05 mg/kg- day. For the maximum days of release scenario, a total of 19 releases were modeled across all OES with drinking water ADRs across all presented age classes ranging from 1.8x1008 to 1.9x1002 mg/kg-day, ADDs ranging from 2.7x10-09 to 1.9x10-02 mg/kg-day, and LADDs ranging from 8.9x10-11 to 5.0x10-03 mg/kg-day. Page 145 of 204 ------- Public Comment Draft - Do Not Cite or Quote 1 Table 3-39. Summary of NMP Drinking Water Exposure by PES for 12 Days of Release Scenarios OES No. of Releases Modeled d Ajje Group ADR (mjj/kjj-day) ADD (mjj/kjj-day) LADD (m<;/k<;-day) Min Exposure" Mean Exposure'' Max Exposure' Min Exposure" Mean Exposure'' Max Exposure' Min Exposure" Mean Exposure6 Max Exposure' Chemical Processing, Excluding Formulation 5 Adult (21+) 2.0E-07 7.8E-04 3.4E-03 1.2E-09 2.2E-06 9.5E-06 5.0E-10 9.2E-07 4.0E-06 Pregnant Female 2.2E-07 8.7E-04 3.8E-03 1.9E-09 3.5E-06 1.5E-05 8.0E-10 1.5E-06 6.4E-06 Infant (birth to <1) 7.0E-07 2.7E-03 1.2E-02 3.0E-09 5.5E-06 2.4E-05 3.9E-11 7.1E-08 3.1E-07 Electronics Manufacturing 2 Adult (21+) 1.2E-03 1.6E-03 1.9E-03 2.2E-06 4.3E-06 6.3E-06 9.4E-07 1.8E-06 2.7E-06 Pregnant Female 1.3E-03 1.7E-03 2.2E-03 3.6E-06 6.8E-06 1.0E-05 1.5E-06 2.9E-06 4.3E-06 Infant (birth to <1) 4.1E-03 5.5E-03 6.8E-03 5.7E-06 1.1E-05 1.6E-05 7.3E-08 1.4E-07 2.1E-07 Formulation 1 Adult (21+) 5.3E-03 5.3E-03 5.3E-03 1.7E-05 1.7E-05 1.7E-05 7.2E-06 7.2E-06 7.2E-06 Pregnant Female 5.9E-03 5.9E-03 5.9E-03 2.7E-05 2.7E-05 2.7E-05 1.1E-05 1.1E-05 1.1E-05 Infant (birth to <1) 1.9E-02 1.9E-02 1.9E-02 4.3E-05 4.3E-05 4.3E-05 5.5E-07 5.5E-07 5.5E-07 Metal Finishing 1 Adult (21+) 6.9E-04 6.9E-04 6.9E-04 1.2E-06 1.2E-06 1.2E-06 5.2E-07 5.2E-07 5.2E-07 Pregnant Female 7.6E-04 7.6E-04 7.6E-04 1.9E-06 1.9E-06 1.9E-06 8.2E-07 8.2E-07 8.2E-07 Infant (birth to <1) 2.4E-03 2.4E-03 2.4E-03 3.1E-06 3.1E-06 3.1E-06 4.0E-08 4.0E-08 4.0E-08 Disposal and Recycling 0 Adult (21+) - - - - - - - - - Pregnant Female - - - - - - - - - Infant (birth to <1) - - - - - - - - - Cleaning 0 Adult (21+) - - - - - - - - - Pregnant Female - - - - - - - - - Infant (birth to <1) - - - - - - - - - Overall 9 Adult (21+) 2.0E-07 1.4E-03 5.3E-03 1.2E-09 4.2E-06 1.7E-05 5.0E-10 1.8E-06 7.2E-06 Pregnant Female 2.2E-07 1.6E-03 5.9E-03 1.9E-09 6.7E-06 2.7E-05 8.0E-10 2.8E-06 1.1E-05 Infant (birth to <1) 7.0E-07 5.1E-03 1.9E-02 3.0E-09 1.1E-05 4.3E-05 3.9E-11 1.4E-07 5.5E-07 " The minimum exposure for the identified days of release, within the identified OES, and for the identified age group. h The arithmetic mean exposure for the identified days of release, within the identified OES, and for the identified age group. c The maximum exposure for the identified days of release, within the identified OES, and for the identified age group. For OES with 0 releases, no exposure is anticipated, and thus are represented with a 2 3 4 5 Page 146 of 204 ------- Public Comment Draft - Do Not Cite or Quote 6 Table 3-40. Summary of NMP Drinking Water Exposure by PES for Maximum Days of Release Scenarios OES No. of Releases Modeled Ajje Group ADR (mjj/kjj-day) ADD (mjj/kjj-day) LADD (mjj/kjj-day) Min Exposure" Mean Exposure'' Max Exposure' Min Exposure" Mean Exposure'' Max Exposure' Min Exposure" Mean Exposure'' Max Exposure' Chemical Processing, Excluding Formulation 10 Adult (21+) 1.8E-08 7.6E-03 3.3E-02 2.7E-09 1.2E-03 7.3E-03 1.2E-09 5.1E-04 3.1E-03 Pregnant Female 2.0E-08 8.4E-03 3.6E-02 4.3E-09 1.9E-03 1.2E-02 1.8E-09 8.2E-04 5.0E-03 Infant (birth to <1) 6.4E-08 2.7E-02 0.1146475 6.9E-09 3.1E-03 1.9E-02 8.9E-11 4.0E-05 2.4E-04 Electronics Manufacturing 5 Adult (21+) 5.6E-05 5.4E-03 2.6E-02 2.3E-06 2.1E-04 8.5E-04 9.6E-07 9.0E-05 3.6E-04 Pregnant Female 6.2E-05 5.9E-03 2.8E-02 3.6E-06 3.4E-04 1.4E-03 1.5E-06 1.4E-04 5.8E-04 Infant (birth to <1) 2.0E-04 1.9E-02 9.0E-02 5.8E-06 5.4E-04 2.2E-03 7.4E-08 6.9E-06 2.8E-05 Formulation 1 Adult (21+) 2.2E-04 2.2E-04 2.2E-04 1.7E-05 1.7E-05 1.7E-05 7.2E-06 7.2E-06 7.2E-06 Pregnant Female 2.4E-04 2.4E-04 2.4E-04 2.7E-05 2.7E-05 2.7E-05 1.2E-05 1.2E-05 1.2E-05 Infant (birth to <1) 7.6E-04 7.6E-04 7.6E-04 4.4E-05 4.4E-05 4.4E-05 5.6E-07 5.6E-07 5.6E-07 Metal Finishing 1 Adult (21+) 3.1E-05 3.1E-05 3.1E-05 1.1E-06 1.1E-06 1.1E-06 4.8E-07 4.8E-07 4.8E-07 Pregnant Female 3.4E-05 3.4E-05 3.4E-05 1.8E-06 1.8E-06 1.8E-06 7.6E-07 7.6E-07 7.6E-07 Infant (birth to <1) 1.1E-04 1.1E-04 1.1E-04 2.9E-06 2.9E-06 2.9E-06 3.7E-08 3.7E-08 3.7E-08 Disposal and Recycling 1 Adult (21+) - - - - - - - - - Pregnant Female - - - - - - - - - Infant (birth to <1) - - - - - - - - - Cleaning 1 Adult (21+) - - - - - - - - - Pregnant Female - - - - - - - - - Infant (birth to <1) - - - - - - - - - Overall 19 Adult (21+) 1.8E-08 5.4E-03 3.3E-02 2.7E-09 7.0E-04 7.3E-03 1.2E-09 3.0E-04 3.1E-03 Pregnant Female 2.0E-08 6.0E-03 3.6E-02 4.3E-09 1.1E-03 1.2E-02 1.8E-09 4.7E-04 5.0E-03 Infant (birth to <1) 6.4E-08 1.9E-02 0.1146475 6.9E-09 1.8E-03 1.9E-02 8.9E-11 2.3E-05 2.4E-04 " The minimum exposure for the identified days of release, within the identified OES, and for the identified age group. h The arithmetic mean exposure for the identified days of release, within the identified OES, and for the identified age group. c The maximum exposure for the identified days of release, within the identified OES, and for the identified age group. 7 Page 147 of 204 ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Public Comment Draft - Do Not Cite or Quote 3.3.4.2 Incidental Oral for NMP Modeled incidental oral estimates are summarized by OES category in Table 3-41 for the 20-day release scenario and in Table 3-42 for the maximum days of release scenario. Results are presented for the adult, pregnant female, and youth (11 to 15 years) age classes, but complete by facility results across all age classes for all evaluated releases are available in SF FLA Water Pathway Exposure Data for NMP (Appendix B). For the 12-day release scenario, a total of 9 releases were modeled across all OES with incidental oral ingestion exposure ADRs across all presented age groups ranging from 1.7x10-08 to 7.1x10-04 mg/kg- day and ADDs ranging from 3.7x10-10 to 8.2x10-06 mg/kg-day. For the maximum days of release scenario, a total of 19 releases were modeled across all OES with incidental oral ingestion exposure ADRs across all presented age groups ranging from 1.6x10-09 to 4.3x10-03 mg/kg-day and ADDs ranging from 8.5x10-10 to 3.6x10-03 mg/kg-day. Youths (11 to 15 years) had higher exposures than the other age classes due to this age class's higher weighted incidental daily ingestion rate (Table 2-6). Results here were compared to an alternative method for evaluating incidental oral exposure ( 2019.d). Due to methodological differences between to the two methods, in U.S. EPA. (2019d) the 6 to 10 year age class has the highest estimated exposures as compared to the 11 to 15 year age class in the presented method. Weighted incidental daily ingestion rates between the two methods for the highest exposure age class between the two models are 6,6x10 03 L/kg-day and 5,4x10 03 L/kg-day respectively, resulting in slightly higher, but comparable overall exposure values. Using the 019d) method, the 12-day scenario had a maximum ADR of 8.8xlO~04 mg/kg-day and ADD of 1.0xl0~°5 mg/kg-day, while the maximum days of release scenario had a maximum ADR of 5,4x10 03 mg/kg-day and ADD of 4,4x10 03 mg/kg-day. These results are comparable between the two methodologies and supports confidence in the presented estimated exposures. Complete results for evaluation of incidental oral ingestion using the I) method are available in SF FLA Water Pathway Exposure Data for NMP (Appendix B). Page 148 of 204 ------- Public Comment Draft - Do Not Cite or Quote Table 3-41. Summary of NMP Incidental Oral Ingestion Exposure by PES for 12 Days of Release Scenarios No. of ADR (mg/kg-day) ADD (mg/kg-day) OES Releases Age Group Min Mean Max Min Mean Max Modeled^ Exposure" Exposure'' Exposure' Exposure" Exposure'' Exposure' Chemical Processing, Adult (21+) 1.7E-08 6.7E-05 2.9E-04 3.7E-10 6.8E-07 3.0E-06 Excluding Formulation 5 Pregnant Female 2.1E-08 8.1E-05 3.5E-04 4.5E-10 8.2E-07 3.6E-06 Youth (11-15) 2.6E-08 1.0E-04 4.5E-04 5.8E-10 1.1E-06 4.6E-06 Electronics Adult (21+) 1.0E-04 1.3E-04 1.7E-04 7.0E-07 1.3E-06 2.0E-06 Manufacturing 2 Pregnant Female 1.2E-04 1.6E-04 2.0E-04 8.5E-07 1.6E-06 2.4E-06 Youth (11-15) 1.6E-04 2.1E-04 2.6E-04 1.1E-06 2.1E-06 3.1E-06 Formulation Adult (21+) 4.6E-04 4.6E-04 4.6E-04 5.3E-06 5.3E-06 5.3E-06 1 Pregnant Female 5.6E-04 5.6E-04 5.6E-04 6.4E-06 6.4E-06 6.4E-06 Youth (11-15) 7.1E-04 7.1E-04 7.1E-04 8.2E-06 8.2E-06 8.2E-06 Metal Finishing Adult (21+) 5.9E-05 5.9E-05 5.9E-05 3.8E-07 3.8E-07 3.8E-07 1 Pregnant Female 7.1E-05 7.1E-05 7.1E-05 4.6E-07 4.6E-07 4.6E-07 Youth (11-15) 9.1E-05 9.1E-05 9.1E-05 5.9E-07 5.9E-07 5.9E-07 Disposal and Recycling Adult (21+) - - - - - - 0 Pregnant Female - - - - - - Youth (11-15) - - - - - - Cleaning Adult (21+) - - - - - - 0 Pregnant Female - - - - - - Youth (11-15) - - - - - - Overall Adult (21+) 1.7E-08 1.2E-04 4.6E-04 3.7E-10 1.3E-06 5.3E-06 9 Pregnant Female 2.1E-08 1.5E-04 5.6E-04 4.5E-10 1.6E-06 6.4E-06 Youth (11-15) 2.6E-08 1.9E-04 7.1E-04 5.8E-10 2.0E-06 8.2E-06 a The minimum exposure for the identified days of release, within the identified OES, and for the identified age group. b The arithmetic mean exposure for the identified days of release, within the identified OES, and for the identified age group. c The maximum exposure for the identified days of release, within the identified OES, and for the identified age group. J For OES with 0 releases, no exposure is anticipated, and thus are represented with a Page 149 of 204 ------- Public Comment Draft - Do Not Cite or Quote Table 3-42. Summary of NMP Incidental Oral Ingestion Exposure by PES for Maximum Days of Release Scenarios No. of ADR (mg/kg-day) ADD (mg/kg-day) OES Releases Age Group Min Mean Max Min Mean Max Modeled Exposure" Exposure'' Exposure' Exposure" Exposure'' Exposure' Chemical Processing, 10 Adult (21+) 1.6E-09 6.5E-04 2.8E-03 8.5E-10 3.8E-04 2.3E-03 Excluding Formulation Pregnant Female 1.9E-09 7.9E-04 3.4E-03 1.0E-09 4.6E-04 2.8E-03 Youth (11-15) 2.4E-09 1.0E-03 4.3E-03 1.3E-09 5.9E-04 3.6E-03 Electronics 5 Adult (21+) 4.8E-06 4.6E-04 2.2E-03 7.1E-07 6.7E-05 2.7E-04 Manufacturing Pregnant Female 5.8E-06 5.6E-04 2.7E-03 8.6E-07 8.1E-05 3.2E-04 Youth (11-15) 7.4E-06 7.1E-04 3.4E-03 1.1E-06 1.0E-04 4.2E-04 Formulation 1 Adult (21+) 1.8E-05 1.8E-05 1.8E-05 5.4E-06 5.4E-06 5.4E-06 Pregnant Female 2.2E-05 2.2E-05 2.2E-05 6.5E-06 6.5E-06 6.5E-06 Youth (11-15) 2.9E-05 2.9E-05 2.9E-05 8.3E-06 8.3E-06 8.3E-06 Metal Finishing 1 Adult (21+) 2.7E-06 2.7E-06 2.7E-06 3.5E-07 3.5E-07 3.5E-07 Pregnant Female 3.2E-06 3.2E-06 3.2E-06 4.3E-07 4.3E-07 4.3E-07 Youth (11-15) 4.1E-06 4.1E-06 4.1E-06 5.5E-07 5.5E-07 5.5E-07 Disposal and Recycling 1 Adult (21+) 5.0E-05 5.0E-05 5.0E-05 1.7E-05 1.7E-05 1.7E-05 Pregnant Female 6.1E-05 6.1E-05 6.1E-05 2.1E-05 2.1E-05 2.1E-05 Youth (11-15) 7.8E-05 7.8E-05 7.8E-05 2.7E-05 2.7E-05 2.7E-05 Cleaning 1 Adult (21+) 2.1E-06 2.1E-06 2.1E-06 8.3E-07 8.3E-07 8.3E-07 Pregnant Female 2.5E-06 2.5E-06 2.5E-06 1.0E-06 1.0E-06 1.0E-06 Youth (11-15) 3.2E-06 3.2E-06 3.2E-06 1.3E-06 1.3E-06 1.3E-06 Overall 19 Adult (21+) 1.6E-09 4.7E-04 2.8E-03 8.5E-10 2.2E-04 2.3E-03 Pregnant Female 1.9E-09 5.7E-04 3.4E-03 1.0E-09 2.7E-04 2.8E-03 Youth (11-15) 2.4E-09 7.2E-04 4.3E-03 1.3E-09 3.4E-04 3.6E-03 a The minimum exposure for the identified days of release, within the identified OES, and for the identified age group. b The arithmetic mean exposure for the identified days of release, within the identified OES, and for the identified age group. c The maximum exposure for the identified days of release, within the identified OES, and for the identified age group. Page 150 of 204 ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 Public Comment Draft - Do Not Cite or Quote 3.3.4.3 Incidental Dermal for NMP Modeled incidental dermal estimates are summarized by OES category in Table 3-43 for the 20-day release scenario and in Table 3-44 for the maximum days of release scenario. Results are presented for the adult (21+ years) and pregnant female age class, but complete by facility results across all age classes for all evaluated releases are available in SF FLA Water Pathway Exposure Data for NMP (Appendix B). For the 12-day release scenario, a total of 9 releases were modeled across all OES with incidental dermal exposure ADRs ranging from 1.7x10-09 to 5.3x10-05 mg/kg-day and ADDs ranging from 3.8x10-11 to 6.2x 10-07 mg/kg-day. For the maximum release scenario, a total of 19 releases were modeled across all OES with incidental dermal exposure ADRs ranging from 1.6x10-10 to 3.3x10-04 mg/kg-day and ADDs ranging from 8.6x10-11 to 2.7x10-04 mg/kg-day. Page 151 of 204 ------- Public Comment Draft - Do Not Cite or Quote Table 3-43. Summary of NMP Incidental Dermal Exposure by PES for 12 Days of Release Scenarios No. of ADR (mg/kg-day) ADD (mg/kg-day) OES Releases Age Group Min Mean Max Min Mean Max Modeled'' Exposure" Exposure'' Exposure' Exposure" Exposure'' Exposure' Chemical Processing, 5 Adult (21+) 1.7E-09 6.8E-06 3.0E-05 3.8E-11 6.9E-08 3.0E-07 Excluding Formulation Pregnant Female 2.0E-09 7.8E-06 3.4E-05 4.4E-11 7.9E-08 3.5E-07 Electronics 2 Adult (21+) 1.0E-05 1.4E-05 1.7E-05 7.1E-08 1.4E-07 2.0E-07 Manufacturing Pregnant Female 1.2E-05 1.6E-05 1.9E-05 8.2E-08 1.6E-07 2.3E-07 Formulation 1 Adult (21+) 4.6E-05 4.6E-05 4.6E-05 5.4E-07 5.4E-07 5.4E-07 Pregnant Female 5.3E-05 5.3E-05 5.3E-05 6.2E-07 6.2E-07 6.2E-07 Metal Finishing 1 Adult (21+) 6.0E-06 6.0E-06 6.0E-06 3.9E-08 3.9E-08 3.9E-08 Pregnant Female 6.9E-06 6.9E-06 6.9E-06 4.5E-08 4.5E-08 4.5E-08 Disposal and Recycling 0 Adult (21+) - - - - - - Pregnant Female - - - - - - Cleaning 0 Adult (21+) - - - - - - Pregnant Female - - - - - - Overall 9 Adult (21+) 1.7E-09 1.3E-05 4.6E-05 3.8E-11 1.3E-07 5.4E-07 Pregnant Female 2.0E-09 1.5E-05 5.3E-05 4.4E-11 1.5E-07 6.2E-07 a The minimum exposure for the identified days of release, within the identified OES, and for the identified age group. b The arithmetic mean exposure for the identified days of release, within the identified OES, and for the identified age group. c The maximum exposure for the identified days of release, within the identified OES, and for the identified age group. d For OES with 0 releases, no exposure is anticipated, and thus are represented with a Page 152 of 204 ------- Public Comment Draft - Do Not Cite or Quote Table 3-44. Summary of NMP Incidental Dermal Exposure by PES for Maximum Days of Release Scenarios OES No. of Releases Modeled Age Group ADR (mg/kg-day) ADD (mg/kg-day) Min Exposure" Mean Exposure'' Max Exposure' Min Exposure" Mean Exposure'' Max Exposure' Chemical Processing, Excluding Formulation 10 Adult (21+) 1.6E-10 6.6E-05 2.8E-04 8.6E-11 3.9E-05 2.3E-04 Pregnant Female 1.8E-10 7.6E-05 3.3E-04 1.0E-10 4.4E-05 2.7E-04 Electronics Manufacturing 5 Adult (21+) 4.9E-07 4.7E-05 2.2E-04 7.2E-08 6.7E-06 2.7E-05 Pregnant Female 5.6E-07 5.4E-05 2.6E-04 8.3E-08 7.8E-06 3.1E-05 Formulation 1 Adult (21+) 1.9E-06 1.9E-06 1.9E-06 5.4E-07 5.4E-07 5.4E-07 Pregnant Female 2.2E-06 2.2E-06 2.2E-06 6.3E-07 6.3E-07 6.3E-07 Metal Finishing 1 Adult (21+) 2.7E-07 2.7E-07 2.7E-07 3.6E-08 3.6E-08 3.6E-08 Pregnant Female 3.1E-07 3.1E-07 3.1E-07 4.1E-08 4.1E-08 4.1E-08 Disposal and Recycling 1 Adult (21+) 5.1E-06 5.1E-06 5.1E-06 1.8E-06 1.8E-06 1.8E-06 Pregnant Female 5.9E-06 5.9E-06 5.9E-06 2.0E-06 2.0E-06 2.0E-06 Cleaning 1 Adult (21+) 2.1E-07 2.1E-07 2.1E-07 8.4E-08 8.4E-08 8.4E-08 Pregnant Female 2.4E-07 2.4E-07 2.4E-07 9.7E-08 9.7E-08 9.7E-08 Overall 19 Adult (21+) 1.6E-10 4.7E-05 2.8E-04 8.6E-11 2.2E-05 2.3E-04 Pregnant Female 1.8E-10 5.4E-05 3.3E-04 1.0E-10 2.6E-05 2.7E-04 aThe minimum exposure for the identified days of release, within the identified OES, and b The arithmetic mean exposure for the identified days of release, within the identified OES c The maximum exposure for the identified days of release, within the identified OES, and brthe identified age group. >, and for the identified age group, for the identified age group. Page 153 of 204 ------- Public Comment Draft - Do Not Cite or Quote 3,3,5 Risk Characterization for NMP 2 3 4 5 6 7 8 9 10 11 12 13 14 15 3.3.5.1 Drinking Water Risk for NMP EPA calculated risk estimates for each of the endpoints in Table 3-37 across all known facilities and modeled release scenarios under each OES. These estimates were then summarized across facilities to present the range from minimum to maximum risk for multiple lifestages under each OES. In addition to adults, risk estimates are shown for the most sensitive lifestage for each endpoint—pregnant women for developmental toxicity (acute) and infants for male reproductive toxicity (chronic). Risks relative to benchmark for NMP were not indicated for either 12-day (Table 3-45) or maximum (Table 3-46) release scenarios, with all risk estimates indicating that exposures are more than 10-fold below levels which would result in risk. Therefore, fenceline drinking water risk is not expected to result from releases of NMP facilities. Table 3-45. Summary of Non-cancer Risk Estimates for Drinking Water Exposures by OES for No. of Aeute MOE Chronic MOE OES Releases Ajjc Group (Benchmark = 30) (Benchmark = 30) Modeled" Mill Risk6 Mean Risk' Max Risk'' Mill Risk6 Mean Risk' Max Risk'' Chemical 5 Adult (21+) 5.3E+08 1.1E+08 3.1E+04 5.5E+09 1.1E+09 6.9E+05 Processing, Excluding Formulation Pregnant Female 4.8E+08 9.6E+07 2.8E+04 3.4E+09 6.9E+08 4.3E+05 Infant (birth to <1) N/Ae N/A N/A 2.1E+09 4.3E+08 2.7E+05 Electronics 2 Adult (21+) 9.0E+04 7.2E+04 5.4E+04 2.9E+06 2.0E+06 1.0E+06 Manufacturing Pregnant Female 8.1E+04 6.5E+04 4.9E+04 1.8E+06 1.2E+06 6.4E+05 Infant (birth to <1) N/A N/A N/A 1.1E+06 7.7E+05 4.0E+05 Formulation 1 Adult (21+) 2.0E+04 2.0E+04 2.0E+04 3.8E+05 3.8E+05 3.8E+05 Pregnant Female 1.8E+04 1.8E+04 1.8E+04 2.4E+05 2.4E+05 2.4E+05 Infant (birth to <1) N/A N/A N/A 1.5E+05 1.5E+05 1.5E+05 Metal Finishing 1 Adult (21+) 1.5E+05 1.5E+05 1.5E+05 5.3E+06 5.3E+06 5.3E+06 Pregnant Female 1.4E+05 1.4E+05 1.4E+05 3.3E+06 3.3E+06 3.3E+06 Infant (birth to <1) N/A N/A N/A 2.1E+06 2.1E+06 2.1E+06 Disposal and Recycling 0 Adult (21+) - - - - - - Pregnant Female - - - - - - Infant (birth to <1) - - - - - - Cleaning 0 Adult (21+) - - - - - - Pregnant Female - - - - - - Infant (birth to <1) - - - - - - Overall 9 Adult (21+) 5.3E+08 5.9E+07 2.0E+04 5.5E+09 6.1E+08 3.8E+05 Pregnant Female 4.8E+08 5.3E+07 1.8E+04 3.4E+09 3.8E+08 2.4E+05 Infant (birth to <1) N/A N/A N/A 2.1E+09 2.4E+08 1.5E+05 " For OES with 0 releases, no risks were estimated, and thus are represented with a h The minimum risk value is associated with the maximum MOE and the maximum ADR. c The mean risk value is the arithmetic mean MOE. d The maximum risk value is associated with the minimum MOE and the minimum ADR. e Not applicable to the endpoint used for POD derivation (see Section 3.3.2.1). 16 Page 154 of 204 ------- Public Comment Draft - Do Not Cite or Quote 17 Table 3-46. Summary of Non-cancer Risk Estimates for Drinking Water Exposures by OES for 18 Various Lifestages under Maximum Days of Release Scenarios for NMP OES No. of Releases Modeled Age Group Aeute MOE (Benehmark = 30) Chronic MOE (Benchmark = 30) Min Risk" Mean Risk'' Max Risk' Min Risk6 Mean Risk' Max Risk'' Chemical Processing, Excluding Formulation 10 Adult (21+) 5.8E+09 5.8E+08 3,213 2.4E+09 2.4E+08 886 Pregnant Female 5.2E+09 5.3E+08 2,903 1.5E+09 1.5E+08 554 Infant (birth to <1) N/Arf N/A N/A 9.4E+08 9.5E+07 347 Electronics Manufacturing 5 Adult (21+) 1.9E+06 6.8E+05 4,107 2.9E+06 8.1E+05 7,622 Pregnant Female 1.7E+06 6.1E+05 3,711 1.8E+06 5.1E+05 4,769 Infant (birth to <1) N/A N/A N/A 1.1E+06 3.2E+05 2,984 Formulation 1 Adult (21+) 4.9E+05 4.9E+05 4.9E+05 3.8E+05 3.8E+05 3.8E+05 Pregnant Female 4.4E+05 4.4E+05 4.4E+05 2.4E+05 2.4E+05 2.4E+05 Infant (birth to <1) N/A N/A N/A 1.5E+05 1.5E+05 1.5E+05 Metal Finishing 1 Adult (21+) 3.4E+06 3.4E+06 3.4E+06 5.8E+06 5.8E+06 5.8E+06 Pregnant Female 3.1E+06 3.1E+06 3.1E+06 3.6E+06 3.6E+06 3.6E+06 Infant (birth to <1) N/A N/A N/A 2.3E+06 2.3E+06 2.3E+06 Disposal and Recycling 1 Adult (21+) 1.8E+05 1.8E+05 1.8E+05 1.2E+05 1.2E+05 1.2E+05 Pregnant Female 1.6E+05 1.6E+05 1.6E+05 7.3E+04 7.3E+04 7.3E+04 Infant (birth to <1) N/A N/A N/A 4.6E+04 4.6E+04 4.6E+04 Cleaning 1 Adult (21+) 4.3E+06 4.3E+06 4.3E+06 2.5E+06 2.5E+06 2.5E+06 Pregnant Female 3.9E+06 3.9E+06 3.9E+06 1.5E+06 1.5E+06 1.5E+06 Infant (birth to <1) N/A N/A N/A 9.7E+05 9.7E+05 9.7E+05 Overall 19 Adult (21+) 5.8E+09 3.1E+08 3,213 2.4E+09 1.3E+08 886 Pregnant Female 5.2E+09 2.8E+08 2,903 1.5E+09 8.1E+07 554 Infant (birth to <1) N/A N/A N/A 9.4E+08 5.0E+07 347 " The minimum risk value is associated with the maximum MOE and the maximum ADR. b The mean risk value is the arithmetic mean MOE. c The maximum risk value is associated with the minimum MOE and the minimum ADR. J Not applicable to the endpoint used for POD derivation (see Section 3.3.2.1). 19 3.3.5.2 Incidental Swimming Risk for NMP 20 EPA calculated risk estimates from incidental swimming for each of the endpoints in Table 3-37 across 21 all known facilities and modeled release scenarios under each OES. These estimates were then 22 summarized across facilities to present the range from minimum to maximum risk for multiple lifestages 23 under each OES. Aggregate risk from incidental ingestion and dermal contact during recreational 24 contact with water are not presented. Risk estimates calculated for each route of exposure independently 25 are at least an order of magnitude from the benchmarks, indicating that aggregating risk across these 26 routes would not result in different risk conclusions. 27 3.3.5.2.1 Incidental Oral for NMP 28 In addition to adults, risk estimates are shown for more sensitive lifestages/subpopulations for each 29 endpoint— both pregnant females and 1 l-to-15 year olds. Risks relative to benchmark for NMP were 30 not indicated for either 12-day (Table 3-47) or maximum (Table 3-48) release scenarios, with all risk 31 estimates greater than two orders of magnitude away from benchmark. Therefore, oral ingestion risk 32 from incidental swimming is not expected to result from releases of NMP facilities. 33 Page 155 of 204 ------- Public Comment Draft - Do Not Cite or Quote 34 Table 3-47. Summary of Non-cancer Incidental Oral Ingestion Risk by OES for Various Lifestages 35 under 12 Days of Release Scenario for NMP OES No. of Releases Modeled" Ajjc Group Acute MOE (Benchmark = 30) Chronic MOE (Benchmark = 30) Min Risk* Mean Riskc Max Riskrf Min Risk* Mean Riskc Max Risk'' Chemical Processing, Excluding Formulation 5 Adult (21+) 6.2E+09 1.2E+09 3.6E+05 1.7E+10 3.5E+09 2.2E+06 Pregnant Female 5.1E+09 1.0E+09 3.0E+05 1.4E+10 2.9E+09 1.8E+06 Youth (11-15) 4.0E+09 8.0E+08 2.3E+05 1.1E+10 2.3E+09 1.4E+06 Electronics Manufacturing 2 Adult (21+) 1.1E+06 8.4E+05 6.3E+05 9.3E+06 6.3E+06 3.3E+06 Pregnant Female 8.7E+05 6.9E+05 5.2E+05 7.7E+06 5.2E+06 2.7E+06 Youth (11-15) 6.8E+05 5.4E+05 4.1E+05 6.0E+06 4.0E+06 2.1E+06 Formulation 1 Adult (21+) 2.3E+05 2.3E+05 2.3E+05 1.2E+06 1.2E+06 1.2E+06 Pregnant Female 1.9E+05 1.9E+05 1.9E+05 1.0E+06 1.0E+06 1.0E+06 Youth (11-15) 1.5E+05 1.5E+05 1.5E+05 7.9E+05 7.9E+05 7.9E+05 Metal Finishing 1 Adult (21+) 1.8E+06 1.8E+06 1.8E+06 1.7E+07 1.7E+07 1.7E+07 Pregnant Female 1.5E+06 1.5E+06 1.5E+06 1.4E+07 1.4E+07 1.4E+07 Youth (11-15) 1.1E+06 1.1E+06 1.1E+06 1.1E+07 1.1E+07 1.1E+07 Disposal and Recycling 0 Adult (21+) - - - - - - Pregnant Female - - - - - - Youth (11-15) - - - - - - Cleaning 0 Adult (21+) - - - - - - Pregnant Female - - - - - - Youth (11-15) - - - - - - Overall 9 Adult (21+) 6.2E+09 6.9E+08 2.3E+05 1.7E+10 2.0E+09 1.2E+06 Pregnant Female 5.1E+09 5.7E+08 1.9E+05 1.4E+10 1.6E+09 1.0E+06 Youth (11-15) 4.0E+09 4.4E+08 1.5E+05 1.1E+10 1.3E+09 7.9E+05 " For OES with 0 releases, no risk is anticipated, and thus are represented with a h The minimum risk value is associated with the maximum MOE and the maximum ADR. c The mean risk value is the arithmetic mean MOE. ''The maximum risk value is associated with the minimum MOE and the minimum ADR. 36 37 Page 156 of 204 ------- Public Comment Draft - Do Not Cite or Quote 38 Table 3-48. Summary of Non-cancer Incidental Oral Ingestion Risk by OES for Various Lifestages 39 under Maximum Days of Release Scenario for NMP OES No. of Releases Modeled Ajjc Group Acute MOE (Benchmark = 30) Chronic MOE (Benchmark = 30) Min Risk" Mean Risk b Max Riskc Min Risk" Mean Risk b Max Risk' Chemical Processing, Excluding Formulation 10 Adult (21+) 6.7E+10 6.8E+09 3.7E+04 7.6E+09 7.8E+08 2,823 Pregnant Female 5.5E+10 5.6E+09 3.1E+04 6.3E+09 6.4E+08 2,325 Youth (11-15) 4.3E+10 4.4E+09 2.4E+04 4.9E+09 5.0E+08 1,820 Electronics Manufacturing 5 Adult (21+) 2.2E+07 7.9E+06 4.8E+04 9.2E+06 2.6E+06 2.4E+04 Pregnant Female 1.8E+07 6.5E+06 3.9E+04 7.6E+06 2.1E+06 2.0E+04 Youth (11-15) 1.4E+07 5.1E+06 3.1E+04 5.9E+06 1.7E+06 1.6E+04 Formulation 1 Adult (21+) 5.7E+06 5.7E+06 5.7E+06 1.2E+06 1.2E+06 1.2E+06 Pregnant Female 4.7E+06 4.7E+06 4.7E+06 1.0E+06 1.0E+06 1.0E+06 Youth (11-15) 3.7E+06 3.7E+06 3.7E+06 7.8E+05 7.8E+05 7.8E+05 Metal Finishing 1 Adult (21+) 4.0E+07 4.0E+07 4.0E+07 1.8E+07 1.8E+07 1.8E+07 Pregnant Female 3.3E+07 3.3E+07 3.3E+07 1.5E+07 1.5E+07 1.5E+07 Youth (11-15) 2.5E+07 2.5E+07 2.5E+07 1.2E+07 1.2E+07 1.2E+07 Disposal and Recycling 1 Adult (21+) 2.1E+06 2.1E+06 2.1E+06 3.7E+05 3.7E+05 3.7E+05 Pregnant Female 1.7E+06 1.7E+06 1.7E+06 3.1E+05 3.1E+05 3.1E+05 Youth (11-15) 1.3E+06 1.3E+06 1.3E+06 2.4E+05 2.4E+05 2.4E+05 Cleaning 1 Adult (21+) 5.1E+07 5.1E+07 5.1E+07 7.9E+06 7.9E+06 7.9E+06 Pregnant Female 4.2E+07 4.2E+07 4.2E+07 6.5E+06 6.5E+06 6.5E+06 Youth (11-15) 3.3E+07 3.3E+07 3.3E+07 5.1E+06 5.1E+06 5.1E+06 Overall 19 Adult (21+) 6.7E+10 3.6E+09 3.7E+04 7.6E+09 4.1E+08 2,823 Pregnant Female 5.5E+10 3.0E+09 3.1E+04 6.3E+09 3.4E+08 2,325 Youth (11-15) 4.3E+10 2.3E+09 2.4E+04 4.9E+09 2.6E+08 1,820 " The minimum risk value is associated with the maximum MOE and the maximum ADR. b The mean risk value is the arithmetic mean MOE. c The maximum risk value is associated with the minimum MOE and the minimum ADR. 40 3.3.5.2.2 Incidental Dermal for NMP 41 In addition to adults, risk estimates are shown for the more sensitive subpopulation of pregnant females 42 (adult exposure is greater than youth exposure, so risk estimates for that lifestage are not presented). 43 Risks relative to benchmark for NMP were not indicated for either 12-day (Table 3-49) or maximum 44 (Table 3-50) release scenarios, with all risk estimates greater than two orders of magnitude away from 45 benchmark. Therefore, dermal exposure risk from incidental swimming is not expected to result from 46 releases of NMP facilities. 47 Page 157 of 204 ------- Public Comment Draft - Do Not Cite or Quote 48 Table 3-49. Summary of Non-cancer Risk Estimates for Incidental Dermal Exposure by OES for 49 Various Lifestages under 12 Days of Release Scenario for NMP OES No. of Releases Modeled a Ajje Group Acute MOE (Benchmark = 30) Chronic MOE (Benchmark = 30) Min Risk* Mean Riskc Max Risk'' Min Risk* Mean Riskc Max Risk'' Chemical Processing, Excluding Formulation 5 Adult (21+) 6.1E+10 1.2E+10 3.5E+06 1.7E+11 3.5E+10 2.2E+07 Pregnant Female 5.3E+10 1.1E+10 3.1E+06 1.5E+11 3.0E+10 1.9E+07 Electronics Manufacturing 2 Adult (21+) 1.0E+07 8.3E+06 6.2E+06 9.2E+07 6.2E+07 3.2E+07 Pregnant Female 9.0E+06 7.2E+06 5.4E+06 8.0E+07 5.4E+07 2.8E+07 Formulation 1 Adult (21+) 2.3E+06 2.3E+06 2.3E+06 1.2E+07 1.2E+07 1.2E+07 Pregnant Female 2.0E+06 2.0E+06 2.0E+06 1.0E+07 1.0E+07 1.0E+07 Metal Finishing 1 Adult (21+) 1.8E+07 1.8E+07 1.8E+07 1.7E+08 1.7E+08 1.7E+08 Pregnant Female 1.5E+07 1.5E+07 1.5E+07 1.5E+08 1.5E+08 1.5E+08 Disposal and Recycling 0 Adult (21+) - - - - - - Pregnant Female - - - - - - Cleaning 0 Adult (21+) - - - - - - Pregnant Female - - - - - - Overall 9 Adult (21+) 6.1E+10 6.8E+09 2.3E+06 1.7E+11 1.9E+10 1.2E+07 Pregnant Female 5.3E+10 5.9E+09 2.0E+06 1.5E+11 1.7E+10 1.0E+07 " For OES with 0 releases, no risk is anticipated, and thus are represented with a h The minimum risk value is associated with the maximum MOE and the maximum ADR. c The mean risk value is the arithmetic mean MOE. d The maximum risk value is associated with the minimum MOE and the minimum ADR. 50 51 Page 158 of 204 ------- Public Comment Draft - Do Not Cite or Quote 52 53 Table 3-50. Summary of Non-cancer Risk Estimates for Incidental Dermal Exposure by OES for OES No. of Releases Modeled Ajjc Group Acute MOE (Benchmark = 30) Chronic MOE (Benchmark = 30) Min Risk" Mean Risk b Max Risk' Min Risk" Mean Risk b Max Risk' Chemical Processing, Excluding Formulation 10 Adult (21+) 6.6E+11 6.7E+10 3.7E+05 7.5E+10 7.7E+09 2.8E+04 Pregnant Female 5.8E+11 5.8E+10 3.2E+05 6.5E+10 6.6E+09 2.4E+04 Electronics Manufacturing 5 Adult (21+) 2.2E+08 7.8E+07 4.7E+05 9.1E+07 2.5E+07 2.4E+05 Pregnant Female 1.9E+08 6.8E+07 4.1E+05 7.9E+07 2.2E+07 2.1E+05 Formulation 1 Adult (21+) 5.6E+07 5.6E+07 5.6E+07 1.2E+07 1.2E+07 1.2E+07 Pregnant Female 4.9E+07 4.9E+07 4.9E+07 1.0E+07 1.0E+07 1.0E+07 Metal Finishing 1 Adult (21+) 3.9E+08 3.9E+08 3.9E+08 1.8E+08 1.8E+08 1.8E+08 Pregnant Female 3.4E+08 3.4E+08 3.4E+08 1.6E+08 1.6E+08 1.6E+08 Disposal and Recycling 1 Adult (21+) 2.1E+07 2.1E+07 2.1E+07 3.7E+06 3.7E+06 3.7E+06 Pregnant Female 1.8E+07 1.8E+07 1.8E+07 3.2E+06 3.2E+06 3.2E+06 Cleaning 1 Adult (21+) 5.0E+08 5.0E+08 5.0E+08 7.8E+07 7.8E+07 7.8E+07 Pregnant Female 4.3E+08 4.3E+08 4.3E+08 6.7E+07 6.7E+07 6.7E+07 Overall 19 Adult (21+) 6.6E+11 3.5E+10 3.7E+05 7.5E+10 4.1E+09 2.8E+04 Pregnant Female 5.8E+11 3.1E+10 3.2E+05 6.5E+10 3.5E+09 2.4E+04 " The minimum risk value is associated with the maximum MOE and the maximum ADR. h The mean risk value is the arithmetic mean MOE. c The maximum risk value is associated with the minimum MOE and the minimum ADR. 54 3.3.6 Confidence and Risk Conclusions for NMP Case Study Results 55 This section illustrates by example EPA's use of results from applying the proposed screening level 56 methodology to make risk conclusions and does not represent final agency action. Any results or risk 57 conclusions presented here are not intended to be used in support of risk management actions or 58 rulemakings as presented. 59 60 EPA did not identify risks relative to the benchmarks from fenceline exposure to NMP through drinking 61 water or recreational contact with water. Exposures were more than 10-fold below levels which would 62 result in risk for all exposure scenarios, and therefore EPA does not expect that any small variation in 63 assumptions would result in different risk conclusions. The use of surface water concentration estimates 64 based on the point of release are likely to result in a higher-end estimate of fenceline community 65 exposure from drinking water and incidental swimming (Section 2.4.4). When also considering the 66 inclusion of more sensitive lifestages and risk estimates based on maximum releases across all facilities, 67 these risk conclusions incorporate health-protective assumptions based on the parameters used in these 68 analyses. 69 Page 159 of 204 ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Public Comment Draft - Do Not Cite or Quote REFERENCES Ashford. R. (1994). Ashford's dictionary of industrial chemicals: Properties, production, uses. London: Wavelength. Boublik. d. V; Hal a. E. (1984). The vapour pressures of pure substances: Selected values of the temperature dependence of the vapour pressures of some pure substances in the normal and low pressure region. In Physical Sciences Data, Vol 17 (2nd Revised ed.). Amsterdam, The Netherlands: Elsevier Science Publishers. Daub inner. RP. (1989). 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Developmental toxicity of N-methyl-2-pyrrolidone in rats following inhalation exposure. Food Chem Toxicol 41: 583-588. http://dx.doi.orE >0278-6915(02)00300-9 Sasaki. H; Koiima. M; M01 akamura. J; Shibasaki. J. (1988). Enhancing effect of pyrrolidone derivatives on transdermal drug delivery. 1. Int J Pharm 44: 15-24. Schenk. L; Rauma. nsson. MN; Johanson. G. (2018). Percutaneous absorption of thirty-eight organic solvents in vitro using pig skin. PLoS ONE 13: e0205458. http://dx.doi.ore oumat. pone. 0205458 Singh. HB; Sala Itiles. RE. (1983). Selected man-made halogenated chemicals in the air and oceanic environment. J Geophys Res 88: 3675-3683. http://dx.doi.orE 29/JC088iC06pQ3675 ten Berge \\ I 'w \ \ppelman. LM. (1986). Concentration-time mortality response relationship of irritant and systemically acting vapours and gases. J Hazard Mater 13: 301-309. http://dx.doi.orE >304-3894(86)85003-8 Trinity Consultants. (2015). Emission Report, NPB Response - Addendum. Trinity Consultants. sus Bureau. (2015). Statistics of U.S. Businesses (SUSB). https://www.censiis.gov/data/tables/2015/econ/siisb/2015-siisb-anniial.html (1988). Recommendations for and documentation of biological values for use in risk assessment [EPA Report], (EPA600687008). Cincinnati, OH. http://cfpub.epa. gov/ncea/cfm/recordisplav.cfm?deid=34855 U.S. EPA. (2005). Supplemental guidance for assessing susceptibility from early-life exposure to carcinogens [EPA Report], (EPA/630/R-03/003F). Washington, DC: U.S. Environmental Protection Agency, Risk Assessment Forum, https://www.epa.gov/risk/siipplemental- guidancE-assessing-susceptibilitv-earlv-lifE-exposurE-carcinogens U.S. EPA. (201 la). Exposure factors handbook: 201 1 edition [EPA Report], (EPA/600/R-090/052F). Washington, DC: U.S. Environmental Protection Agency, Office of Research and Develop.m.ent, National Center for Environmental Assessment. http://cfpub.epa. gov/ncea/cfm/recordisplav.cfm?deid=236252 U.S. EPA. (201 lb). Recommended use of body weight 3/4 as the default method in derivation of the oral reference dose. (EPA100R110001). Washington, DC. https://www.epa.gov/sites/production/files/2013-09/documents/recommended-usE-of-bw34.pdf Page 161 of 204 ------- 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 133 134 135 136 137 138 139 140 141 142 143 144 145 146 Public Comment Draft - Do Not Cite or Quote U.S. EPA. (2012a). Advances in inhalation gas dosimetry for derivation of a reference concentration (RfC) and use in risk assessment (pp. 1-140). (EPA/600/R-12/044). Washington, DC. https://cfpub.epa.gov/ncea/risk/recordisplay.cfm?deid=24465Q > .>, €FTOKEN= 17139189 U.S. EPA. (2015). Evaluation of Swimmer Exposures Using the SWIMODEL Algorithms and Assumptions, https://www.epa.gov/sites/production/files/2Q16- 11 /documents/swimodel final.pdf U.S. EPA. (2016b). Public database 2016 chemical data reporting (May 2017 release). Washington, DC: US Environmental Protection Agency, Office of Pollution Prevention and Toxics. https://www.epa.gov/chemical-data-reporting U.S. EPA. (2017). Consumer Exposure Model (CEM) version 2.0: User guide. U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxics. https://www.epa.eov/sites/prodiiction/files/2i 'docum ents/cem2.0 user guide.pdf U.S. EPA. (2018). User's Guide for the A MS/EPA Regulatory Model (AERMOD). (EPA Document Number: EPA-454/B-18-001). U.S. EPA. (2019a). IECCU 1.1 User's Guide. In Simulation Program for Estimating Chemical Emissions from Sources and Related Changes to Indoor Environmental Concentrations in Buildings with Conditioned and Unconditioned Zones (IECCU). (EPA Contract # EP-W-12- 010). Washington, DC: U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxics. https://heronet.epa.gov/heronet/index.cfm?action=search.view&reference id=6305433 U.S. EPA. (2019c). User's Guide: Integrated Indoor-Outdoor Air Calculator (IIOAC). Washington, DC: U.S. EPA. https://heronet.epa.gov/heronet/index.cfm?action=search.view&reference id=69 U.S. EPA. (2019d). Recommended Human Health Recreational Ambient Water Quality Criteria or Swimming Advisories for Microcystins and Cylindrospermopsin [EPA Report], (EPA 822-R-19- 001). Washington, DC. https://nepis.epa.gov/Exe/ZyPL ?Dockev=P 100WX86.txt U.S. EPA. (2019e). Exposure factors handbook chapter 3 (update): Ingestion of water and other select liquids. (EPA/600/R-18/259F). https://cfpub.epa. gov/ncea/efp/recordisplav.cfm?deid=343661 (2020b). Risk evaluation for 1-bromopropane (n-Propyl bromide), CASRN: 106-94-5 [EPA Report], (#740-Rl-8013). Washington, DC: Office of Chemical Safety and Pollution Prevention. https://www.regiilations.gov/dociiment/EPA-HQ-0] 0235-0085 U.S. EPA. (2020c). Risk evaluation for methylene chloride (dichloromethane, DCM); CASRN: 75-09-2. (EPA-740-R1-8010). Washington, DC: Office of Chemical Safety and Pollution Prevention. https://www.regiilations.gov/dociiment/EPA-HQ-0] 19-0437-0107 U.S. EPA. (2020d). Risk evaluation for n-M ethyl pyrrol i done (2-Pyrrolidinone, 1-Methyl-) (NMP); CASRN: 872-50-4 [EPA Report], (EPA-740-R1-8009). Washington, DC: Office of Chemical Safety and Pollution Prevention, https://www.regulations.gov/document/EPA-HQ-OPPT-2019- 0236-0081 U.S. EPA. (2020e). Risk evaluation for 1,4-dioxane (CASRN: 123-91-1) [EPA Report], (EPA-740-R1- 8007). Washington, DC: Office of Chemical Safety and Pollution Prevention. https://www.regiilations.gov/dociiment/EPA-HQ-0] 0238-0092 LISGS. (2003). A national survey of methyl tert-butyl ether and other volatile organic compounds in drinking-water sources: Results of the random survey. Reston, VA: U.S. Department of the Interior, U.S. Geological Survey, https://piibs.er.iisgs.gov/publication/wri024079 W.I.L. Research. (2001). An inhalation two-generation reproductive toxicity study of 1 -bromopropane in rats. (Study No. WIL-380001). Ashland, OH. Yalkowsky. SH; He "S . Join i1 (2010). Handbook of aqueous solubility data (2nd ed.). Boca Raton, FL: CRC Press. http://dx.doi.org/10.1201/EB 802458 Page 162 of 204 ------- Public Comment Draft - Do Not Cite or Quote 147 Page 163 of 204 ------- 148 149 150 151 152 153 154 155 156 157 158 159 160 161 162 163 164 165 166 167 168 169 170 171 172 173 174 175 176 177 178 179 180 181 182 183 184 185 186 187 188 189 190 191 192 193 194 Public Comment Draft - Do Not Cite or Quote Appendix A ABBREVIATIONS AND PHYSICAL-CHEMICAL PROPERTIES A,1 Abbreviations 1,4-D 1,4-Dioxane 1-BP 1-Bromopropane ACGM American Conference of Governmental Industrial Hygienists AEGL Acute Exposure Guideline Level AERMOD American Meteorological Society/Environmental Protection Agency Regulatory Model ATSDR Agency for Toxic Substances and Disease Registry BAF Bioaccumulation factor BCF Bioconcentration factor BMD Benchmark dose BMR Benchmark response CAA Clean Air Act CASRN Chemical Abstracts Service Registry Number CBI Confidential Business Information CDR Chemical Data Reporting CEHD Chemical Exposure Health Data CEPA Canadian List of Toxic Substances CERCLA Comprehensive Environmental Response, Compensation and Liability Act CFR Code of Federal Regulations CHIRP Chemical Risk Information Platform CNS Central nervous system coc Concentration(s) of concern CoCAP Cooperative Chemicals Assessment Program COHb Carboxyhemoglobin CPS A Consumer Product Safety Act CPSC Consumer Product Safety Commission CSCL Chemical Substances Control Law CSHO Certified Safety and Health Official CTC Carbon tetrachloride CWA Clean Water Act MC Dichloromethane (methylene chloride) DIY Do it yourself DMR Discharge Monitoring Report DOT Department of Transportation EC50 Effect concentration at which 50% of test organisms exhibit an effect ECHA European Chemicals Agency E-FAST Exposure and Fate Assessment Screening Tool EG Effluent Guidelines EHC Environmental Health Criteria EPA Environmental Protection Agency EPCRA Emergency Planning and Community Right-to-Know Act ESD Emission Scenario Document EU European Union FDA Food and Drug Administration FFDCA Federal Food, Drug, and Cosmetic Act Page 164 of 204 ------- 195 196 197 198 199 200 201 202 203 204 205 206 207 208 209 210 211 212 213 214 215 216 217 218 219 220 221 222 223 224 225 226 227 228 229 230 231 232 233 234 235 236 237 238 239 240 241 242 243 Public Comment Draft - Do Not Cite or Quote FSHA Federal Hazardous Substance Act HAP Hazardous Air Pollutant HEC Human Equivalent Concentration HED Human Equivalent Dose HERO Health and Environmental Research Online (Database) HFC Hydrofluorocarbon HHE Health hazard evaluation HMTA Hazardous Materials Transportation Act HPV High Production Volume I ARC International Agency for Research on Cancer ICIS Integrated Compliance Information System IDLH Immediately Dangerous to Life and Health IECCU Indoor Environment Concentration in Buildings with Conditioned and Unconditioned Zones IIOAC Integrated Indoor/Outdoor Air Calculator IMAP Inventory Multi-Tiered Assessment and Prioritisation IRIS Integrated Risk Information System ISHA Industrial Safety and Health Act Koc Soil organic carbon: water partitioning coefficient Kow Octanol: water partition coefficient LC50 Lethal concentration at which 50% of test organisms die LD50 Lethal dose at which 50% of test organisms die LOD Limit of detection Log Koc Logarithmic organic carbon: water partition coefficient Log Kow Logarithmic octanol: water partition coefficient MACT Maximum Achievable Control Technology MC Methylene chloride MCL Maximum Contaminant Level MCLG Maximum Contaminant Level Goal MOA Mode of action MSW Municipal solid waste NAC National Advisory Committee NAICS North American Industry Classification System NATA National Scale Air-Toxics Assessment NAWQA National Water Quality Assessment Program ND Non-detect NEI National Emissions Inventory NESHAP National Emission Standards for Hazardous Air Pollutants NHANES National Health and Nutrition Examination Survey NICNAS National Industrial Chemicals Notification and Assessment Scheme NIH National Institutes of Health NIOSH National Institute for Occupational Safety and Health NITE National Institute of Technology and Evaluation NMP n-Methyl -2-pyrroli done NO A A National Oceanic and Atmospheric Administration NPDES National Pollutant Discharge Elimination System NPDWR National Primary Drinking Water Regulation NRC National Research Council NTP National Toxicology Program Page 165 of 204 ------- 244 245 246 247 248 249 250 251 252 253 254 255 256 257 258 259 260 261 262 263 264 265 266 267 268 269 270 271 272 273 274 275 276 277 278 279 280 281 282 283 284 285 286 287 288 289 290 291 Public Comment Draft - Do Not Cite or Quote NWIS National Water Information System OCSPP Office of Chemical Safety and Pollution Prevention OECD Organisation for Economic Co-operation and Development OEHHA Office of Environmental Health Hazard Assessment OEL Occupational exposure limit OES Occupational exposure scenario(s) ONU Occupational non-user OPPT Office of Pollution Prevention and Toxics OSHA Occupational Safety and Health Administration OTVD Open-top vapor degreaser PBPK Physiologically based pharmacokinetic PBZ Personal breathing zone PECO Population, exposure, comparator, and outcome PEL Permissible Exposure Limit PESS Potentially exposed or susceptible subpopulations POD Point of departure POTW Publicly owned treatment works PPE Personal protective equipment PSD Particle size distribution PV Production volume QC Quality control RCRA Resource Conservation and Recovery Act REACH Registration, Evaluation, Authorization and Restriction of Chemicals (European Union) REL Recommended Exposure Limit RICE Reciprocating internal combustion engines RTR Risk and technology review SDS Safety data sheet SDWA Safe Drinking Water Act SIDS Screening Information Data Set SMAC Spacecraft Maximum Allowable Concentrations SNAP Significant New Alternatives Policy SpERC Specific Environmental Release Categories STEL Short-Term Exposure Limit STORET STOrage and RETrieval and Water Quality exchange TCCR Transparent, clear, consistent, and reasonable TLV Threshold Limit Value TRI Toxics Release Inventory TSCA Toxic Substances Control Act TTO Total toxic organics TWA Time-weighted average U.S. United States USGS United States Geological Survey VOC Volatile organic compound VP Vapor pressure WHO World Health Organization A.2 Select Physical-Chemical Properties of Case Study Chemicals TableApx A-l summarizes the basic physical-chemical properties of the chemicals chosen for the case studies in this document. All of the properties appear in the chemicals' respective final risk evaluations, Page 166 of 204 ------- Public Comment Draft - Do Not Cite or Quote 292 for which they were identified using the systematic review procedures described in those documents (1- 293 BP: (IlS^PAo2020b); MC: (U.S. EPA. 2020c): NMP: ( :020dV). 294 Table Apx A-l. Select 'hysical-Chemical Properties of Case Study Chemicals Property 1-Bromopropane Methylene Chloride N-Methylpyrrolidone Molecular formula C3H7Br CH2CI2 C5H9ON Molecular mass 122.99 84.93 99.1 Melting point -110 °C (O'Neil. 2013) -95 °C (O'Neil. 2013) -25 °C (Ashford. 1994) Boiling point 71 °C (O'Neil. 2013) 39.7 °C (O'Neil. 2013) 202 °C (O'Neil et al.. 2006) Density 1.353 g/cm3 at 20 °C (O'Neil. 2013) 1.33 g/cm3 at 20 °C ( feil. 2013) 1.03 a/cm3 at 25 °C (O'Neil et al.. 2006) Vapor pressure 110.8 mmHg at 20 °C (Boublik et al., 1984) 435 mmHg at 25 °C ( iblik et al., 1984) 0.345 mmHg at 25 °C ( ibert and Banner, 1989) Vapor density (air =1) 4.25 (Pattv et al.. 1963) 2.93 (Holbrook. 2003) 3.4 CNFPA, 1997) Water solubility 2.450 g/L at 20 °C (Yalkowskv et al., 2010) 13 g/L at 25 °C (Horvath. 1982) 1,000 g/L at 25 °C (miscible) (O'Neil et al.. 2006) Henry's law constant 7.3x10-3 atmm3/mol (U.S. EPA. 2012b) 2.91 x 10~3 atm • m3/mol (Leiehton and Calo. I«>S|) 3.2x 10~9 atmmVmol (Kim et al., 2000) log Kow 2.10 (Hanscfa. 1995) 2.27 (Hansell. 1995) -0.38 (Sasaki et al.. 1988) 296 297 Page 167 of 204 ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Public Comment Draft - Do Not Cite or Quote Appendix B LIST OF SUPPLEMENTAL FILES List of supplemental documents (see Docket: https://www.regulations.gov/docket/EPA-HQ-OPPT- 2( for access to all files): 01. SFFLAAir Pathway Input Parameters for AERMOD for 1-BP and MC 02. SF FLA Air Pathway Pre-screening Results for 1-BP 03. SF FL A Air Pathway Pre-screening Results for MC 04. SF FLA Air Pathway Co-Resident Exposure Results for 1-BP 05. SF FLA Air Pathway Full-Screen Results for 1-BP 06. SF FLA Air Pathway Full-Screen Results for MC 07. SF FLA Air Pathway Summary Statistics of Exposure Concentrations for 1-BP 08. SF FLA Air Pathway Summary Statistics of Exposure Concentrations for MC 09. SF FLA Air Pathway Information for Co-Resident Modeling for 1-BP 10. SF FLA Dry-Cleaning Model_3rd GenEmission Results for 1-BP 11. SFFLAEnvironmental Releases to Ambient Air for 1-BP 12. SF FLA Environmental Releases to Ambient Air for MC 13. SFFLAWater Pathway Exposure Data for MC 14. SF FLA Water Pathway Exposure Data for NMP 15. SF FLA Air Pathway Input Parameters for IIOAC for 1-BP and MC 16. SF FLA README File Co-Resident Exposure Modeling Page 168 of 204 ------- Public Comment Draft - Do Not Cite or Quote i Appendix C TRI-CDR CROSSWALK 2 3 4 5 Table Apx C-l presents the TRI-CDR Crosswalk used to map facilities to the OES for each chemical. Blanks in the 2016 CDR code column indicate there is no corresponding CDR code that matches the TRI code. Table Apx C-l. TRI-CDR Use Code Crosswalk TRI Section TRI Description TRI Sub- use Code TRI Sub-use Code Name 2016 CDR Code 2016 CDR Code Name 2016 CDR Functional Use Definition 3.1.a Manufacture: Produce 3.1.b Manufacture: Import 3.1.c Manufacture: For on-site use/processing 3.1.d Manufacture: For sale/distributio n 3.1.e Manufacture: As a byproduct 3.1.f Manufacture: As an impurity 3.2.a Processing: As a reactant PC Processing as a reactant Chemical substance is used in chemical reactions for the manufacturing of another chemical substance or product. 3.2.a Processing: As a reactant P101 Feedstocks 3.2.a Processing: As a reactant P102 Raw Materials 3.2.a Processing: As a reactant P103 Intermediates U015 Intermediates Chemical substances consumed in a reaction to produce other chemical substances for commercial advantage. A residual of the intermediate chemical substance which has no separate function may remain in the reaction product. Page 169 of 204 ------- Public Comment Draft - Do Not Cite or Quote TRI Section TRI Description TRI Sub- use Code TRI Sub-use Code Name 2016 CDR Code 2016 CDR Code Name 2016 CDR Functional Use Definition 3.2.a Processing: As a reactant P104 Initiators U024 Process regulators Chemical substances used to change the rate of a chemical reaction, start or stop the reaction, or otherwise influence the course of the reaction. Process regulators may be consumed or become part of the reaction product. 3.2.a Processing: As a reactant P199 Other U016 Ion exchange agents Chemical substances, usually in the form of a solid matrix, that are used to selectively remove targeted ions from a solution. Examples generally consist of an inert hydrophobic matrix such as styrenedivinylbenzene or phenol-formaldehyde, cross-linking polymer such as divinylbenzene, and ionic functional groups including sulfonic, carboxylic or phosphonic acids. This code also includes aluminosilicate zeolites. 3.2.a Processing: As a reactant P199 Other U019 Oxidizing/reducing agent Chemical substances used to alter the valence state of another substance by donating or accepting electrons or by the addition or removal of hydrogen to a substance. Examples of oxidizing agents include nitric acid, perchlorates, hexavalent chromium compounds, and peroxydisulfuric acid salts. Examples of reducing agents include hydrazine, sodium thiosulfate, and coke produced from coal. 3.2.a Processing: As a reactant P199 Other U999 Other (specify) 3.2.b Processing: As a formulation component PF Processing- incorporation into formulation, mixture, or reaction product Chemical substance is added to a product (or product mixture) prior to further distribution of the product. 3.2.b Processing: As a formulation component P201 Additives U007 Corrosion inhibitors and antiscaling agents Chemical substances used to prevent or retard corrosion or the formation of scale. Examples include phenylenediamine, chromates, nitrates, phosphates, and hydrazine. Page 170 of 204 ------- Public Comment Draft - Do Not Cite or Quote TRI Section TRI Description TRI Sub- use Code TRI Sub-use Code Name 2016 CDR Code 2016 CDR Code Name 2016 CDR Functional Use Definition 3.2.b Processing: As a formulation component P201 Additives U009 Fillers Chemical substances used to provide bulk, increase strength, increase hardness, or improve resistance to impact. Fillers incorporated in a matrix reduce production costs by minimizing the amount of more expensive substances used in the production of articles. Examples include calcium carbonate, barium sulfate, silicates, clays, zinc oxide and aluminum oxide. 3.2.b Processing: As a formulation component P201 Additives U010 Finishing agents Chemical substances used to impart such functions as softening, staticproofing, wrinkle resistance, and water repellence. Substances may be applied to textiles, paper, and leather. Examples include quaternary ammonium compounds, ethoxylated amines, and silicone compounds. 3.2.b Processing: As a formulation component P201 Additives U017 Lubricants and lubricant additives Chemical substances used to reduce friction, heat, or wear between moving parts or adjacent solid surfaces, or that enhance the lubricity of other substances. Examples of lubricants include mineral oils, silicate and phosphate esters, silicone oil, greases, and solid film lubricants such as graphite and PTFE. Examples of lubricant additives include molybdenum disulphide and tungsten disulphide. 3.2.b Processing: As a formulation component P201 Additives U034 Paint additives and coating additives not described by other codes Chemical substances used in a paint or coating formulation to enhance properties such as water repellence, increased gloss, improved fade resistance, ease of application, foam prevention, etc. Examples of paint additives and coating additives include polyols, amines, vinyl acetate ethylene emulsions, and aliphatic polyisocyanates. 3.2.b Processing: As a formulation component P202 Dyes U008 Dyes Chemical substances used to impart color to other materials or mixtures (i.e., substrates) by penetrating into the surface of the substrate. Examples types include azo, anthraquinone, amino azo, aniline, eosin, stilbene, acid, basic or cationic, reactive, dispersive, and natural dyes. Page 171 of 204 ------- Public Comment Draft - Do Not Cite or Quote TRI Section TRI Description TRI Sub- use Code TRI Sub-use Code Name 2016 CDR Code 2016 CDR Code Name 2016 CDR Functional Use Definition 3.2.b Processing: As a formulation component P202 Dyes U021 Pigments Chemical substances used to impart color to other materials or mixtures (i.e., substrates) by attaching themselves to the surface of the substrate through binding or adhesion. This code includes fluorescent agents, luminescent agents, whitening agents, pearlizing agents, and opacifiers. Examples include metallic oxides of iron, titanium, zinc, cobalt, and chromium; metal powder suspensions; lead chromates; vegetable and animal products; and synthetic organic pigments. 3.2.b Processing: As a formulation component P203 Reaction Diluents U030 Solvents (which become part of product formulation or mixture) Chemical substances used to dissolve another substance (solute) to form a uniformly dispersed mixture (solution) at the molecular level. Examples include diluents used to reduce the concentration of an active material to achieve a specified effect and low gravity materials added to reduce cost. 3.2.b Processing: As a formulation component P203 Reaction Diluents U032 Viscosity adjustors Chemical substances used to alter the viscosity of another substance. Examples include viscosity index (VI) improvers, pour point depressants, and thickeners. 3.2.b Processing: As a formulation component P204 Initiators U024 Process Regulators Chemical substances used to change the rate of a chemical reaction, start or stop the reaction, or otherwise influence the course of the reaction. Process regulators may be consumed or become part of the reaction product. 3.2.b Processing: As a formulation component P205 Solvents U030 Solvents (which become part of product formulation or mixture) Chemical substances used to dissolve another substance (solute) to form a uniformly dispersed mixture (solution) at the molecular level. Examples include diluents used to reduce the concentration of an active material to achieve a specified effect and low gravity materials added to reduce cost. 3.2.b Processing: As a formulation component P206 Inhibitors U024 Process Regulators Chemical substances used to change the rate of a chemical reaction, start or stop the reaction, or otherwise influence the course of the reaction. Process regulators Page 172 of 204 ------- Public Comment Draft - Do Not Cite or Quote TRI Section TRI Description TRI Sub- use Code TRI Sub-use Code Name 2016 CDR Code 2016 CDR Code Name 2016 CDR Functional Use Definition may be consumed or become part of the reaction product. 3.2.b Processing: As a formulation component P207 Emulsifiers U003 Adsorbents and Absorbents Chemical substances used to retain other substances by accumulation on their surface or by assimilation. Examples of adsorbents include silica gel, activated alumina, and activated carbon. Examples of absorbents include straw oil, alkaline solutions, and kerosene. 3.2.b Processing: As a formulation component P208 Surfactants U002 Adhesives and Sealant Chemicals Chemical substances used to promote bonding between other substances, promote adhesion of surfaces, or prevent seepage of moisture or air. Examples include epoxides, isocyanates, acrylamides, phenol, urea, melamine, and formaldehyde. 3.2.b Processing: As a formulation component P208 Surfactants U023 Plating agents and surface treating agents Chemical substances applied to metal, plastic, or other surfaces to alter physical or chemical properties of the surface. Examples include metal surface treating agents, strippers, etchants, rust and tarnish removers, and descaling agents. 3.2.b Processing: As a formulation component P208 Surfactants U031 Surface active agents Chemical substances used to modify surface tension when dissolved in water or water solutions, or reduce interfacial tension between two liquids or between a liquid and a solid or between liquid and air. Examples include carboxylates, sulfonates, phosphates, carboxylic acid, esters, and quaternary ammonium salts. 3.2.b Processing: As a formulation component P209 Lubricants U017 Lubricants and lubricant additives Chemical substances used to reduce friction, heat, or wear between moving parts or adjacent solid surfaces, or that enhance the lubricity of other substances. Examples of lubricants include mineral oils, silicate and phosphate esters, silicone oil, greases, and solid film lubricants such as graphite and PTFE. Examples of lubricant additives include molybdenum disulphide and tungsten disulphide. 3.2.b Processing: As a formulation component P210 Flame Retardants U011 Flame retardants Chemical substances used on the surface of or incorporated into combustible materials to reduce or eliminate their tendency to ignite when exposed to heat Page 173 of 204 ------- Public Comment Draft - Do Not Cite or Quote TRI Section TRI Description TRI Sub- use Code TRI Sub-use Code Name 2016 CDR Code 2016 CDR Code Name 2016 CDR Functional Use Definition or a flame for a short period of time. Examples include inorganic salts, chlorinated or brominated organic compounds, and organic phosphates/phosphonates. 3.2.b Processing: As a formulation component P211 Rheological Modifiers U022 Plasticizers Chemical substances used in plastics, cement, concrete, wallboard, clay bodies, or other materials to increase their plasticity or fluidity. Examples include phthalates, trimellitates, adipates, maleates, and lignosulphonates. 3.2.b Processing: As a formulation component P211 Rheological Modifiers U032 Viscosity adjusters Chemical substances used to alter the viscosity of another substance. Examples include viscosity index (VI) improvers, pour point depressants, and thickeners. 3.2.b Processing: As a formulation component P299 Other U003 Adsorbents and Absorbents Chemical substances used to retain other substances by accumulation on their surface or by assimilation. Examples of adsorbents include silica gel, activated alumina, and activated carbon. Examples of absorbents include straw oil, alkaline solutions, and kerosene. 3.2.b Processing: As a formulation component P299 Other U016 Ion exchange agents Chemical substances, usually in the form of a solid matrix, that are used to selectively remove targeted ions from a solution. Examples generally consist of an inert hydrophobic matrix such as styrenedivinylbenzene or phenol-formaldehyde, cross-linking polymer such as divinylbenzene, and ionic functional groups including sulfonic, carboxylic or phosphonic acids. This code also includes aluminosilicate zeolites. 3.2.b Processing: As a formulation component P299 Other U018 Odor agents Chemical substances used to control odors, remove odors, mask odors, or impart odors. Examples include benzenoids, terpenes and terpenoids, musk chemicals, aliphatic aldehydes, aliphatic cyanides, and mercaptans. 3.2.b Processing: As a formulation component P299 Other U019 Oxidizing/reducing agent Chemical substances used to alter the valence state of another substance by donating or accepting electrons or by the addition or removal of hydrogen to a substance. Examples of oxidizing agents include nitric acid, perchlorates, hexavalent chromium compounds, and peroxydisulfuric acid salts. Examples of reducing agents Page 174 of 204 ------- Public Comment Draft - Do Not Cite or Quote TRI Section TRI Description TRI Sub- use Code TRI Sub-use Code Name 2016 CDR Code 2016 CDR Code Name 2016 CDR Functional Use Definition include hydrazine, sodium thiosulfate, and coke produced from coal. 3.2.b Processing: As a formulation component P299 Other U020 Photosensitive chemicals Chemical substances used for their ability to alter their physical or chemical structure through absorption of light, resulting in the emission of light, dissociation, discoloration, or other chemical reaction. Examples include sensitizers, fluorescents, photovoltaic agents, ultraviolet absorbers, and ultraviolet stabilizers. 3.2.b Processing: As a formulation component P299 Other U027 Propellants and blowing agents Chemical substances used to dissolve or suspend other substances and either to expel those substances from a container in the form of an aerosol or to impart a cellular structure to plastics, rubber, or thermo set resins. Examples include compressed gasses and liquids and substances which release ammonia, carbon dioxide, or nitrogen. 3.2.b Processing: As a formulation component P299 Other U028 Solid separation agents Chemical substances used to promote the separation of suspended solids from a liquid. Examples include flotation aids, flocculants, coagulants, dewatering aids, and drainage aids. 3.2.b Processing: As a formulation component P299 Other U999 Other (specify) 3.2.c Processing: As an article component PA Processing- incorporation into article Chemical substance becomes an integral component of an article distributed for industrial, trade, or consumer use. 3.2.c Processing: As an article component U008 Dyes Chemical substances used to impart color to other materials or mixtures (i.e., substrates) by penetrating into the surface of the substrate. Examples types include azo, anthraquinone, amino azo, aniline, eosin, stilbene, acid, basic or cationic, reactive, dispersive, and natural dyes. 3.2.c Processing: As an article component U009 Fillers Chemical substances used to provide bulk, increase strength, increase hardness, or improve resistance to impact. Fillers incorporated in a matrix reduce Page 175 of 204 ------- Public Comment Draft - Do Not Cite or Quote TRI Section TRI Description TRI Sub- use Code TRI Sub-use Code Name 2016 CDR Code 2016 CDR Code Name 2016 CDR Functional Use Definition production costs by minimizing the amount of more expensive substances used in the production of articles. Examples include calcium carbonate, barium sulfate, silicates, clays, zinc oxide and aluminum oxide. 3.2.c Processing: As an article component U021 Pigments Chemical substances used to impart color to other materials or mixtures (i.e., substrates) by attaching themselves to the surface of the substrate through binding or adhesion. This code includes fluorescent agents, luminescent agents, whitening agents, pearlizing agents, and opacifiers. Examples include metallic oxides of iron, titanium, zinc, cobalt, and chromium; metal powder suspensions; lead chromates; vegetable and animal products; and synthetic organic pigments. 3.2.c Processing: As an article component U034 Paint additives and coating additives not described by other codes Chemical substances used in a paint or coating formulation to enhance properties such as water repellence, increased gloss, improved fade resistance, ease of application, foam prevention, etc. Examples of paint additives and coating additives include polyols, amines, vinyl acetate ethylene emulsions, and aliphatic polyisocyanates. 3.2.c Processing: As an article component U999 Other (specify) 3.2.d Processing: Repackaging PK Processing- repackaging Preparation of a chemical substance for distribution in commerce in a different form, state, or quantity. This includes transferring the chemical substance from a bulk container into smaller containers. This definition does not apply to sites that only relabel or redistribute the reportable chemical substance without removing the chemical substance from the container in which it is received or purchased. 3.2.e Processing: As an impurity Page 176 of 204 ------- Public Comment Draft - Do Not Cite or Quote TRI Section TRI Description TRI Sub- use Code TRI Sub-use Code Name 2016 CDR Code 2016 CDR Code Name 2016 CDR Functional Use Definition 3.2.f Processing: Recycling 3.3.a Otherwise Use: As a chemical processing aid U Use-non incorporative Activities Chemical substance is otherwise used (e.g., as a chemical processing or manufacturing aid). 3.3.a Otherwise Use: As a chemical processing aid Z101 Process Solvents U029 Solvents (for cleaning or degreasing) Chemical substances used to dissolve oils, greases, and similar materials from textiles, glassware, metal surfaces, and other articles. Examples include trichloroethylene, perchloroethylene, methylene chloride, liquid carbon dioxide, and n-propyl bromide. 3.3.a Otherwise Use: As a chemical processing aid Z102 Catalysts U020 Photosensitive chemicals Chemical substances used for their ability to alter their physical or chemical structure through absorption of light, resulting in the emission of light, dissociation, discoloration, or other chemical reaction. Examples include sensitizers, fluorescents, photovoltaic agents, ultraviolet absorbers, and ultraviolet stabilizers. 3.3.a Otherwise Use: As a chemical processing aid Z102 Catalysts U025 Processing aids, specific to petroleum production Chemical substances added to water-, oil-, or synthetic drilling muds or other petroleum production fluids to control viscosity, foaming, corrosion, alkalinity and pH, microbiological growth, hydrate formation, etc., during the production of oil, gas, and other products from beneath the earth's surface. 3.3.a Otherwise Use: As a chemical processing aid Z102 Catalysts U026 Processing aids, not otherwise listed Chemical substances used to improve the processing characteristics or the operation of process equipment or to alter or buffer the pH of the substance or mixture, when added to a process or to a substance or mixture to be processed. Processing agents do not become a part of the reaction product and are not intended to affect the function of a substance or article created. Examples include buffers, dehumidifiers, dehydrating agents, sequestering agents, and chelators. Page 177 of 204 ------- Public Comment Draft - Do Not Cite or Quote TRI Section TRI Description TRI Sub- use Code TRI Sub-use Code Name 2016 CDR Code 2016 CDR Code Name 2016 CDR Functional Use Definition 3.3.a Otherwise Use: As a chemical processing aid Z103 Inhibitors U024 Process Regulators Chemical substances used to change the rate of a chemical reaction, start or stop the reaction, or otherwise influence the course of the reaction. Process regulators may be consumed or become part of the reaction product. 3.3.a Otherwise Use: As a chemical processing aid Z103 Inhibitors U025 Processing aids, specific to petroleum production Chemical substances added to water-, oil-, or synthetic drilling muds or other petroleum production fluids to control viscosity, foaming, corrosion, alkalinity and pH, microbiological growth, hydrate formation, etc., during the production of oil, gas, and other products from beneath the earth's surface. 3.3.a Otherwise Use: As a chemical processing aid Z103 Inhibitors U026 Processing aids, not otherwise listed Chemical substances used to improve the processing characteristics or the operation of process equipment or to alter or buffer the pH of the substance or mixture, when added to a process or to a substance or mixture to be processed. Processing agents do not become a part of the reaction product and are not intended to affect the function of a substance or article created. Examples include buffers, dehumidifiers, dehydrating agents, sequestering agents, and chelators. 3.3.a Otherwise Use: As a chemical processing aid Z104 Initiators U024 Process Regulators Chemical substances used to change the rate of a chemical reaction, start or stop the reaction, or otherwise influence the course of the reaction. Process regulators may be consumed or become part of the reaction product. 3.3.a Otherwise Use: As a chemical processing aid Z104 Initiators U025 Processing aids, specific to petroleum production Chemical substances added to water-, oil-, or synthetic drilling muds or other petroleum production fluids to control viscosity, foaming, corrosion, alkalinity and pH, microbiological growth, hydrate formation, etc., during the production of oil, gas, and other products from beneath the earth's surface. Page 178 of 204 ------- Public Comment Draft - Do Not Cite or Quote TRI Section TRI Description TRI Sub- use Code TRI Sub-use Code Name 2016 CDR Code 2016 CDR Code Name 2016 CDR Functional Use Definition 3.3.a Otherwise Use: As a chemical processing aid Z104 Initiators U026 Processing aids, not otherwise listed Chemical substances used to improve the processing characteristics or the operation of process equipment or to alter or buffer the pH of the substance or mixture, when added to a process or to a substance or mixture to be processed. Processing agents do not become a part of the reaction product and are not intended to affect the function of a substance or article created. Examples include buffers, dehumidifiers, dehydrating agents, sequestering agents, and chelators. 3.3.a Otherwise Use: As a chemical processing aid Z105 Reaction Terminators U024 Process Regulators Chemical substances used to change the rate of a chemical reaction, start or stop the reaction, or otherwise influence the course of the reaction. Process regulators may be consumed or become part of the reaction product. 3.3.a Otherwise Use: As a chemical processing aid Z105 Reaction Terminators U025 Processing aids, specific to petroleum production Chemical substances added to water-, oil-, or synthetic drilling muds or other petroleum production fluids to control viscosity, foaming, corrosion, alkalinity and pH, microbiological growth, hydrate formation, etc., during the production of oil, gas, and other products from beneath the earth's surface. 3.3.a Otherwise Use: As a chemical processing aid Z105 Reaction Terminators U026 Processing aids, not otherwise listed Chemical substances used to improve the processing characteristics or the operation of process equipment or to alter or buffer the pH of the substance or mixture, when added to a process or to a substance or mixture to be processed. Processing agents do not become a part of the reaction product and are not intended to affect the function of a substance or article created. Examples include buffers, dehumidifiers, dehydrating agents, sequestering agents, and chelators. 3.3.a Otherwise Use: As a chemical processing aid Z106 Solution Buffers U026 Processing aids, not otherwise listed Chemical substances used to improve the processing characteristics or the operation of process equipment or to alter or buffer the pH of the substance or mixture, when added to a process or to a substance or mixture to Page 179 of 204 ------- Public Comment Draft - Do Not Cite or Quote TRI Section TRI Description TRI Sub- use Code TRI Sub-use Code Name 2016 CDR Code 2016 CDR Code Name 2016 CDR Functional Use Definition be processed. Processing agents do not become a part of the reaction product and are not intended to affect the function of a substance or article created. Examples include buffers, dehumidifiers, dehydrating agents, sequestering agents, and chelators. 3.3.a Otherwise Use: As a chemical processing aid Z199 Other U002 Adhesives and Sealant Chemicals Chemical substances used to promote bonding between other substances, promote adhesion of surfaces, or prevent seepage of moisture or air. Examples include epoxides, isocyanates, acrylamides, phenol, urea, melamine, and formaldehyde. 3.3.a Otherwise Use: As a chemical processing aid Z199 Other U006 Bleaching agents Chemical substances used to lighten or whiten a substrate through chemical reaction, usually an oxidative process which degrades the color system. Examples generally fall into one of two groups: chlorine containing bleaching agents (e.g., chlorine, hypochlorites, N-chloro compounds and chlorine dioxide); and, peroxygen bleaching agents (e.g., hydrogen peroxide, potassium permanganate, and sodium perborate). 3.3.a Otherwise Use: As a chemical processing aid Z199 Other U018 Odor agents Chemical substances used to control odors, remove odors, mask odors, or impart odors. Examples include benzenoids, terpenes and terpenoids, musk chemicals, aliphatic aldehydes, aliphatic cyanides, and mercaptans. 3.3.a Otherwise Use: As a chemical processing aid Z199 Other U023 Plating agents and surface treating agents Chemical substances applied to metal, plastic, or other surfaces to alter physical or chemical properties of the surface. Examples include metal surface treating agents, strippers, etchants, rust and tarnish removers, and descaling agents. 3.3.a Otherwise Use: As a chemical processing aid Z199 Other U025 Processing aids, specific to petroleum production Chemical substances added to water-, oil-, or synthetic drilling muds or other petroleum production fluids to control viscosity, foaming, corrosion, alkalinity and pH, microbiological growth, hydrate formation, etc., during the production of oil, gas, and other products from beneath the earth's surface. Page 180 of 204 ------- Public Comment Draft - Do Not Cite or Quote TRI TRI TRI Sub- TRI Sub-use 2016 CDR 2016 CDR Code 2016 CDR Functional Use Definition Section Description use Code Code Name Code Name 3.3.a Otherwise Use: As a chemical processing aid Z199 Other U026 Processing aids, not otherwise listed Chemical substances used to improve the processing characteristics or the operation of process equipment or to alter or buffer the pH of the substance or mixture, when added to a process or to a substance or mixture to be processed. Processing agents do not become a part of the reaction product and are not intended to affect the function of a substance or article created. Examples include buffers, dehumidifiers, dehydrating agents, sequestering agents, and chelators. 3.3.a Otherwise Use: As a chemical processing aid Z199 Other U028 Solid separation agents Chemical substances used to promote the separation of suspended solids from a liquid. Examples include flotation aids, flocculants, coagulants, dewatering aids, and drainage aids. 3.3.b Otherwise Use: As a manufacturing aid U Use-non incorporative Activities Chemical substance is otherwise used (e.g., as a chemical processing or manufacturing aid). 3.3.b Otherwise Use: Z201 Process U017 Lubricants and Chemical substances used to reduce friction, heat, or As a Lubricants lubricant additives wear between moving parts or adjacent solid surfaces, or manufacturing that enhance the lubricity of other substances. Examples aid of lubricants include mineral oils, silicate and phosphate esters, silicone oil, greases, and solid film lubricants such as graphite and PTFE. Examples of lubricant additives include molybdenum disulphide and tungsten disulphide. 3.3.b Otherwise Use: Z202 Metalworkin U007 Corrosion inhibitors Chemical substances used to prevent or retard corrosion As a g Fluids and antiscaling or the formation of scale. Examples include manufacturing agents phenylenediamine, chromates, nitrates, phosphates, and aid hydrazine. 3.3.b Otherwise Use: Z202 Metalworkin U014 Functional fluids Liquid or gaseous chemical substances used for one or As a g Fluids (open systems) more operational properties in an open system. Examples manufacturing include antifreezes and de-icing fluids such as ethylene aid and propylene glycol, sodium formate, potassium Page 181 of 204 ------- Public Comment Draft - Do Not Cite or Quote TRI Section TRI Description TRI Sub- use Code TRI Sub-use Code Name 2016 CDR Code 2016 CDR Code Name 2016 CDR Functional Use Definition acetate, and, sodium acetate. This code also includes substances incorporated into metal working fluids. 3.3.b Otherwise Use: As a manufacturing aid Z203 Coolants U013 Functional fluids (closed systems) Liquid or gaseous chemical substances used for one or more operational properties in a closed system. Examples include: heat transfer agents (e.g., coolants and refrigerants) such as polyalkylene glycols, silicone oils, liquified propane, and carbon dioxide; hydraulic/transmission fluids such as mineral oils, organophosphate esters, silicone, and propylene glycol; and dielectric fluids such as mineral insulating oil and high flash point kerosene. This code does not include fluids used as lubricants. 3.3.b Otherwise Use: As a manufacturing aid Z204 Refrigerants U013 Functional fluids (closed systems) Liquid or gaseous chemical substances used for one or more operational properties in a closed system. Examples include: heat transfer agents (e.g., coolants and refrigerants) such as polyalkylene glycols, silicone oils, liquified propane, and carbon dioxide; hydraulic/transmission fluids such as mineral oils, organophosphate esters, silicone, and propylene glycol; and dielectric fluids such as mineral insulating oil and high flash point kerosene. This code does not include fluids used as lubricants. 3.3.b Otherwise Use: As a manufacturing aid Z205 Hydraulic Fluids U013 Functional fluids (closed systems) Liquid or gaseous chemical substances used for one or more operational properties in a closed system. Examples include: heat transfer agents (e.g., coolants and refrigerants) such as polyalkylene glycols, silicone oils, liquified propane, and carbon dioxide; hydraulic/transmission fluids such as mineral oils, organophosphate esters, silicone, and propylene glycol; and dielectric fluids such as mineral insulating oil and high flash point kerosene. This code does not include fluids used as lubricants. Page 182 of 204 ------- Public Comment Draft - Do Not Cite or Quote TRI Section TRI Description TRI Sub- use Code TRI Sub-use Code Name 2016 CDR Code 2016 CDR Code Name 2016 CDR Functional Use Definition 3.3.b Otherwise Use: As a manufacturing aid Z299 Other U013 Functional fluids (closed systems) Liquid or gaseous chemical substances used for one or more operational properties in a closed system. Examples include: heat transfer agents (e.g., coolants and refrigerants) such as polyalkylene glycols, silicone oils, liquified propane, and carbon dioxide; hydraulic/transmission fluids such as mineral oils, organophosphate esters, silicone, and propylene glycol; and dielectric fluids such as mineral insulating oil and high flash point kerosene. This code does not include fluids used as lubricants. 3.3.b Otherwise Use: As a manufacturing aid Z299 Other U023 Plating agents and surface treating agents Chemical substances applied to metal, plastic, or other surfaces to alter physical or chemical properties of the surface. Examples include metal surface treating agents, strippers, etchants, rust and tarnish removers, and descaling agents. 3.3.c Otherwise Use: Ancillary or other use U Use-non incorporative Activities Chemical substance is otherwise used (e.g., as a chemical processing or manufacturing aid). 3.3.c Otherwise Use: Ancillary or other use Z301 Cleaner U007 Corrosion inhibitors and antiscaling agents Chemical substances used to prevent or retard corrosion or the formation of scale. Examples include phenylenediamine, chromates, nitrates, phosphates, and hydrazine. 3.3.c Otherwise Use: Ancillary or other use Z301 Cleaner U029 Solvents (for cleaning or degreasing) Chemical substances used to dissolve oils, greases, and similar materials from textiles, glassware, metal surfaces, and other articles. Examples include trichloroethylene, perchloroethylene, methylene chloride, liquid carbon dioxide, and n-propyl bromide. 3.3.c Otherwise Use: Ancillary or other use Z302 Degreaser U003 Adsorbents and Absorbents Chemical substances used to retain other substances by accumulation on their surface or by assimilation. Examples of adsorbents include silica gel, activated alumina, and activated carbon. Examples of absorbents include straw oil, alkaline solutions, and kerosene. Page 183 of 204 ------- Public Comment Draft - Do Not Cite or Quote TRI Section TRI Description TRI Sub- use Code TRI Sub-use Code Name 2016 CDR Code 2016 CDR Code Name 2016 CDR Functional Use Definition 3.3.c Otherwise Use: Ancillary or other use Z302 Degreaser U029 Solvents (for cleaning or degreasing) Chemical substances used to dissolve oils, greases, and similar materials from textiles, glassware, metal surfaces, and other articles. Examples include trichloroethylene, perchloroethylene, methylene chloride, liquid carbon dioxide, and n-propyl bromide. 3.3.c Otherwise Use: Ancillary or other use Z303 Lubricant U017 Lubricants and lubricant additives Chemical substances used to reduce friction, heat, or wear between moving parts or adjacent solid surfaces, or that enhance the lubricity of other substances. Examples of lubricants include mineral oils, silicate and phosphate esters, silicone oil, greases, and solid film lubricants such as graphite and PTFE. Examples of lubricant additives include molybdenum disulphide and tungsten disulphide. 3.3.c Otherwise Use: Ancillary or other use Z304 Fuel U012 Fuels and fuel additives Chemical substances used to create mechanical or thermal energy through chemical reactions, or which are added to a fuel for the purpose of controlling the rate of reaction or limiting the production of undesirable combustion products, or which provide other benefits such as corrosion inhibition, lubrication, or detergency. Examples of fuels include coal, oil, gasoline, and various grades of diesel fuel. Examples of fuel additives include oxygenated compound such as ethers and alcohols, antioxidants such as phenylenediamines and hindered phenols, corrosion inhibitors such as carboxylic acids, amines, and amine salts, and blending agents such as ethanol. 3.3.c Otherwise Use: Ancillary or other use Z305 Flame Retardant U011 Flame retardants Chemical substances used on the surface of or incorporated into combustible materials to reduce or eliminate their tendency to ignite when exposed to heat or a flame for a short period of time. Examples include inorganic salts, chlorinated or brominated organic compounds, and organic phosphates/phosphonates. Page 184 of 204 ------- Public Comment Draft - Do Not Cite or Quote TRI Section TRI Description TRI Sub- use Code TRI Sub-use Code Name 2016 CDR Code 2016 CDR Code Name 2016 CDR Functional Use Definition 3.3.c Otherwise Use: Ancillary or other use Z306 Waste Treatment U006 Bleaching agents Chemical substances used to lighten or whiten a substrate through chemical reaction, usually an oxidative process which degrades the color system. Examples generally fall into one of two groups: chlorine containing bleaching agents (e.g., chlorine, hypochlorites, N-chloro compounds and chlorine dioxide); and peroxygen bleaching agents (e.g., hydrogen peroxide, potassium permanganate, and sodium perborate). 3.3.c Otherwise Use: Ancillary or other use Z306 Waste Treatment U018 Odor agents Chemical substances used to control odors, remove odors, mask odors, or impart odors. Examples include benzenoids, terpenes and terpenoids, musk chemicals, aliphatic aldehydes, aliphatic cyanides, and mercaptans. 3.3.c Otherwise Use: Ancillary or other use Z306 Waste Treatment U019 Oxidizing/reducing agent Chemical substances used to alter the valence state of another substance by donating or accepting electrons or by the addition or removal of hydrogen to a substance. Examples of oxidizing agents include nitric acid, perchlorates, hexavalent chromium compounds, and peroxydisulfuric acid salts. Examples of reducing agents include hydrazine, sodium thiosulfate, and coke produced from coal. 3.3.c Otherwise Use: Ancillary or other use Z306 Waste Treatment U028 Solid separation agents Chemical substances used to promote the separation of suspended solids from a liquid. Examples include flotation aids, flocculants, coagulants, dewatering aids, and drainage aids. 3.3.c Otherwise Use: Ancillary or other use Z307 Water Treatment U006 Bleaching agents Chemical substances used to lighten or whiten a substrate through chemical reaction, usually an oxidative process which degrades the color system. Examples generally fall into one of two groups: chlorine containing bleaching agents (e.g., chlorine, hypochlorites, N-chloro compounds and chlorine dioxide); and, peroxygen bleaching agents (e.g., hydrogen peroxide, potassium permanganate, and sodium perborate). Page 185 of 204 ------- Public Comment Draft - Do Not Cite or Quote TRI Section TRI Description TRI Sub- use Code TRI Sub-use Code Name 2016 CDR Code 2016 CDR Code Name 2016 CDR Functional Use Definition 3.3.c Otherwise Use: Ancillary or other use Z307 Water Treatment U018 Odor agents Chemical substances used to control odors, remove odors, mask odors, or impart odors. Examples include benzenoids, terpenes and terpenoids, musk chemicals, aliphatic aldehydes, aliphatic cyanides, and mercaptans. 3.3.c Otherwise Use: Ancillary or other use Z307 Water Treatment U019 Oxidizing/reducing agent Chemical substances used to alter the valence state of another substance by donating or accepting electrons or by the addition or removal of hydrogen to a substance. Examples of oxidizing agents include nitric acid, perchlorates, hexavalent chromium compounds, and peroxydisulfuric acid salts. Examples of reducing agents include hydrazine, sodium thiosulfate, and coke produced from coal. 3.3.c Otherwise Use: Ancillary or other use Z307 Water Treatment U028 Solid separation agents Chemical substances used to promote the separation of suspended solids from a liquid. Examples include flotation aids, flocculants, coagulants, dewatering aids, and drainage aids. 3.3.c Otherwise Use: Ancillary or other use Z308 Construction Materials 3.3.c Otherwise Use: Ancillary or other use Z399 Other U001 Abrasives Chemical substances used to wear down or polish surfaces by rubbing against the surface. Examples include sandstones, pumice, silex, quartz, silicates, aluminum oxides, and glass. 3.3.c Otherwise Use: Ancillary or other use Z399 Other U013 Functional fluids (closed systems) Liquid or gaseous chemical substances used for one or more operational properties in a closed system. Examples include: heat transfer agents (e.g., coolants and refrigerants) such as polyalkylene glycols, silicone oils, liquified propane, and carbon dioxide; hydraulic/transmission fluids such as mineral oils, organophosphate esters, silicone, and propylene glycol; and dielectric fluids such as mineral insulating oil and high flash point kerosene. This code does not include fluids used as lubricants. Page 186 of 204 ------- Public Comment Draft - Do Not Cite or Quote TRI Section TRI Description TRI Sub- use Code TRI Sub-use Code Name 2016 CDR Code 2016 CDR Code Name 2016 CDR Functional Use Definition 3.3.c Otherwise Use: Ancillary or other use Z399 Other U014 Functional fluids (open systems) Liquid or gaseous chemical substances used for one or more operational properties in an open system. Examples include antifreezes and de-icing fluids such as ethylene and propylene glycol, sodium formate, potassium acetate, and, sodium acetate. This code also includes substances incorporated into metal working fluids. 3.3.c Otherwise Use: Ancillary or other use Z399 Other U018 Odor agents Chemical substances used to control odors, remove odors, mask odors, or impart odors. Examples include benzenoids, terpenes and terpenoids, musk chemicals, aliphatic aldehydes, aliphatic cyanides, and mercaptans. 3.3.c Otherwise Use: Ancillary or other use Z399 Other U020 Photosensitive chemicals Chemical substances used for their ability to alter their physical or chemical structure through absorption of light, resulting in the emission of light, dissociation, discoloration, or other chemical reaction. Examples include sensitizers, fluorescents, photovoltaic agents, ultraviolet absorbers, and ultraviolet stabilizers. 3.3.c Otherwise Use: Ancillary or other use Z399 Other U023 Plating agents and surface treating agents Chemical substances applied to metal, plastic, or other surfaces to alter physical or chemical properties of the surface. Examples include metal surface treating agents, strippers, etchants, rust and tarnish removers, and descaling agents. 6 Page 187 of 204 ------- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Public Comment Draft - Do Not Cite or Quote Appendix D EXPOSURE - PRE-SCREENING ANALYSIS Pre-screening analysis for the ambient air pathway was completed for both 1-BP and MC in this work. The methodology for this analysis is described in Section 2.1.2.1. All inputs used for all exposure scenarios evaluated are included in Supplemental File SF FLA Air Pathway Input Parameters for 110AC for 1-BP andMC (Appendix B). Some of the inputs are further discussed below. The physical parameters of the source type are pre-defined values within IIOAC and are discussed in the IIOAC users guide ( ). The only source type parameter that can be varied is the area of a fugitive source. For this work, EPA used 100 m2 as the area of the fugitive source because even with releases reported to TRI, there was no data available on the actual size of the fugitive source. Table Apx D-l. Parameters Used for Point and Fugitive Source Type Parameter Stack" Fugitive'' Release height (m) 10 3.05 Stack inside diameter (m) 2 N/A Exit gas velocity (m/s) 5 N/A Exit gas temperature (K) 300 N/A Area (m2) N/A 100 a Length and width were assumed to be 10 meters. b N/A indicates parameter is not applicable for that source type. Meteorological Stations: IIOAC includes 14 pre-defined climate regions (each with a surface station and upper-air station). As discussed in Section 2.1.2.1, where no TRI data or city location was provided for releases, EPA selected two of the 14 climate regions to represent a central tendency (West North Central) and high-end (South [Coastal]) climate region based on a sensitivity analysis of the average concentration and deposition predictions, using 5 years of meteorological data (2011 through 2015) for all source types. A summary of the average air concentration and particle deposition predictions for all 14 climate regions is provided in TableApx D-2. TableApx D-2. Average Air Concentrations and Particle Deposition for 14 IIOAC Climate Regions Climate Region Su rt'acc Station Avg. Air Concentration (jig/m3) Avg. Particle Deposition (g/m2) Air Concentration Rank Particle Deposition Rank East North Central Iowa City, IA 3.71 2.66 3 5 Northeast (Coastal) Camp Springs, MD 3.48 1.75 7 14 Northeast (Inland) Pittsburgh, PA 1.85 5.58 14 1 Northwest (Coastal) Everett, WA 3.60 2.14 4 10 Northwest (Inland) Idaho Falls, ID 2.88 3.64 12 2 Page 188 of 204 ------- 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Public Comment Draft - Do Not Cite or Quote Climate Region Su rfacc Station Avg. Air Concentration (jig/m3) Avg. Particle Deposition (g/m2) Air Concentration Rank Particle Deposition Rank South (Inland) Topeka, KS 3.46 2.09 8 11 South (Coastal) Lake Charles, LA 4.51 2.19 1 8 Southeast (Coastal) New River, NC 3.73 2.50 2 6 Southeast (Inland) Atlanta, GA 3.08 2.36 10 7 Southwest Grand Junction, CO 3.14 3.24 9 3 West (Coastal) Point Mugu, CA 3.05 2.03 11 13 West (Inland) Las Vegas, NV 2.30 2.75 13 4 West North Central Sioux Falls, SD 3.49 2.16 6 9 Central Rockford, IL 3.50 2.06 5 12 Release: Release data was extracted from the 2019 TRI data set. EPA extracted the maximum total release reported from all TRI reporting facilities for each chemical. EPA also calculated the arithmetic mean of all reported releases across all TRI reporting facilities for each chemical. These values do not include surrogate facilities or EPA estimated releases but were used to represent the maximum and mean releases for purposes of the pre-screening analysis. These releases are summarized in Table Apx D-3. Table Apx D-3. Maximum and Mean Releases by Chemical for Pre-screening Analysis Chemical Number of Days Operating Maximum Facility Release Average Facility Release lbs kg kg/site-day lbs kg kg/site-day 1-Bromopropane 365 229,135 103,916 285 15,658 7,101 19.46 260 400 27.31 Methylene Chloride 375 438,116 198,692 544 10,708 4,856 13.30 260 764 18.68 Exposure Concentrations and Risk Calculations: All exposure concentrations for 1-BP for all IIOAC model runs for all exposure scenarios are included in Supplemental File SFFLA Air Pathway Pre-Screening Results for 1-BP (Appendix B). All exposure concentrations for MC for all IIOAC model runs for all exposure scenarios are included in Supplemental File SF FLA Air Pathway Pre-Screening Results for MC (Appendix B). IIOAC Model runs provided mean (central tendency) and high-end (defined as the 95th percentile) daily-averaged and annual-averaged outdoor air concentrations in micrograms per cubic meter (|ig/m3) at fenceline (100 meters) and community average (100-1000 meters) distances, for each scenario modeled. Exposure concentrations were converted into ppm using the chemical's molecular weight. The highest daily outdoor air concentrations (in ppm), from all the IIOAC model runs, for fenceline and community average distances, respectively, were used to calculate acute non-cancer risks at various Page 189 of 204 ------- 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 Public Comment Draft - Do Not Cite or Quote PODs. The highest annual outdoor air concentrations (in ppm), from all the IIOAC model runs, for fenceline and community average distances, respectively, were used to calculate chronic non-cancer and cancer risks at various PODs. These results are summarized in TableApx D-4. For both 1-BP and MC, the highest daily and annual average outdoor air concentrations occurred for the following exposure scenario: Fugitive emissions in a rural setting using the high end meteorological station (South Coastal) with the maximum release and 365 days of operation (24/7). Risk Findings: Risk Calculations using the highest daily and annual outdoor air concentrations for 1-BP are included in Supplemental File SFFLA Air Pathway Pre-Screening Results for 1-BP (Appendix B). Risk calculations using the highest daily and annual outdoor air concentrations for MC are included in Supplemental File SF FLA Air Pathway Pre-Screening Analysis Results for MC (Appendix B). Based on the data provided in Table Apx D-4, acute and chronic non-cancer risks were found at the fenceline distance of 100 meters for 1-BP for the high-end and central tendency exposure concentrations. Additionally, cancer risks were found at both fenceline and community average distances for 1-BP for both the high-end and central tendency exposure concentrations. Neither acute nor chronic non-cancer risks were found for MC. Cancer risk was found at the fenceline distance of 100 meters for MC for the high-end exposure concentration only. Based on the data provided in Table Apx D-4, acute and chronic non-cancer risks were found at the fenceline distance of 100 meters for 1-BP for the high-end exposure concentration only. Additionally, cancer risks were found at both fenceline and community average distances for both the high-end and central tendency exposure concentrations. Non-cancer risks were not found for MC although cancer risks were found at the fenceline distance of 100 meters for the high-end exposure concentration only. Based on the results above, we found risks for each of the two chemicals evaluated (1-BP and MC), and therefore EPA has initiated a full screening level analysis. Page 190 of 204 ------- Public Comment Draft - Do Not Cite or Quote 1 Table Apx D-4. Exposure Concentrations and Risk Calculations Chemical noAC Outputs (Statistics) Concentration (ppm) Risks (Inhalation) Fcncclinc Community Average Non-cancerah-'d Cancer7 Daily Annual Daily Annual Acute Chronic Fcncclinc Community Average Fcncclinc Community Average Fcncclinc Community Average 1-BP HE 9.71E-02 9.71E-02 1.13E-02 1.13E-02 62 531 62 531 5.83E-04 6.78E-05 CT 8.90E-02 8.90E-02 1.01E-01 1.01E-01 67 597 67 597 5.34E-04 6.03E-05 MC HE 2.68E-06 2.68E-01 3.12E-02 3.12E-02 648 5569 64 551 1.56E-06 1.81E-07 CT 6.56E-03 6.56E-03 7.64E-04 7.64E-04 26,507 227,786 2,620 2,2517 3.81E-08 4.43E-09 " Used Benchmark MOE of 100 for acute and chronic risks for 1 -BP b Used Benchmark MOE of 30 and 10 for acute and chronic risks, respectively, for MC c Used End Points (Post-Implantation Loss (F0)) of 6 (per ppm) for acute and chronic risks for 1-BP d Used End Points of 174 (Decreased Visual Performance) and 17.2 (Vacuolization and Cell Foci) (per ppm) for acute and chronic risks, respectively, for MC e Used Benchmark MOE of 1.00E-06 for cancer risk ' Used End Points 5.00E-03 (liver) for 1-BP and 5.80E-06 (lung and liver tumors) for MC Page 191 of 204 ------- Public Comment Draft - Do Not Cite or Quote Appendix E 1-BP, MC, AND NMP RISK EVALUATION COU TO OES MAPPING TableApx E-l, TableApx E-2, and TableApx E-3 contain a mapping of the conditions of use (COU) to occupational exposure scenarios (OES) from the 1-BP, MC, and NMP Risk Evaluations, respectively ( 2020b. c, d). EPA used the OES from the Risk Evaluations, as they are summarized in these tables, for the release estimates in Sections 3.1.3, 3.2.3, and 3.3.3. Table Apx E-l. 1-BP Risk Evaluation Conditions of Use to OES Mapping Conditions of Use from the 1-BP Risk Evaluation" Occupational Life Cycle Stage Category Subcategory Exposure Scenario (OES) from the 1-BP Risk Evaluation" Manufacture Domestic manufacture Domestic manufacture Manufacture Import Import Import Processing as a reactant Intermediate in all other basic inorganic chemical manufacturing, all other basic organic chemical manufacturing, and pesticide, fertilizer and other agricultural chemical manufacturing Processing as a Reactant Processing - incorporating into formulation, mixture or reaction product Solvents for cleaning or degreasing in manufacturing of: • all other chemical product and Processing - Incorporation into Formulation, Mixture, or Reaction Product Processing preparation • computer and electronic product • electrical equipment, appliance and component • soap, cleaning compound and toilet preparation • services Processing - incorporating into articles Solvents (which become part of product formulation or mixture) in construction Processing - Incorporation into Articles Processing Repackaging Solvent for cleaning or degreasing in all other basic organic chemical Repackaging Recycling Recycling Disposal and Recycling Distribution in Distribution Distribution Not assessed as a commerce separate operation; exposures/releases from distribution are Page 192 of 204 ------- Public Comment Draft - Do Not Cite or Quote Conditions of Use from the 1-BP Risk Evaluation" Occupational Exposure Scenario (OES) from the 1-BP Risk Evaluation" Life Cycle Stage Category Subcategory considered within each condition of use. Industrial/ commercial use Solvent (for cleaning or degreasing) Batch vapor degreaser (e.g., open-top, closed- loop) Batch Vapor Degreaser (Open-Top) Batch Vapor Degreaser (Closed- Loop) In-line vapor degreaser (e.g., conveyorized, web cleaner) In-line Vapor Degreaser Cold cleaner Cold Cleaner Aerosol spray degreaser/cleaner Aerosol Spray Degreaser/Cleaner Adhesives and sealants Adhesive chemicals - spray adhesive for foam cushion manufacturing and other uses Adhesive Chemicals (Spray Adhesives) Industrial/ commercial use Industrial/ commercial use Cleaning and furniture care products Dry cleaning solvent Dry Cleaning Spot cleaner, stain remover Spot Cleaner, Stain Remover Liquid cleaner (e.g., coin and scissor cleaner) Other Uses Liquid spray/aerosol cleaner Other Uses Other uses Arts, crafts and hobby materials - adhesive accelerant Other Uses Automotive care products - engine degreaser, brake cleaner Aerosol Spray Degreaser/Cleaner Anti-adhesive agents - mold cleaning and release product Other Uses Building/construction materials not covered elsewhere - insulation THERMAX Installation Electronic and electronic products and metal products Other Uses Functional fluids (closed systems) - refrigerant Other Uses Functional fluids (open system) - cutting oils Other Uses Other - asphalt extraction Other Uses Page 193 of 204 ------- Public Comment Draft - Do Not Cite or Quote Conditions of Use from the 1-BP Risk Evaluation" Occupational Exposure Scenario (OES) from the 1-BP Risk Evaluation" Life Cycle Stage Category Subcategory Other - laboratory chemicals Other Uses Temperature indicator - coatings Other Uses Disposal (Manufacturing, Processing, Use) Disposal Municipal waste incinerator Disposal, Recycling Off-site waste transfer a This table is based on Table 2-2 of the 2020 1-Bromopane Risk Evaluation (U.S. EPA, 2020b). 9 10 Page 194 of 204 ------- Public Comment Draft - Do Not Cite or Quote 11 Table Apx E-2. MC Risk Evaluation Conditions of Use to PES Mapping Conditions of I se from (lie MC Uisk Evaluation" Occupational Lxposurc Scenario l.il'e Cycle Stage Category l.il'e Cycle Stage (OLS) from the MC Uisk Evaluation Category11 Manufacturing Domestic manufacturing Manufacturing Manufacturing Import Import Repackaging Intermediate in industrial gas manufacturing (e.g., manufacture of fluorinated gases used as refrigerants) Intermediate for Processing Processing as a reactant pesticide, fertilizer, and other agricultural chemical manufacturing Processing as a Reactant CBI function for petrochemical manufacturing Intermediate for other chemicals Solvents (for cleaning or degreasing), including manufacturing of: • All other basic organic chemical • Soap, cleaning compound and Incorporated into formulation, mixture, or reaction product toilet preparation Processing - Incorporation into Formulation, Mixture, or Reaction Solvents (which become part of product formulation or mixture), including manufacturing of: • All other chemical product and preparation • Paints and coatings Product Page 195 of 204 ------- Public Comment Draft - Do Not Cite or Quote Conditions of I so from (lie \l( Kisk Evaluation" Life Cycle Stage Processing Category Repackaging Life Cycle Stage Propellants and blowing agents for all other chemical product and preparation manufacturing Propellants and blowing agents for plastics product manufacturing Paint additives and coating additives not described by other codes for CBI industrial sector Laboratory chemicals for all other chemical product and preparation manufacturing Laboratory chemicals for CBI industrial sectors Processing aid, not otherwise listed for petrochemical manufacturing Adhesive and sealant chemicals in adhesive manufacturing Unknown function for oil and gas drilling, extraction, and support activities Solvents (which become part of product formulation or mixture) for all other chemical product and preparation manufacturing CBI functions for all other chemical product Occupational Exposure Scenario (OES) from (lie MC Kisk Evaluation Category11 Processing - Incorporation into Formulation, Mixture, or Reaction Product Repackaging Page 196 of 204 ------- Public Comment Draft - Do Not Cite or Quote Conditions of I so from (lie \l( Kisk Evaluation" Occupational Exposure Scenario Life Cycle Stage Category Life Cycle Stage (OES) from (lie M( Kisk Evaluation Category11 and preparation manufacturing Recycling Recycling Waste Handling, Disposal, Treatment, and Recycling Distribution in commerce Distribution Distribution Repackaging Batch vapor degreaser (e.g., open-top, closed- loop) Batch Open-Top Vapor Degreasing Industrial, commercial and consumer uses Solvents (for cleaning or degreasing) In-line vapor degreaser (e.g., conveyorized, web cleaner) Convey orized Vapor Degreasing Cold cleaner Cold Cleaning Aerosol spray degreaser/cleaner Commercial Aerosol Products (Aerosol Degreasing, Aerosol Lubricants, Automotive Care Products) Adhesives and sealants Single component glues and adhesives and sealants and caulks Adhesives and Sealants Paints and coatings including paint and coating removers Paints and coatings use Paints and Coatings Adhesive/caulk removers Adhesive and Caulk Removers Paints and coating removers, including furniture refinishers Paint Remover Industrial, commercial and consumer uses Industrial, commercial and Metal products not covered elsewhere Degreasers - aerosol and non-aerosol degreasers and cleaners e.g., coil cleaners Commercial Aerosol Products (Aerosol Degreasing, Aerosol Lubricants, Automotive Care Products) Miscellaneous Non-aerosol Industrial and Commercial Uses consumer uses Fabric, textile, and leather products not covered elsewhere Textile finishing and impregnating/ surface treatment products e.g., water repellant Fabric Finishing Automotive care products Function fluids for air conditioners: refrigerant, treatment, leak sealer Miscellaneous Non-aerosol Industrial and Commercial Uses Page 197 of 204 ------- Public Comment Draft - Do Not Cite or Quote Conditions of I so from (lie \l( Kisk Evaluation" Occupational Exposure Scenario Life Cycle Stage Category Life Cycle Stage (OES) from (lie M( Kisk Evaluation Category11 Interior car care - spot remover Commercial Aerosol Products (Aerosol Degreasing, Aerosol Lubricants, Automotive Care Products) Automotive care products Degreasers: gasket remover, transmission cleaners, carburetor cleaner, brake quieter/cleaner Commercial Aerosol Products (Aerosol Degreasing, Aerosol Lubricants, Automotive Care Products) Apparel and footwear care products Post-market waxes and polishes applied to footwear e.g., shoe polish Commercial Aerosol Products (Aerosol Degreasing, Aerosol Lubricants, Automotive Care Products) Laundry and dishwashing products Spot remover for apparel and textiles Spot Cleaning Industrial, commercial and consumer uses Industrial, commercial and consumer uses Lubricants and greases Liquid and spray lubricants and greases Commercial Aerosol Products (Aerosol Degreasing, Aerosol Lubricants, Automotive Care Products) Miscellaneous Non-aerosol Industrial and Commercial Uses Degreasers - aerosol and non-aerosol degreasers and cleaners Building/ construction materials not covered elsewhere Cold pipe insulation Commercial Aerosol Products (Aerosol Degreasing, Aerosol Lubricants, Automotive Care Products) Solvents (which become part of product formulation or mixture) All other chemical product and preparation manufacturing Processing - Incorporation into Formulation, Mixture, or Reaction Product Processing aid not otherwise listed In multiple manufacturing sectors Cellulose Triacetate Film Production Propellants and blowing agents Flexible polyurethane foam manufacturing Flexible Polyurethane Foam Manufacturing Arts, crafts, and hobby materials Crafting glue and cement/concrete Adhesives and Sealants Page 198 of 204 ------- Public Comment Draft - Do Not Cite or Quote Conditions of I so from (lie \l( Kisk Evaluation" Occupational Exposure Scenario (OES) from (lie M( Kisk Evaluation Category11 Life Cycle Stage Category Life Cycle Stage Other Uses Laboratory chemicals - all other chemical product and preparation manufacturing Laboratory Use Electrical equipment, appliance, and component manufacturing Miscellaneous Non-aerosol Industrial and Commercial Uses Plastic and rubber products Plastic Product Manufacturing Anti-adhesive agent - anti-spatter welding aerosol Commercial Aerosol Products (Aerosol Degreasing, Aerosol Lubricants, Automotive Care Products) Oil and gas drilling, extraction, and support activities Miscellaneous Non-aerosol Industrial and Commercial Uses Toys, playground, and sporting equipment - including novelty articles (toys, gifts, etc.) Miscellaneous Non-aerosol Industrial and Commercial Uses Carbon remover, lithographic printing cleaner, wood floor cleaner, brush cleaner Lithographic Printing Plate Cleaning Disposal Disposal Industrial pre-treatment Waste Handling, Disposal, Treatment, and Recycling Industrial wastewater treatment Publicly owned treatment works (POTW) Underground injection Municipal landfill Hazardous landfill Other land disposal Municipal waste incinerator Page 199 of 204 ------- Public Comment Draft - Do Not Cite or Quote Conditions of I so from (lie \l( Kisk Evaluation" Occupational Exposure Scenario (OES) from (lie MC Kisk Evaluation Category11 Life Cycle Stage Category Life Cycle Stage Hazardous waste incinerator Off-site waste transfer a This table is based on Table 2-22 of the 2020 Methylene Chloride Risk Evaluation ("U.S. EPA. 2020c). Page 200 of 204 ------- Public Comment Draft - Do Not Cite or Quote Table Apx E-3. NMP Risk Evaluation Conditions of Use to OES Mapping Conditions of Use from t le NMP Risk Evaluation" Occupational Exposure Scenario Life Cycle Stage Category Subcategory (OES) from the NMP Risk Evaluation Category" Manufacturing Domestic Manufacture Domestic Manufacture Manufacturing Import Import Repackaging Processing as a reactant or intermediate Intermediate in Plastic Material and Resin Manufacturing Chemical Processing, Excluding Formulation Other Non-incorporative Processing Adhesives and sealant chemicals in Adhesive Manufacturing Incorporation into Formulation, Mixture, or Reaction Product Anti-adhesive agents in Printing and Related Support Activities Incorporation into Formulation, Mixture, or Reaction Product Paint additives and coating additives not described by other codes in Paint and Coating Manufacturing; and Print Ink Manufacturing Incorporation into Formulation, Mixture, or Reaction Product Processing aids not otherwise listed in Plastic Material and Resin Manufacturing Incorporation into Formulation, Mixture, or Reaction Product Processing Incorporated into formulation, mixture, or reaction product Solvents (for cleaning or degreasing) in Non- metallic Mineral Product Manufacturing; Machinery Manufacturing; Plastic Material and Resin Manufacturing; Primary Metal Manufacturing; Soap, Cleaning Compound and Toilet Preparation Manufacturing; Transportation Equipment Manufacturing; All Other Chemical Product and Preparation Manufacturing; Printing and Related Support Activities; Services; Wholesale and Retail Trade Incorporation into Formulation, Mixture, or Reaction Product Surface active agents in Soap, Cleaning Compound and Toilet Preparation Manufacturing Incorporation into Formulation, Mixture, or Reaction Product Plating agents and surface treating agents in Fabricated Metal Product Manufacturing Incorporation into Formulation, Mixture, or Reaction Product Page 201 of 204 ------- Public Comment Draft - Do Not Cite or Quote Conditions of Use from t le NMP Risk Evaluation" Occupational Exposure Scenario (OES) from the NMP Risk Evaluation Category" Life Cycle Stage Category Subcategory Processing Solvents (which become part of product formulation or mixture) in Electrical Equipment, Appliance and Component Manufacturing; Other Manufacturing; Paint and Coating Manufacturing; Print Ink Manufacturing; Soap, Cleaning Compound and Toilet Preparation Manufacturing; Transportation Equipment Manufacturing; All Other Chemical Product and Preparation Manufacturing; Printing and Related Support Activities; Wholesale and Retail Trade Incorporation into Formulation, Mixture, or Reaction Product Other uses in Oil and Gas Drilling, Extraction and Support Activities; Plastic Material and Resin Manufacturing; Services Incorporation into Formulation, Mixture, or Reaction Product Incorporation into articles Lubricants and lubricant additives in Machinery Manufacturing Metal Finishing Paint additives and coating additives not described by other codes in Transportation Equipment Manufacturing Application of Paints, Coatings, Adhesives, and Sealants Solvents (which become part of product formulation or mixture), including in Textiles, Apparel and Leather Manufacturing Incorporation into Formulation, Mixture, or Reaction Product Other, including in Plastic Product Manufacturing Chemical Processing, Excluding Formulation Repackaging Wholesale and Retail Trade Repackaging Recycling Recycling Recycling and Disposal Distribution in Commerce Distribution Distribution in Commerce Repackaging Paints and coatings Paint and coating removers Removal of Paints, Coatings, Adhesives, and Sealants Adhesive removers Removal of Paints, Coatings, Adhesives, and Sealants Page 202 of 204 ------- Public Comment Draft - Do Not Cite or Quote Conditions of Use from t le NMP Risk Evaluation" Occupational Exposure Scenario (OES) from the NMP Risk Evaluation Category" Life Cycle Stage Category Subcategory Industrial/ Commercial Use Lacquers, stains, varnishes, primers and floor finishes Application of Paints, Coatings, Adhesives, and Sealants Powder coatings (surface preparation) Application of Paints, Coatings, Adhesives, and Sealants Paint additives and coating additives not described by other codes Use in Computer and Electronic Product Manufacturing in Electronic Parts Manufacturing Other Electronics Manufacturing Use in Computer and Electronic Product Manufacturing for Use in Semiconductor Manufacturing Semiconductor Manufacturing Use in Construction, Fabricated Metal Product Manufacturing, Machinery Manufacturing, Other Manufacturing, Paint and Coating Manufacturing, Primary Metal Manufacturing, Transportation Equipment Manufacturing, Wholesale and Retail Trade Application of Paints, Coatings, Adhesives, and Sealants Solvents (for cleaning or degreasing) Use in Electrical Equipment, Appliance and Component Manufacturing Other Electronics Manufacturing Use in Electrical Equipment, Appliance and Component Manufacturing for Use in Semiconductor Manufacturing Semiconductor Manufacturing Ink, toner, and colorant products Printer ink Printing and Writing Inks in writing equipment Printing and Writing Processing aids, specific to petroleum production Petrochemical Manufacturing Chemical Processing, Excluding Formulation Other uses Other uses in Oil and Gas Drilling, Extraction and Support Activities Chemical Processing, Excluding Formulation Functional Fluids (closed systems) Chemical Processing, Excluding Formulation Adhesives and sealants Adhesives and sealant chemicals including binding agents Application of Paints, Coatings, Adhesives, and Sealants Page 203 of 204 ------- Public Comment Draft - Do Not Cite or Quote Conditions of Use from t le NMP Risk Evaluation" Occupational Exposure Scenario (OES) from the NMP Risk Evaluation Category" Life Cycle Stage Category Subcategory Industrial/ Commercial Use Single component glues and adhesives, including lubricant adhesives Application of Paints, Coatings, Adhesives, and Sealants Two-component glues and adhesives, including some resins Application of Paints, Coatings, Adhesives, and Sealants Other uses Soldering materials Soldering Anti-freeze and de-icing products Commercial Automotive Serving Automotive care products Commercial Automotive Serving Lubricants and greases Commercial Automotive Serving Metal products not covered elsewhere Metal Finishing Lubricant and lubricant additives, including hydrophilic coatings Metal Finishing Laboratory chemicals Laboratory Use Lithium ion battery manufacturing Lithium Ion Cell Manufacturing c Cleaning and furniture care products, including wood cleaners, gasket removers Cleaning Fertilizer and other agricultural chemical manufacturing - processing aids and solvents Fertilizer Application Disposal Disposal Industrial pre-treatment Recycling and Disposal Industrial wastewater treatment Recycling and Disposal Publicly owned treatment works (POTW) Recycling and Disposal Underground injection Recycling and Disposal Landfill (municipal, hazardous, or other land disposal) Recycling and Disposal Emissions to air Recycling and Disposal Incinerators (municipal and hazardous waste) Recycling and Disposal " This table is based on Table 2-2 of the 2020 n-Methvlpvrrolidone Risk Evaluation (U.S. EPA. 2020dV Page 204 of 204 ------- |