From:
Holloway,
Thomas
C.
(
Tom)
Sent:
Tuesday,
June
24,
2003
11:
41
AM
To:
'
Dail.
Lynn@
epamail.
epa.
gov'
Cc:
Reeves,
David
Subject:
RE:
Briefing
for
Magnetic
Tape
Residual
Risk:
Test
Results
Lynn,

Here
are
my
responses
to
Anne
Pope's
arguments:

(
1)
Anne
is
correct
that
there
are
reporting
thresholds
for
pollutants
(
such
as
TCE
and
TCA)
in
the
TRI,
but
I
believe
there
are
ranges
even
below
the
thresholds
which
facilities
can
check
off.
The
argument
is
academic
anyway
since
the
NEI
results
for
Imation
show
that
TCE
and
TCA
are
not
associated
with
the
magnetic
tape
process
(
based
on
the
SIC
code).
As
I
mentioned
in
my
June
17
and
June
19
e­
mails,
we
recommended
the
NEI
data
for
Imation
be
used
because
it
is
possible
to
segregate
the
magnetic
tape
data
for
that
facility
from
the
other
processes
based
on
the
SIC
code.

(
2)
Anne
is
correct
that
the
facilities
we
initially
received
from
ERG
were
based
on
MACT
code
assignments,
and
those
facilities
may
at
one
time
have
been
subject
to
the
Magnetic
Tape
NESHAP.
However,
the
NEI
results
we
received
had
no
MACT
code
for
Magnetic
Tape
for
facilities
like
Sony
(
Dothan,
AL),
JVC
(
Tuscaloosa,
AL),
Quantegy
(
Opelika,
AL),
3M
(
Hutchinson,
MN),
Imation,
and
others
that
we
knew
were
covered
under
the
Magnetic
Tape
NESHAP
as
early
as
the
proposal
BID
(
those
facilities
were
all
listed
there).
We
probably
should
have
given
ERG
the
SIC
code
3695,
too,
for
their
initial
NEI
search.
However,
that
approach
would
still
have
missed
some
facilities
because
the
NEI
has
incorrect
SIC
codes
for
some
of
the
facilities
on
our
list.
For
example,
Sony
has
been
assigned
SIC
code
3679,
and
the
magnetic
tape
plant
at
3M
has
been
assigned
SIC
code
2672.
The
NEI
would
have
been
more
helpful
once
we
had
our
list
of
facilities
together.

(
3)
Anne
is
correct
that
the
NEI
has
some
process­
specific
data,
but
it
also
includes
a
lot
of
default
parameter
data
which
are
not
very
useful
(
e.
g.,
default
stack
parameters
for
fugitive
emission
sources).

I
have
looked
at
your
presentation
to
Sally.
It
looks
good.
It's
probably
too
late
to
make
any
changes,
but
I
noticed
that
you
mentioned
ethyl
acrylate
and
toluene
diisocyanate
as
being
emitted
from
Imation.
These
data
are
from
the
TRI
results
for
the
entire
Imation
facility
(
only
a
portion
of
which
makes
magnetic
tape).
Based
on
what
we
have
recently
learned
from
the
NEI,
the
magnetic
tape
process
at
Imation
does
not
emit
these
two
pollutants.
So
if
we
go
with
the
NEI
data
for
Imation,
which
I
submitted
to
you
on
June
19,
then
the
carcinogenic
risk
associated
with
Imation
should
actually
be
even
lower.
(
My
June
19
submittal
includes
only
a
portion
of
the
NEI
data
for
Imation,
i.
e.,
the
data
associated
with
SIC
code
3695,
which
does
not
include
the
TCE
and
TCA
emissions
that
Anne
Pope
mentions.)

Let
me
know
if
you
have
any
questions.

Tom
Holloway
