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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
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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
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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
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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
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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
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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
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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
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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.
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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).
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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
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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.
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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.
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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)
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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
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1-BP Air Pathway OESs
Additional Risk Identified?
Recycling and Disposal
Yes
Co-Resident Receptors (Dry-Cleaning)
Yes
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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
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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
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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
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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).
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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
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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.
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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.
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• 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.
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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.
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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
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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.
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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
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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
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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."
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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
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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
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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.
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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.
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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
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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
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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.
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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),
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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-
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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.
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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
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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.
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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
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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)
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• 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.
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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—
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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)
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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).
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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).
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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
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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
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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
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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.
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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
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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
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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
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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
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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).
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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
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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-
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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"
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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
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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).
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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
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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.
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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
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141
142
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144
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147
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150
151
152
153
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156
157
158
159
160
161
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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
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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.
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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.
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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.
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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
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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"
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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
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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
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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).
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165
166
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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
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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
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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
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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
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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
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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.
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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
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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
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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
-
-
-
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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
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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
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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
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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
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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
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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
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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
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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
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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)"
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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.
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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.
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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.
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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.
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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.
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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3,3,5 Risk Characterization for NMP
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3
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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
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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
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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
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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
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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
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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
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564; NIH Publication No. 11-5906). Research Triangle Park, NC.
http://ntp.niehs.nih.eov/ntp/htdocs/lt rptsZtr564.pdf
O'Neil Ml. (2013). The Merck index: An encyclopedia of chemicals, drugs, and biologicals. In MJ
O'Neil (Ed.), (15th ed.). Cambridge, UK: Royal Society of Chemistry.
O'Neit. MJ; Heckelman. PE; Koch. CB. (2006). The Merck index: An encyclopedia of chemicals, drugs,
and biologicals (14th ed.). Whitehouse Station, NJ: Merck & Co.
Organization for Economic. C-o; Develop.m.ent. (2017). Draft ESD on Vapor Degreasing - Internal
EPA document. Organization for Economic Co-operation and Develop.m.ent (OECD).
jP.au I \ t asseu < *\\ h ish. DP. (1963). Industrial hygiene and toxicology: Vol. II: Toxicology. In FA
Patty; DW Fassett; DD Irish (Eds.), (2nd revised ed.). New York, NY: Interscience Publishers.
Poet. TS; Kirmaii ( K Rider. M; van Thriel. v a'gas. ML; Hinderliter. PM. (2010). Quantitative risk
analysis for N-methyl pyrrolidone using physiologically based pharmacokinetic and benchmark
dose modeling. Toxicol Sci 113: 468-482. http://dx.doi.ore/10.1093/toxsci/kfp264
Putz. YR; Johnson. BL; Setzer (1979). A comparative study of the effects of carbon monoxide and
methylene chloride on human performance. J Environ Pathol Toxicol 2: 97-112.
Saillenfait. AM; Gall is sot. F; Langonne. I; Sab at (2002). Developmental toxicity of N-methyl-2-
pyrrolidone administered orally to rats. Food Chem Toxicol 40: 1705-1712.
http://dx.doi.org/ i 0. i 0 i 6/S0278-6915(02)00115-1
Saillenfait. AM; Gallissot. F; Mop (2003). 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
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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
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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
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219
220
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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
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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,
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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
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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
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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.
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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.
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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.
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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
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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
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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
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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
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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
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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.
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Name
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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.
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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
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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.
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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
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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.
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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.
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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.
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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).
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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.
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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
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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
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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
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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