Date:
May
5,
2003
From:
Thomas
Holloway
Subject:
Response
to
ICF
Memo
To:
H.
Lynn
Dail
This
memorandum
summarizes
our
response
to
ICF's
preliminary
NEI
queries,
which
are
presented
in
their
April
25,
2003
memorandum.

As
noted
in
ICF's
memorandum,
there
are
some
conflicts
between
the
primary
SIC
codes
listed
in
the
NEI
and
the
magnetic
tape
SIC
codes
provided
by
EPA.
The
magnetic
tape
SIC
codes
provided
by
EPA
(
3695,
2672,
and
3861)
are
based
on
information
retrieved
from
searches
of
the
TRI
database.
The
SIC
codes
3695,
2672,
and
3861
are
associated
with
magnetic
and
optical
recording
media
manufacturing,
coated
and
laminated
paper
manufacturing,
and
photographic
equipment
and
supplies,
respectively.

According
to
ICF's
NEI
search
results,
most
of
the
emissions
from
Quantegy
and
all
of
the
emissions
from
Sony
are
from
operations
associated
with
SIC
code
3679
(
electronic
components
manufacturing).
This
SIC
code
was
not
included
in
any
of
our
TRI
search
results.
Our
contacts
at
Quantegy
and
Sony
have
verified
that
their
facilities
only
produce
magnetic
tape,
so
all
of
the
reported
emissions
for
these
facilities
are
from
magnetic
tape
manufacturing
operations.
Therefore,
the
NEI
emission
estimates
associated
with
SIC
code
3679
must
be
associated
with
the
facilities'
magnetic
tape
manufacturing
operations.
(
Whether
these
facilities'
operations
actually
belong
in
SIC
code
3679
is
another
matter.)
The
SIC
code
3679
specifically
includes
communications
equipment
manufacturing,
audio/
video
equipment
manufacturing,
printed
circuit
assembly,
and
other
electronic
components
manufacturing.
It
is
conceivable
that
audio,
video,
and
data
tape,
which
are
magnetic
tape
products
manufactured
at
Quantegy
and
Sony,
could
have
been
categorized
as
communications
and
audio/
video
equipment
under
SIC
code
3679.

Consequently,
it
must
be
concluded
that
Sony's
cobalt
emissions,
the
primary
factor
in
the
its
elevated
hazard
index
(
HI),
are
from
magnetic
tape
manufacturing.
According
to
our
contact
at
Sony
(
Mr.
Mark
Farmer,
Environmental
Manager,
334­
793­
7655,
ext.
1011),
their
facility
manufactures
Advanced
Metal
Evaporated
(
AME)
tape
for
high
data
storage.
The
process
involves
the
vaporization
of
cobalt
under
a
vacuum
and
depositing
it
onto
a
plastic
film.
Mr.
Farmer
stated
that
there
are
very
few
emissions
from
the
process;
they
have
baghouses
that
collect
cobalt
dust
from
the
cleaning
of
parts
and
equipment.
Mr.
Farmer
also
stated
that
they
use
some
cobalt
doped
iron
oxide
powder
(
approximately
3
weight
percent)
in
their
conventional
coating
process,
and
there
are
some
fugitive
emissions
from
this
process.
2
With
the
exception
of
3M,
the
differences
in
emission
estimates
between
those
reported
in
the
NEI
and
those
provided
by
EPA
(
based
on
the
TRI)
are
most
likely
due
to
a
difference
in
base
years
from
which
emissions
were
estimated.
The
NEI
emission
estimates
are
very
similar
to
TRI
emission
estimates
for
the
year
1998,
while
EPA
used
TRI
emission
estimates
for
the
year
2000.
Except
for
Quantegy,
this
difference
in
base
years
had
little
effect,
with
NEI
and
TRI
emission
estimates
falling
within
±
15
percent
of
each
other.
In
the
case
of
Quantegy,
TRI
emission
estimates
were
about
70
percent
lower
than
NEI
emission
estimates,
primarily
because
of
a
large
reduction
in
methyl
ethyl
ketone
emissions
from
this
facility
in
the
year
2000.

In
the
case
of
3M,
the
difference
in
emission
estimates
between
those
reported
in
the
NEI
and
those
provided
by
EPA
may
be
because
the
NEI
search
did
not
include
the
necessary
SIC
code.
Another
search
for
3M
using
SIC
code
3679
or
a
related
SIC
code
may
provide
additional
emissions
data.

The
NEI
data
for
the
Eastman
Kodak
facility
show
2.75
tons
of
manganese/
manganese
compound
emissions
and
3.3
tons
of
chromium/
chromium
compound
emissions.
While
not
directly
associated
with
magnetic
tape
manufacturing
operations,
the
reported
manganese
and
chromium
emissions
should
be
verified
and
somehow
related
to
the
current
risk
evaluation
for
this
facility.
