UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
OFFICE
OF
AIR
QUALITY
PLANNING
AND
STANDARDS
EMISSION
STANDARDS
DIVISION
RESEARCH
TRIANGLE
PARK,
NC
27711
August
12,
2003
SUBJECT:
Residual
Risk
Test
in
Support
of
the
Section
112(
f)(
2)
Residual
Risk
Analysis
for
Magnetic
Tape
Manufacturing
Source
Category
FROM:
H.
Lynn
Dail,
Project
Lead
Coatings
and
Consumer
Products
Group
(
C539­
03)

TO:
Maria
Pimentel,
Health
Scientist
Risk
Evaluation
and
Analysis
Group
(
C404­
01)

The
residual
risk
project
for
magnetic
tape
source
category
has,
to
date,
investigated
both
the
2001
TRI,
1999
NEI
air
emission
databases
and
has
gleaned
information
from
these
databases
and
from
the
individual
facilities
themselves.
We
believe
we
have
suitable
information
to
commence
the
initial
risk
screening
test
for
this
source
category.
Attached
are
the
results
of
our
investigation
which
includes
a
list
of
facility
names
and
addresses,
the
HAPs
emitted,
the
emission
points
and
the
stack
parameters,
and
the
relative
weighted
toxicity
values.

During
the
investigation,
it
was
important
to
answer
a
number
of
questions
concerning
the
data
and
how
it
may
demonstrate
the
representative
emissions
associated
with
the
magnetic
tape
surface
coating
industry.
The
Magnetic
Tape
NESHAP
sets
standards
for
3
Standard
Industrial
Codes
(
SIC),
2672,
3695,
and
3861
for
the
surface
coating
of
magnetic
tape
We
have
evaluated
the
resulting
information
from
the
facilities,
the
2000
TRI
and
1999
NEI,
Version
3
(
released
by
EPA
in
July
2002)
for
sources
on
a
number
of
the
following
points:

1.
Identification
of
all
operating
magnetic
tape
major
sources.
Total
of
six.
2.
Information
sources
included
TRI
data
supporting
the
NEI
data
and
facility­
supplied
data.
3.
Data
extracted
using
primary
Magnetic
Tape
SIC
codes.
4.
Data
included
plant
names,
locations,
all
SIC
codes,
stack
parameter
data,
magnetic
tape
HAP
emissions,
and
total
emissions
data.
5.
Data
was
cross
checked
to
correspond
to
a
single
Federal
Facility
ID
number.

Resulting
data
queries
into
the
1999
NEI,
the
2000
TRI
have
shown
predominant
magnetic
tape
surface
coating
primarily
in
Alabama,
with
remaining
locations
in
Oklahoma,
Minnesota
and
New
York.
It
is
reported
that
these
facilities
and
states
provided
very
detailed
and
complete
inventory
data
at
the
individual
stack
level.
The
facility
data
from
the
TRI
revealed
emissions
units,
their
stack
emission
poinst,
the
emission
points
with
particular
production
processes
including
magnetic
tape
surface
coating
and
other
MACT
category
processes,
and
the
emission
points
associated
with
the
facility.
Values
for
magnetic
tape
surface
coating
facilities
identified
on
the
resulting
lists
are
included
in
the
NEI.
All
facility­
specific
and
defaulted
values
for
stack,
operation
parameters
and
location
fields
are
identified.
All
facilities
are
named
with
their
geographic
location
and
contains
recommendations
on
the
data
deemed
most
suitable
for
use
in
the
risk
test
as
follows:
2
Quantegy
Inc.,
Opelika,
AL:

S
Used
2000
TRI
emission
supplemented
with
facility­
reported
stack
parameter
data
with
the
NEI
data.

S
Supplemented
facility­
reported
stack
parameter
data
with
NEI
data.

S
Use
facility­
reported
fugitive
parameter
data
JVC
Magnetics
America
Co.,
Tuscaloosa,
AL:

S
Use
2001
TRI
emission
data
available
with
facility­
reported
percentages.

S
Use
facility­
reported
fugitive
parameter
data.

Sony
Magnetics
Products
Inc.
of
America,
Dothan,
AL:

S
2000
TRI
emissions
data
and
apply
facility­
reported
percentages
included
S
Use
facility­
provided
2003
inventory
loss
data.

S
Use
facility
diagrams
to
determine
room
dimensions.

S
Refer
to
attached
memorandum
on
Cobalt
use
to
discern
emission
amounts.

3M
Magnetic
Tape
Manufacturing
Division,
Hutchinson,
MN
S
Use
first
available
NEI
data.

S
Supplement
data
with
existing
TRI
data
and
use
default
parameters.

Eastman
Kodak,
Rochester,
NY:

S
Use
facility­
reported
emissions
data.

S
Use
facility­
reported
parameter
data.
(
Specific
to
process)

Imation
Enterprises
Corp.,
Weatherford,
OK:

S
NEI
and
TRI
emissions
are
similar.
Use
NEI
data
and
supplement
with
actual
stack
diameter
and
operating
hour
data
reported
by
facility.

We've
identified
three
potential
HAP
carcinogen
emissions
from
one
facility.
This
facility
emits
0.4
pounds
of
each
of
the
following;
acrylonitrile,
ethyl
acrylate,
and
toluene
diisocyanate.
None
of
these
compounds
appear
to
be
important
as
far
as
persistence
and
bioaccumulaltion
potential
go.
The
magnitude
of
emissions
for
all
HAPs
are
very
low.
The
primary
non­
carcinogenic
HAPs
used
in
this
source
category
are
methyl
ethyl
ketone
(
MEK),
toluene,
methanol
and
n­
hexane.
They
account
for
99.9%
of
total
HAP
emissions.
MEK
emissions
account
for
67%
of
the
total
HAP
emissions
and
toluene
30%.

One
facility,
Sony
Magnetic
Products
of
Dothan,
Alabama,
uses
metallic
cobalt
in
the
production
of
a
magnetic
computer
data
storage
tape.
Generally,
Sony
reports
their
inventory
loses
as
emissions,
however
this
does
not
accurately
account
for
material
loses.
Not
all
material
reported
in
the
inventory
loses
are
emitted.
A
large
portion
of
cobalt
ends
up
as
waste
in
the
cleaning
process
yet
is
counted
as
emissions.
An
attached
Memorandum
goes
into
detail
concerning
this
inequity.
The
issue
to
be
aware
of
is
that
the
reported
emission
number
exceeds
the
actual
cobalt
emissions
at
the
plant.
In
fact,
tests
on
the
particulate
cobalt
indicate
that
between
85%
and
95%
of
the
emissions
are
respirable.
3
Regarding
the
presence
of
1,1,2­
trichloroethane
and
trichloroethylene
in
the
NEI
database
for
Imation:
No
1,1,
2­
trichloroethane
emissions
were
reported
in
the
TRI
after
1997
for
Imation.
Only
a
portion
of
the
Imation
factory
is
dedicated
to
magnetic
tape
production.
Based
on
information
from
Imation,
the
total
VOC
associated
with
magnetic
tape
operations
is
less
than
9
percent.
The
TRI
results
for
the
three
facilities,
Quantegy,
JVC,
and
Sony/
Dothan)
than
manufacture
only
magnetic
tape
do
not
show
any
1,1,2­
trichloroethane
or
trilchloretylene
listed.
(
Sony
reports
no
used
of
the
compound
since
1992.

It
is
important
to
note
that
half
the
facilities
product
magnetic
tape
products
solely.
The
remaining
half
of
the
manufacturing
facilities
include
a
co­
mingling
of
magnetic
tape
production
in
conjunction
with
other
MACT
category
production.
In
two
instances,
magnetic
tape
represented
less
than
15%
of
the
total
production.
In
the
most
extreme
case
of
co­
located
MACT
categories,
magnetic
tape
represents
less
than
1%
of
production
at
the
facility.

Thank
you
for
efforts
in
analyzing
any
potential
risks
that
may
or
may
not
exist
with
the
surface
coating
activities
in
this
source
category.
If
you
have
any
questions,
please
contact
H.
Lynn
Dail
at
extension
2363.

Attachment
4
bcc:
Dianne
Byrne,
Group
Leader,
CCPG
Dave
Guinnup,
Group
Leader,
REAG
