QUALITATIVE
RISK
CHECK
SUMMARY
REPORT
SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
120
2.12
ROHM
AND
HAAS
COMPANY
This
section
presents
the
information
and
approach
used
in
assigning
the
Rohm
and
Haas
Company
(
Rohm
and
Haas)
to
one
of
the
three
prioritization
groupings
based
on
(
1)
the
facilities
overall
potential
for
resulting
in
adverse
health
impacts
and
(
2)
an
assessment
of
the
protectiveness
of
current
or
future
MACT
standards
to
determine
if
additional
permit
limits
may
be
required
to
ensure
protection
of
human
health
and
the
environment.
Section
2.12.1
presents
facility­
specific
background
information
including
process
descriptions
and
permit
history.
Section
2.12.2
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
specific
to
the
risk­
based
facility
prioritization
strategy.
Section
2.12.3
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
following
the
MACT­
based
facility
prioritization
strategy.
Specific
sources
of
information
used
to
evaluate
the
Rohm
and
Haas
facility
are
cited
and
referenced
at
the
end
of
this
report.

2.12.1
Facility
Information
The
following
summarizes
the
facility­
specific
information
provided
in
Section
2.2.1.1
of
the
Rohm
and
Haas
Qualitative
Risk
Check
Report
(
EPA
2001m).
This
information
is
intended
to
provide
a
general
facility
overview,
including
process
descriptions
and
permit
history.

The
Rohm
and
Haas
Company
owns
and
operates
a
manufacturing
and
hazardous
waste
storage
and
treatment
facility
in
Jefferson
County,
Kentucky.
Manufacturing
consists
primarily
of
acrylic
polymers
in
the
form
of
emulsions,
modifiers
for
plastics,
molding
resins,
and
solid
and
solution
grade
resins
(
Rohm
and
Haas
1996).
The
facility
is
subject
to
the
requirements
of
RCRA
promulgated
at
Title
40
CFR
Part
266
and
the
equivalent
KDEP
state
regulations
at
401
KAR.
In
addition
to
manufacturing,
Rohm
and
Haas
operates
a
hazardous
waste
burning
boiler
(
Boiler
No.
100)
for
energy
recovery.

The
facility
is
located
approximately
1.5
kilometers
east
of
the
Indiana
and
Kentucky
border
across
the
Ohio
River
in
Louisville,
Jefferson
County,
Kentucky,
and
occupies
approximately
160
acres
of
land
on
Campground
Road.
The
facility
was
first
constructed
in
1942
by
the
U.
S.
Government
and
was
bought
by
Rohm
and
Haas
in
1960.
Constructed
features
on
the
property
include
(
1)
administrative,
preparation,
receiving,
and
laboratory
buildings;
(
2)
a
container
storage
pad;
(
3)
three
hazardous
waste
management
tanks;
(
4)
the
incineration
building;
(
5)
a
deluge
water
basin;
and
(
6)
two
recycle
tanks.

Rohm
and
Haas
receives
a
variety
of
wastes
from
on­
and
off­
site
sources.
Waste
materials
generated
at
the
facility
are
transported
directly
by
pipeline
or
in
containers
via
fork­
lift
trucks,
while
off­
site
wastes
are
transported
to
the
facility
by
rail
car
or
tank
truck.
All
containerized
wastes
are
characterized
before
they
are
accepted
at
the
container
storage
pad
and
are
managed
as
if
they
were
filled
with
free
liquid.
No
waste
is
accepted
from
off
site
for
storage
or
treatment
at
the
facility
until
a
representative
sample
has
been
analyzed
and
it
has
been
determined
that
the
waste
can
be
managed
safely
in
conformance
with
all
applicable
permits.
Management
of
the
wastes
includes
design
spill
calculation,
verification
that
container
labels
match
manifests,
and
compatibility
determination
based
on
process
knowledge,
testing,
and
material
safety
data
sheets
(
MSDS)
(
Rohm
and
Haas
1996).

Waste
streams
generated
at
the
facility
are
generally
stored
in
one
of
three
storage
tanks
and
are
treated
in
QUALITATIVE
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SUMMARY
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SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
121
the
facility's
boiler.
In
addition,
the
facility
accepts
similar
hazardous
and
nonhazardous
wastes
from
other
Rohm
and
Haas
facilities
to
burn
for
energy
recovery
in
the
boiler.
These
plants
manufacture
acrylic
monomers,
plastics
and
resins,
pesticides,
plasticizers,
and
specialty
chemicals.
The
Rohm
and
Haas
research
center
in
Spring
House,
Pennsylvania,
may
also
send
waste
to
the
Louisville
plant
(
Rohm
and
Haas
1996).

After
they
have
been
accurately
characterized,
the
wastes
are
transported
to
one
of
three
stainless­
steel
tanks
(#
64140,
#
64141,
and
#
64250)
or
the
container
storage
pad
on
site.
The
storage
pad
is
located
in
the
north­
central
portion
of
the
facility
and
stores
material
that
is
being
held
for
shipment
for
off­
site
management
or
transport
to
the
boiler
for
incineration.
The
pad
has
a
concrete
berm
for
spill
containment.
The
enclosed
tanks
are
used
to
store
liquid
hazardous
wastes
before
they
are
burned
in
the
boiler.
Tanks
#
64140
and
#
64141
primarily
receive
wastes
from
rail
cars
and
directly
by
pipeline,
while
Tank
#
64250
primarily
receives
wastes
from
tank
trucks
and
directly
by
pipeline.
All
three
units
include
sumps
and
have
concrete
dikes
for
secondary
containment
(
Rohm
and
Haas
1996).
Both
the
tanks
and
the
container
storage
pad
were
constructed
to
provide
an
approved
location
to
store
of
hazardous
waste
for
longer
than
90
days.
(
Rohm
and
Haas
1996).

Based
on
discussions
with
Pat
Moran,
Environmental
Manager
of
Rohm
and
Haas,
only
two
of
the
original
five
boilers
onsite
(
Nos.
100,
200,
300,
400,
and
500)
are
in
operation:
Boiler
No.
100
and
Boiler
No.
500
(
Tetra
Tech
2001a).
Boilers
200,
300,
and
400
were
shut
down
in
the
early
1990s.
Because
Boiler
No.
500
is
not
permitted
to
treat
hazardous
wastes,
hazardous
wastes
managed
by
Rohm
and
Haas
are
treated
only
in
Boiler
No.
100
(
Tetra
Tech
2001a).
Specifically,
Boiler
No.
100
is
a
forced
draft
A.
B.
Combustion
Engineering
type
35­
A­
14
packaged
water
tube
boiler
designed
to
provide
superheated
steam
at
about
400
pounds
per
square
inch
gauge
(
psig).
The
combustion
chamber
is
sealed
to
prevent
fugitive
emissions.
The
flue
gases
are
discharged
to
the
atmosphere
through
Stack
No.
3,
which
is
a
65­
foot­
tall
stack.
No
APCDs
are
provided
for
dust
abatement
to
the
stack.
The
production
capacity
of
the
packaged
boiler
is
180,000
pounds
per
hour
(
lbs/
hr)
of
steam.
The
schematic
for
Boiler
No.
100
shows
waste
feed
mechanisms,
a
combustion
chamber,
and
a
flue
gas
stack
(
CDM
1999).

Information
on
the
regulatory
history
of
Rohm
and
Haas
was
limited
to
the
Dispersion
Modeling
Documentation
for
Compliance
Certification
of
Boiler
No.
100
Burning
Hazardous
Waste
Exhausting
from
Stack
No.
3
(
CDM
1999).
Rohm
and
Haas
submitted
several
Precompliance
Certification
forms
in
November
1999.
Precompliance
Certification
Form
1
established
allowable
feed
rates
before
compliance
testing
began.
Precompliance
Certification
Form
2
calculated
the
estimated
uncontrolled
emissions
for
each
feed
stream
for
compliance
with
standards
for
particulate
matter,
metals,
hydrogen
chloride,
and
chlorine.
Rohm
and
Haas
completed
a
separate
form
for
each
feed
stream.
Precompliance
Certification
Form
3
calculated
the
estimated
controlled
emissions
for
compliance
with
standards
for
particulate
matter,
Tier
II
or
III
metals,
hydrogen
chloride,
and
chlorine.
Precompliance
Certification
Form
4
compared
the
total
allowable
emission
rates
to
total
emission
rates
for
compliance
with
the
particulate
matter,
Tier
II
or
III
metals,
hydrogen
chloride,
and
chlorine
standards.
Precompliance
Certification
Form
5
documented
the
feed
rate
limits
for
ash,
metals,
and
chlorine
during
the
precompliance
period.
Precompliance
Certification
Form
7
documented
the
adjusted
Tier
I
feed
rate
limits
for
metals
and
chlorine
during
the
precompliance
period.
Also
in
November
1999,
Rohm
and
Haas
submitted
two
Compliance
Test
Notification
forms.
Compliance
Test
Notification
Form
3
described
the
testing
planned
for
Stack
3.
The
test
was
intended
to
QUALITATIVE
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SUMMARY
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SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
122
demonstrate
compliance
with
emission
limits
for
carbon
monoxide
and
particulate
matter
while
feeding
hazardous
liquid
at
the
maximum
rate.
Compliance
Test
Notification
Form
4
documented
the
planned
versus
allowable
feed
rate
limits.
In
addition,
Rohm
and
Haas
submitted
a
RCRA
Part
B
permit
application
in
January
2001
that
included
a
Screening
Level
Ecological
Risk
Assessment
Protocol
(
S

F°
Risk,
LC
[
SAF]
2001b),
a
Human
Health
Risk
Assessment
Protocol
(
SAF
2001a),
and
a
BIF
Trial
Burn
Plan
(
Rohm
and
Haas
2001).
QUALITATIVE
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SEPTEMBER
2001
FACILITY
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GROUPING
123
Rohm
and
Haas
is
operating
Boiler
No.
100
under
interim
status
pursuant
to
Hazardous
Waste
Management
Permit
No.
KYD­
006­
390­
017
in
Jefferson
County.
The
facility
is
also
operating
under
Air
Pollution
Control
Permit
No.
449­
90­
0,
which
expired
March
03,
2001.

2.12.2
Risk
Based
Facility
Prioritization
This
section
describes
findings
relative
to
assigning
Rohm
and
Haas
to
one
of
the
three
prioritization
groupings
using
the
risk­
based
facility
prioritization
strategy.
Specifically,
the
following
prioritization
table
presents
the
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
Rohm
and
Haas
Qualitative
Risk
Check
Report
(
EPA
2001m).
In
addition,
the
table
also
identifies
which
prioritization
grouping
the
overall
facility
was
assigned
to
using
the
risk­
based
facility
prioritization
strategy.
The
paragraph
following
the
prioritization
table
provides
further
justification
supporting
why
the
facility
was
assigned
to
its
specific
prioritization
grouping.
QUALITATIVE
RISK
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SUMMARY
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SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
124
OVERALL
RISK­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

Rohm
and
Haas
Louisville,
Kentucky
Risk­
based
Prioritization
Grouping:
Medium
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
above
table,
and
(
2)
consideration
of
how
each
qualitative
guiding
factor
interrelates
collectively,

Rohm
and
Haas
has
been
assigned
to
the
medium
prioritization
group
utilizing
the
overall
risk­
based
QUALITATIVE
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2001
FACILITY
PRIORITIZATION
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125
prioritization
strategy.
The
medium
designation
is
intended
to
heighten
the
awareness
of
several
key
factors
that
indicate
an
increased
potential
for
adverse
impacts
to
human
health
and
the
environment.
However,

when
compared
with
facilities
assigned
to
the
high
prioritization
grouping,
Rohm
and
Haas's
potential
risk
impacts
are
clearly
lower
than
those
facilities
assigned
to
the
high
prioritization
grouping.
In
addition,
even
though
several
individual
guiding
factors
were
assigned
to
the
high
prioritization
grouping,
there
is
less
additive
interaction
between
the
qualitative
guiding
factors
for
this
facility
and
increased
uncertainty,
which
limits
definitive
qualitative
conclusions.
Specifically,
the
decision
to
assign
Rohm
and
Haas
to
the
medium
prioritization
grouping
is
supported
by
the
following
key
factors:


Rohm
and
Haas
treats
an
estimated
35
million
pounds
of
on­
and
off­
site
hazardous
waste
annually
in
Boiler
No.
100,
which
is
not
fitted
with
an
APCD.
These
wastes
are
known
or
permitted
to
contain
common
risk
drivers,
including
mercury,
pesticides,
and
formaldehyde.
In
comparison,
facilities
that
are
grouped
in
the
high
prioritization
grouping
typically
have
multiple
sources
and
treat
larger
amounts
of
waste,
and
facilities
assigned
to
the
low
prioritization
grouping
typically
treat
well
characterized
waste
generated
on
site
that
does
not
contain
common
risk
drivers.


Rohm
and
Haas
has
not
performed
a
trial
burn
designed
to
support
a
site­
specific
risk
assessment;
therefore,
information
on
actual
stack
emission
is
limited.


Presence
and
proximity
of
residential,
farmer,
fisher,
and
acute
exposure
scenarios.
Specifically,
the
closest
residential
exposure
scenario
is
located
only
800
meters
from
the
facility
boundary.


Presence
and
proximity
and
numerous
water
bodies
and
their
associated
watersheds
within
3
kilometers
from
the
facility
boundary.


Presence
of
threatened
or
endangered
species
(
e.
g.,
six
species
of
mussels)
in
the
study
area.


Potentially
significant
documented
public
concerns
are
associated
with
facility
operations.
In
comparison,
facilities
assigned
to
the
low
prioritization
groupings
typically
do
not
have
significant
documented
public
concerns.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
Rohm
and
Haas
Qualitative
Risk
Check
Report
(
EPA
2001m).
Several
individual
qualitative
guiding
factors
assigned
to
the
medium
and
high
prioritization
groupings
indicate
an
increased
potential
for
adverse
risk
impacts.
The
decision
to
assign
Rohm
and
Haas
to
the
medium
prioritization
grouping
is
further
supported
based
on
a
QUALITATIVE
RISK
CHECK
SUMMARY
REPORT
SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
126
comparison
with
the
other
12
facilities
included
in
this
report.
Rohm
and
Haas
consistently
exhibited
characteristics
similar
to
those
facilities
assigned
to
the
medium
prioritization
grouping.
Although
the
potential
for
adverse
health
impacts
has
been
established,
Rohm
and
Haas
was
not
assigned
to
the
high
prioritization
grouping
based
on
the
lack
of
multiple
complicating
factors
characteristic
of
the
high
prioritization
grouping.
For
example,
although
the
closest
residential
exposure
scenarios
are
located
within
approximately
800
meters
from
the
facility
boundary,
when
compared
to
the
high
grouping
facilities,
the
number
of
emission
sources
and
volume
and
type
of
wastes
does
not
support
the
allocation
of
Rohm
and
Haas
into
the
high
prioritization
grouping.
Therefore,
based
on
a
review
of
site­
specific
characteristics
and
a
comparison
to
the
other
facilities
in
this
report,
it
has
been
determined
that
Rohm
and
Haas
is
best
represented
by
facilities
assigned
to
the
medium
priority
grouping
and
lacks
commonalities
or
similar
sitespecific
conditions
associated
with
facilities
assigned
to
the
low
and
high
priority
groupings.

As
discussed
in
Section
1.2,
placement
into
the
medium
prioritization
group
confirms
the
need
for
a
sitespecific
risk
assessment
since
facilities
in
this
grouping
have
an
increased
potential
to
contribute
to
adverse
impacts
to
human
health
and
the
environment.
Further,
consistent
with
the
findings
presented
in
the
Rohm
and
Haas
Qualitative
Risk
Check
Report
(
EPA
2001m),
a
site­
specific
quantitative
risk
assessment
at
the
Rohm
and
Haas
facility
is
recommended
to
provide
the
facility
and
permitting
authority
with
the
information
necessary
to
assess
potential
liabilities
and
ensure
the
protection
of
human
health
and
the
environment.

2.12.3
MACT­
Based
Facility
Prioritization
This
section
describes
the
process
and
findings
relative
to
assigning
Rohm
and
Haas
to
one
of
the
three
prioritization
groupings
based
on
the
MACT­
based
facility
prioritization
strategy.
The
following
prioritization
table
presents
the
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
Rohm
and
Haas
Qualitative
Risk
Check
Report
(
EPA
2001m).
In
addition,
the
table
also
identifies
which
facility­
specific
prioritization
group
the
Rohm
and
Haas
facility
was
assigned
to.
The
paragraph
following
the
prioritization
table
provides
the
basis
for
why
the
facility
was
assigned
to
a
specific
prioritization
grouping.
QUALITATIVE
RISK
CHECK
SUMMARY
REPORT
SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
127
QUALITATIVE
RISK
CHECK
SUMMARY
REPORT
SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
128
MACT­
BASED
FACILITY
PRIORITIZATION
TABLE
QUALITATIVE
GUIDING
FACTORS
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

Rohm
and
Haas
Louisville,
Kentucky
MACT­
Based
Prioritization
Grouping:
High
As
discussed
in
Section
1.1,
while
Phase
I
MACT
standards
do
not
apply
to
facilities
operating
hazardous
waste
fueled
boilers,
it
is
believed
that
the
development
of
future
Phase
II
MACT
standards,
which
will
apply
to
facilities
operating
boilers,
will
also
include
a
national
MACT
risk
assessment.
With
this
QUALITATIVE
RISK
CHECK
SUMMARY
REPORT
SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
129
assumption
in
mind,
it
is
also
believed
that
the
qualitative
guiding
factors
listed
in
section
1.0
and
the
known
limitations
of
the
Phase
I
national
MACT
risk
assessment
will
also
apply
to
boilers.
As
a
result,
the
same
criteria
for
evaluating
and
assigning
facilities
that
are
subject
to
Phase
I
MACT
standards
to
one
of
the
three
prioritization
groupings
utilizing
the
MACT­
based
facility
prioritization
strategy
are
also
applied
to
facilities
with
boilers.
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
table
above,
and
(
2)
consideration
of
how
each
qualitative
guiding
factor
interrelates
collectively,
Rohm
and
Haas
has
been
assigned
to
the
high
prioritization
group
utilizing
the
MACT­
based
prioritization
strategy.
In
addition,
when
compared
with
the
12
other
facilities
included
in
this
summary
report,
Rohm
and
Haas
clearly
exhibits
multiple
complicating
factors
that
individually
or
collectively
support
its
designation
in
the
high
prioritization
grouping.
This
designation
is
intended
to
heighten
the
awareness
of
several
key
factors
that
indicate
the
potential
for
remaining
adverse
risk
impacts
even
after
compliance
with
future
MACT
Standards.
Specifically,
the
decision
to
assign
Rohm
and
Haas
to
the
high
prioritization
grouping
is
supported
by
the
following
key
factors:


Presence
of
35
million
pounds
per
year
of
highly
variable
hazardous
waste
received
from
both
on­
and
off­
site
sources
known
or
permitted
to
contain
chemicals
not
expected
to
be
covered
under
future
MACT
standards
(
e.
g.,
non­
dioxin
PICs,
10
of
the
12
PBTs).
Since
future
MACT
limits
are
not
expected
to
apply
to
all
stack
emissions,
the
potential
for
adverse
health
impacts
from
these
emissions
exists.
In
comparison
with
the
lower
prioritization
groupings,
Rohm
and
Haas
exhibits
multiple
site­
specific
characteristics
and
complex
individual
and
additive
qualitative
guiding
factors
which
indicate
an
increased
potential
from
those
facilities
in
the
low
and
medium
groupings.


Presence
of
other
significant
on­
site
fugitive
emission
sources
(
e.
g.,
133,900
pounds
of
emissions
from
fugitive
sources
as
reported
in
1999
TRI
inventory).
Fugitive
emission
sources
were
not
evaluated
in
the
national
MACT
risk
assessment
conducted
to
support
development
of
current
Phase
I
MACT
Standards,
nor
are
they
expected
to
be
considered
in
the
national
MACT
risk
assessment
conducted
during
the
development
of
future
Phase
II
MACT
Standards.
The
presence
of
potentially
significant
amounts
of
fugitive
emissions
indicates
a
clear
increased
potential
for
adverse
impacts.
In
addition,
when
compared
with
facilities
assigned
to
the
lower
prioritization
groupings,
Rohm
and
Haas
is
capable
of
emitting
more
known
risk
drivers
as
fugitive
emissions
due
to
its
highly
variable
waste
feed
than
the
facilities
in
the
low
and
medium
groupings.


Utilizing
the
same
modeling
methodologies
presented
in
the
national
MACT
risk
assessment
for
selecting
the
appropriate
terrain
option
would
result
in
the
misclassification
of
terrain
in
the
Rohm
and
Haas
assessment
area.
This
mis­
classification
QUALITATIVE
RISK
CHECK
SUMMARY
REPORT
SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
130
increases
the
potential
that
the
concentration
and
deposition
will
be
underestimated
in
areas
with
increased
terrain.
Since
areas
with
increased
terrain
elevation
are
present
in
the
assessment
area
and
many
of
them
are
known
or
capable
of
supporting
the
default
exposure
pathways,
there
is
an
increased
potential
that
the
national
MACT
risk
assessment
that
is
expected
to
support
Phase
II
MACT
limits
underestimated
risk
in
these
areas.
As
a
result,
there
is
an
increased
potential
that
the
Phase
II
MACT
limits
will
result
in
higher
risk
estimates
than
originally
predicted.
Therefore,
protection
to
human
health
and
the
environment
under
the
Phase
II
MACT
standards
cannot
be
confirmed
without
the
introduction
of
additional
site­
specific
information
and
a
sitespecific
refinement
to
air
dispersion
modeling
methodologies,
which
were
not
included
in
the
national
MACT
risk
assessment
to
support
Phase
I
MACT
standards.


Particle
size
distributions
utilized
in
the
national
MACT
risk
assessment
to
support
Phase
I
MACT
standards
were
not
source­
specific,
but
were
generalized
based
on
combustion
unit
type.
As
stated
above,
it
is
assumed
that
the
national
MACT
risk
assessment
to
support
Phase
II
MACT
standards
will
utilize
the
same
methodologies
as
those
used
in
the
national
MACT
risk
assessment
to
support
Phase
I
MACT
standards.
Defining
particle
size
distribution
by
combustion
unit
type
introduces
significant
uncertainty,
thereby
resulting
in
the
inability
to
accurately
quantify
risk
impacts.
Due
to
this
potentially
significant
uncertainty,
protection
based
on
compliance
with
future
Phase
II
MACT
Limits
cannot
be
inferred
based
on
this
methodology,
but
will
require
additional
site­
specific
risk
assessment
activities,
including
introduction
of
representative
particle
size
distribution
data
collected
as
part
of
a
trial
burn
designed
to
support
a
site­
specific
risk
assessment.


The
national
MACT
risk
assessment
conducted
to
support
Phase
I
MACT
limits
did
not
include
an
evaluation
of
acute
exposure,
and
it
is
assumed
that
the
national
MACT
risk
assessment
to
support
Phase
II
MACT
standards
will
utilize
the
same
methodologies.
Since
actual
and
potential
acute
exposure
scenario
locations
are
located
in
close
proximity
to
the
facility,
no
definitive
conclusions
regarding
the
protectiveness
of
MACT
standards
can
be
made
without
additional
risk
assessment
activities.


Residential
exposure
scenario
locations
are
located
in
close
proximity
(
i.
e.,
within
800
meters)
to
the
Rohm
and
Haas
facility.
The
Phase
I
national
MACT
risk
assessment
utilized
16­
sector
based
grid
averaging.
Based
on
the
assumption
that
the
same
approach
will
be
utilized
in
future
MACT
risk
assessments,
this
approach,
when
applied
on
a
site­
specific
basis,
may
result
in
the
averaging
of
locally
elevated
media
concentrations
(
hotspots),
resulting
in
the
potential
underestimation
of
upper­
bound
risk
estimates
for
those
exposure
scenario
located
in
close
proximity
to
Rohm
and
Haas.
Due
to
this
potential
underestimation,
protection
based
on
compliance
with
future
Phase
II
MACT
limits
alone
cannot
be
inferred,
which
further
establishes
the
need
for
additional
risk
assessment
activities.


The
selection
of
representative
water
bodies
in
the
national
MACT
risk
assessment
to
support
Phase
I
MACT
limits
may
have
been
biased
to
meet
multiple
selection
criteria,
QUALITATIVE
RISK
CHECK
SUMMARY
REPORT
SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
131
resulting
in
the
potential
for
overlooking
more
heavily
impacted
water
bodies
and
their
associated
watersheds,
which
may
result
in
the
underestimation
of
risk
to
receptors.
Assuming
that
the
national
MACT
risk
assessment
expected
to
be
conducted
to
support
Phase
II
MACT
limits
will
follow
the
same
methodology,
protection
based
on
compliance
with
Phase
II
MACT
limits
alone
cannot
be
inferred,
which
further
establishes
the
need
for
additional
risk
assessment
activities.


Established
presence
of
significant
ecological
habitats
in
close
proximity
to
the
Rohm
and
Haas
facility
and
ecological
receptors,
including
threatened
or
endangered
species
(
e.
g.,
six
species
of
mussels).
The
national
MACT
Risk
Assessment
did
not
include
a
separate
analysis
or
consideration
of
threatened
or
endangered
species.
Based
on
the
assumption
that
future
MACT
risk
assessment
will
also
not
include
an
evaluation
of
threatened
or
endangered
species,
there
is
an
increased
potential
that
future
MACT
standards
may
not
ensure
protection
of
human
health
and
the
environment.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
Rohm
and
Haas
Qualitative
Risk
Check
Report
(
EPA
2001m).
Further
justification
for
assigning
Rohm
and
Haas
to
the
high
prioritization
group
is
based
on
the
fact
that
while
some
of
the
qualitative
guiding
factors
evaluated
for
this
facility
have
been
individually
assigned
to
the
medium
or
low
group,
these
individual
guiding
factors
alone
do
not
justify
demoting
the
facility
to
a
lower
prioritization
grouping.
Additionally,
the
site­
specific
characteristics
at
the
Rohm
and
Haas
facility
exhibits
the
complex
interplay
or
additive
relationships
between
guiding
factors
typically
found
in
the
facilities
assigned
to
the
high
prioritization
group.

Therefore,
based
on
a
review
of
site­
specific
characteristics
and
a
comparison
to
the
other
facilities
in
this
report,
it
has
been
determined
that,
for
the
MACT­
based
prioritization
grouping,
Rohm
and
Haas
is
best
represented
by
facilities
assigned
to
the
high
priority
grouping
and
exhibits
multiple
site­
specific
characteristics
that
clearly
indicate
an
increased
potential
for
adverse
health
impacts.

As
discussed
in
Section
1.2,
placement
into
the
high
prioritization
group
confirms
the
need
for
conducting
additional
site­
specific
risk
assessment
activities
at
the
Rohm
and
Haas
facility
in
order
to
quantify
risk
impacts
to
human
health
and
the
environment,
since
facilities
in
this
grouping
have
the
largest
potential
for
contributing
to
adverse
health
impacts.
Therefore,
consistent
with
the
Rohm
and
Haas
Qualitative
Risk
Check
Report
(
EPA
2001m),
additional
site­
specific
risk
assessment
activities
are
warranted
and
will
help
both
the
facility
and
permitting
authority
demonstrate
that
compliance
with
future
MACT
standards
meet
the
requirements
of
the
RCRA
omnibus
provisions.

2.13
TENNESSEE
EASTMAN
QUALITATIVE
RISK
CHECK
SUMMARY
REPORT
SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
132
This
section
presents
the
information
and
approach
used
in
assigning
Tennessee
Eastman
(
Eastman)
to
one
of
the
three
prioritization
groupings
based
on
(
1)
the
facility's
overall
potential
for
resulting
in
adverse
health
impacts
and
(
2)
an
assessment
of
the
protectiveness
of
current
or
future
MACT
standards
to
determine
if
additional
permit
limits
may
be
required
to
ensure
protection
of
human
health
and
the
environment.
Section
2.13.1
presents
facility­
specific
background
information
including
process
descriptions
and
permit
history.
Section
2.13.2
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
specific
to
the
risk­
based
facility
prioritization
strategy.
Section
2.13.3
describes
the
process
and
findings
used
to
assign
a
facility
to
one
of
the
three
prioritization
groupings
following
the
MACT­
based
facility
prioritization
strategy.
Specific
sources
of
information
used
to
evaluate
the
Eastman
facility
are
cited
and
referenced
at
the
end
of
this
report.

2.13.1
Facility
Information
The
following
summarizes
the
facility­
specific
information
provided
in
Section
2.2.1.1
of
the
Eastman
Qualitative
Risk
Check
Report
(
EPA
2001g).
This
information
is
intended
to
provide
a
general
facility
overview,
including
process
descriptions
and
permit
history.

Eastman
is
a
privately
owned
facility
that
manufactures
chemicals,
fibers,
and
plastics.
The
Eastman
facility
is
located
on
Eastman
Road,
about
3
kilometers
southeast
of
Kingsport
in
Sullivan
County,

Tennessee.
The
facility
is
situated
at
the
foothills
of
the
Appalachian
mountains
in
a
region
known
as
the
Tri­
Cities
Tennessee/
Virginia
region.
The
property
consists
of
approximately
1,000
acres
and
was
first
established
in
1920
to
produce
methanol
for
use
in
Kodak's
photographic
film
base
(
Eastman
2000).
The
facility
operates
an
on­
site
industrial
wastewater
treatment
system
(
IWWTS)
to
treat
wastewater
from
its
operations.
Eastman
also
operates
three
hazardous
waste
combustion
areas
consisting
of
eight
Boiler
and
Industrial
Furnace
(
BIF)
boilers,
two
rotary
kiln
incinerators
(
RKI),
and
one
liquid
chemical
destructor
(
LCD)
under
a
permit
issued
by
the
Tennessee
Hazardous
Waste
Management
Act
and
RCRA
(
Eastman
1999b).
Constructed
features
on
the
facility
property
include
(
1)
the
manufacturing
facility,
which
includes
the
boilers
and
incinerators;
(
2)
industrial
landfills;
(
3)
a
wastewater
treatment
plant;
and
(
4)
several
administrative
buildings.
QUALITATIVE
RISK
CHECK
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REPORT
SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
133
The
facility's
two
RKIs
and
its
LCD
are
subject
to
the
requirements
of
RCRA
promulgated
at
40
CFR
260
through
263,
265,
268,
and
270,
and
the
equivalent
Tennessee
Department
of
the
Environment
and
Conservation
(
TDEC)
state
regulations.
The
facility's
boilers
are
subject
to
the
BIF
Rule
requirements
of
RCRA
promulgated
at
40
CFR
266
Subpart
H
and
Part
268
Subpart
D
and
the
equivalent
TDEC
state
regulations.

Most
of
the
materials
managed
in
these
units
are
generated
on
site.
However,
small
quantities
of
hazardous
and
nonhazardous
wastes
may
be
received
from
off­
site
facilities
owned
or
operated
by
Eastman,

subsidiaries
of
Eastman,
or
product
distribution
sites
under
contract
to
Eastman
(
Eastman
1999b).
Waste
treated
in
the
RKIs
and
the
LCD
is
stored
in
one
of
four
storage
tanks
or
in
one
of
nine
container
storage
areas
prior
to
treatment.
The
container
storage
areas
include
four
trailer
pads
and
two
warehouse
areas
(
Eastman
1999b).
Waste
treated
in
the
boilers
is
not
stored
in
tanks,
but
in
containers
(
tank
trailers
and
dumpster
tanks)
designed
to
hold
waste
chemicals
(
Eastman
1998a).
These
trailers
and
dumpster
tanks
are
unloaded
on
one
of
two
unloading
pads
prior
to
treatment.

Eastman
operates
a
total
of
eight
on­
site
hazardous
waste
boilers
(
Eastman
1998a).
Boilers
18
through
24
are
stoker­
fed,
coal­
fired
boilers
with
a
steam
rating
of
196
to
476
million
British
thermal
units
per
hour
(
MMBtu/
hr)
(
Eastman
1998b,
c,
d).
Boilers
18
through
22
are
used
for
thermal
treatment
of
biosludge
from
the
on­
site
industrial
wastewater
treatment
system
(
IWWTS)
and
solid
wastes
(
in
pellet
and
powder
form).

The
biosludge
stream
consists
of
de­
watered
biological
solids
from
the
belt
filters
and
solids
from
the
grit
dewatering
system
of
the
IWWTS.
Boilers
23
and
24
are
used
for
thermal
treatment
of
biosludge,
solid
waste,
and
other
pumpable
liquid
waste
chemicals.
Flue
gas
from
all
seven
boilers
exhaust
through
three
interconnected,
225­
foot­
tall
stacks
(
Eastman
1998
b,
c,
d).
Boiler
30
is
a
pulverized
coal,
suspension­
fired
boiler
with
a
steam
rating
of
780
MMBtu/
hr
(
Eastman
1998e).
Boiler
30
is
used
for
thermal
treatment
of
pumpable
liquid
waste
chemicals
and
nonhazardous
process
gas
and
exhausts
through
a
dedicated,
375­

foot­
tall
stack.
Based
on
information
provided
by
EPA
Region
4,
Boiler
30
is
in
the
process
of
being
shut
down
(
EPA
2000a).

Eastman
also
operates
two
RKIs
and
one
LCD
(
Eastman
1999a).
The
RKIs
are
horizontal,
cylindrical,

refractory­
lined
chambers
with
a
"
nameplate"
design
capacity
of
40
to
50
MMBtu/
hr.
Both
hazardous
and
QUALITATIVE
RISK
CHECK
SUMMARY
REPORT
SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
134
nonhazardous
liquid
and
solid
wastes
are
treated
in
the
RKIs
at
temperatures
ranging
from
1,450
to
1,850
oF.
Uncombusted
kiln
gas
and
relatively
high
Btu
(>
5000
Btu/
pound)
waste
liquids
are
further
treated
in
the
combustion
system
at
temperatures
ranging
from
1,700
to
2,100
oF.
The
RKIs
are
equipped
with
an
induced
draft
(
ID)
fan,
which
exhausts
directly
to
a
shared,
200­
foot­
tall
by
10­
foot
inside
diameter
stack.

The
LCD
is
a
horizontal,
rectangular,
refractory­
lined
chamber
with
a
"
nameplate"
design
capacity
of
50
MM
Btu/
hr.
Both
hazardous
and
nonhazardous
wastes
are
treated
in
the
LCD
at
temperatures
ranging
from
1,650
to
2,100
oF.
The
LCD
is
equipped
with
an
ID
fan,
which
exhausts
directly
to
a
50­
foot­
tall
by
42.5­
inch
inside
diameter
stack.

Since
1980,
Eastman
has
been
operating
its
boilers
under
interim
status
as
defined
by
federal
regulations
governing
BIF
facilities
and
air
quality
operating
permits
issued
by
EPA
Region
4.
The
two
RKIs
and
the
LCD
were
originally
permitted
in
September
1989
(
Permit
No.
TNHW­
025).
Eastman
submitted
a
RCRA
Part
A
permit
application
in
August
1991.
In
September
1991,
Eastman
submitted
a
Certification
of
Compliance
for
Boilers
21
and
22.
Eastman
submitted
a
revised
Certification
of
Precompliance
for
Boilers
18,
19,
20,
23,
24,
and
30
in
December
1991.
In
March
1992,
Eastman
submitted
a
revised
Certification
of
Precompliance
for
Boilers
18,
19,
20,
23,
24,
and
30.
In
August
1992,
Eastman
submitted
a
Certification
of
Compliance
for
Boilers
18,
19,
20,
23,
24,
and
30.
In
December
1998,
Eastman
submitted
a
RCRA
Part
A
and
Part
B
permit
application,
a
trial
burn
plan,
and
a
risk
assessment
work
plan
to
EPA.

The
Part
B
permit
application
is
currently
under
review
by
EPA
Region
4
and
the
TDEC.

2.13.2
Risk
Based
Facility
Prioritization
This
section
describes
findings
relative
to
assigning
Eastman
to
one
of
the
three
prioritization
groupings
using
the
risk­
based
facility
prioritization
strategy.
Specifically,
the
following
prioritization
table
presents
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
Eastman
Qualitative
Risk
Check
Report
(
EPA
2001g).
In
addition,
the
table
also
identifies
which
prioritization
grouping
the
overall
facility
was
assigned
to
using
the
risk­
based
facility
prioritization
strategy.
The
paragraph
following
the
prioritization
table
provides
further
justification
supporting
why
the
facility
was
assigned
to
a
specific
prioritization
grouping.
QUALITATIVE
RISK
CHECK
SUMMARY
REPORT
SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
135
OVERALL
RISK­
BASED
FACILITY
PRIORITIZATION
QUALITATIVE
GUIDING
FACTOR
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

Eastman
Kingsport,
Tennessee
Risk­
based
Prioritization
Grouping:
High
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
above
table,
and
(
2)
consideration
of
how
each
qualitative
guiding
factor
interrelates
collectively,

Eastman
has
been
assigned
to
the
high
prioritization
grouping
utilizing
the
overall­
risk
based
prioritization
strategy.
The
high
designation
is
intended
to
heighten
the
awareness
of
several
key
factors
that
indicate
an
QUALITATIVE
RISK
CHECK
SUMMARY
REPORT
SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
136
increased
potential
for
adverse
impacts
to
human
health
and
the
environment.
In
addition,
when
compared
with
the
12
other
facilities
included
in
this
summary
report,
Eastman
clearly
exhibits
multiple
complicating
factors
that
individually
or
collectively
support
its
designation
to
the
high
prioritization
grouping.

Specifically,
the
decision
to
assign
Eastman
to
the
medium
prioritization
grouping
is
supported
by
the
following
key
factors:


Presence
of
three
on­
site
incinerators
and
eight
boilers.
In
comparison,
facilities
assigned
to
the
low
prioritization
grouping
typically
only
operate
a
single
hazardous
waste
combustor.


Presence
of
highly
variable
hazardous
waste
received
mainly
from
off­
site
sources.
In
comparison,
facilities
assigned
to
the
lower
prioritization
groupings
typically
treat
well
or
moderately
characterized
waste.


Eastman
treats
an
estimated
40,000
tons
of
hazardous
wastes
in
its
boilers,
RKIs,
and
LCD
annually.
These
wastes
are
known
or
permitted
to
contain
toxic
and
bioaccumulative
compounds,
including
known
PBTs
and
common
risk
drivers.
In
comparison,
facilities
assigned
to
the
lower
prioritization
groupings
typically
treat
significantly
less
waste,
which
does
not
contain
known
PBTs
or
common
risk
drivers.


Eastman
has
not
performed
a
trial
burn
designed
to
support
a
site­
specific
risk
assessment;
therefore,
information
on
actual
stack
emission
is
limited.


Presence
and
proximity
of
residential,
farmer,
fisher,
and
acute
exposure
scenarios.
Specifically,
the
closest
residential
exposure
scenario
is
located
within
1
kilometer
from
the
facility
boundary.


The
risk
assessment
work
plan
indicates
that
no
on­
site
modeling
will
be
performed.
Due
to
the
large
size
of
the
Eastman
Facility
property
(
i.
e.,
over
1,000
acres)
this
issue
may
be
significant,
since
potential
on­
site
receptors
(
e.
g.,
ecological,
grazing,
etc.)
would
be
overlooked
due
to
a
lack
of
air
dispersion
modeling
data.
In
addition,
due
to
the
size
of
the
Eastman
property,
there
is
an
increased
likelihood
that
maximum
concentration
and
deposition
will
occur
within
the
facility
boundary.


Presence
and
proximity
of
numerous
water
bodies
and
their
associated
watersheds
within
3
kilometers
from
the
facility
boundary.


Presence
of
over
60
threatened
or
endangered
species.
It
should
be
noted;
however,
that
their
presence
within
close
proximity
or
within
the
facility
boundary
has
not
been
confirmed.


Potentially
significant
public
concerns
are
documented
in
association
with
the
facility.
In
comparison,
facilities
assigned
to
the
low
prioritization
grouping
typically
do
not
have
QUALITATIVE
RISK
CHECK
SUMMARY
REPORT
SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
137
documented,
significant
public
concerns.
For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
Eastman
Qualitative
Risk
Check
Report
(
EPA
2001g).
Further
justification
for
assigning
Eastman
to
the
high
prioritization
grouping
is
based
on
the
relationship
or
complex
interplay
associated
with
many
of
the
qualitative
guiding
factors
individually
assigned
to
the
medium
and
high
prioritization
grouping.
For
example,
Eastman
treats
a
large
quantity
of
highly
variable
wastes
in
one
of
three
on­
site
incinerators
and
eight
boilers.
The
waste
feed
is
also
known
or
permitted
to
contain
RCRA
D­,
F­,
and
U­
listed
wastes,
which
may
include
toxic
and
bioaccumulative
compounds
including
known
PBTs.
The
potential
for
adverse
health
impacts
is
further
increased
by
the
close
proximity
(
i.
e.,
within
1
kilometer)
of
existing
exposure
scenario
locations.
Other
complicating
factors
include
the
presence
of
ecological
areas
known
or
anticipated
to
support
threatened
or
endangered
species
and
documented
public
concerns.
When
these
factors
are
considered
collectively,
the
potential
for
adverse
health
impacts
associated
with
Eastman
emissions
is
increased,
especially
when
compared
with
the
12
other
facilities
included
in
this
summary
report.
For
these
reasons,
Eastman
was
assigned
to
the
high
prioritization
grouping
to
increase
the
awareness
of
the
issues
discussed
above
and
to
help
the
facility
and
permitting
authority
allocate
and
prioritize
their
resources
in
order
to
efficiently
address
any
potential
liabilities
and
provide
quantitative
results
supporting
conclusions
regarding
potential
impacts,
if
any,
to
human
health
and
the
environment.
Therefore,
based
on
a
review
of
site­
specific
characteristics
and
a
comparison
to
the
other
facilities
in
this
report,
it
has
been
determined
that
Eastman
is
best
represented
by
facilities
assigned
to
the
high
priority
grouping
and
lacks
commonalities
or
similar
sitespecific
conditions
associated
with
facilities
assigned
to
the
low
and
high
priority
groupings.

As
discussed
in
Section
1.2,
placement
into
the
high
prioritization
group
confirms
the
need
for
conducting
additional
site­
specific
risk
assessment
activities
at
the
Eastman
facility
in
order
to
quantify
risk
impacts
to
human
health
and
the
environment,
since
facilities
in
this
grouping
have
the
largest
potential
for
contributing
to
adverse
health
impacts.
Therefore,
consistent
with
the
Eastman
Qualitative
Risk
Check
Report
(
EPA
2001g),
additional
site­
specific
risk
assessment
activities
are
warranted
and
will
help
both
the
facility
and
permitting
authority
demonstrate
that
the
Eastman
facility
meets
the
requirements
of
the
RCRA
omnibus
provisions.
QUALITATIVE
RISK
CHECK
SUMMARY
REPORT
SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
138
2.13.3
MACT
Based
Facility
Prioritization
This
section
describes
the
process
and
findings
relative
to
assigning
Eastman
to
one
of
the
three
prioritization
groupings
based
on
the
MACT­
based
facility
prioritization
strategy.
The
following
prioritization
table
presents
the
results
for
the
individual
qualitative
guiding
factors
evaluated
in
the
Eastman
Qualitative
Risk
Check
Report
(
EPA
2001g).
In
addition,
the
table
also
identifies
which
facilityspecific
prioritization
group
the
Eastman
facility
was
assigned
to.
The
paragraph
following
the
prioritization
table
provides
the
basis
for
why
the
facility
was
assigned
to
its
specific
prioritization
grouping.
QUALITATIVE
RISK
CHECK
SUMMARY
REPORT
SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
139
MACT­
BASED
FACILITY
PRIORITIZATION
TABLE
QUALITATIVE
GUIDING
FACTORS
PRIORITIZATION
GROUPING
Low
Medium
High
Section
2.2.1.2
 
Volumes
and
Types
of
Waste
Being
Burned

Section
2.2.1.3
 
Emissions
Quantification

Section
2.2.2
 
Other
On­
site
and
Off­
site
Emission
Sources

Section
3.2.1.1
 
Terrain
Characteristics

Section
3.2.1.2
 
Land
Use
for
Dispersion
Coefficients
and
Surface
Roughness

Section
3.2.1.3
 
Building
Wake
Effects

Section
3.2.1.4
 
Particle
Size
Distribution

Section
3.2.1.5
 
Meteorological
Conditions

Section
3.2.1.6
 
Physical
Source
Parameters

Section
3.2.1.7
 
(
Receptor)
Grid
Node
Array

Section
4.2.1
 
Type
of
Receptors
and
Exposure
Scenario(
s)

Section
4.2.2
 
Proximity
to
Exposure
Scenario
Location

Section
4.2.3
 
Presence
or
Absence
and
Proximity
of
Water
Bodies
and
Water
Sheds

Section
4.2.4
 
Proximity
to
Special
Subpopulations

Section
4.2.5
 
Presence
or
Absence
and
Proximity
of
Ecological
Areas

Section
4.2.6
 
Public
Concerns

Eastman
Kingsport,
Tennessee
MACT­
based
Prioritization
Grouping:
High
As
discussed
in
Section
1.1,
while
Phase
I
MACT
standards
do
not
apply
to
facilities
operating
hazardous
waste
fueled
boilers,
it
is
believed
that
development
of
future
Phase
II
MACT
standards,
which
will
apply
to
facilities
operating
boilers,
will
also
include
a
national
MACT
risk
assessment.
With
this
assumption
in
mind,
it
is
also
believed
that
the
qualitative
guiding
factors
listed
in
section
1.0
and
the
known
limitations
of
QUALITATIVE
RISK
CHECK
SUMMARY
REPORT
SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
140
the
Phase
I
national
MACT
risk
assessment
will
also
apply
to
boilers.
As
a
result,
the
same
criteria
for
evaluating
and
assigning
facilities
that
are
subject
to
Phase
I
MACT
standards
to
one
of
the
three
prioritization
groupings
utilizing
the
MACT­
based
facility
prioritization
strategy
are
also
applied
to
facilities
with
boilers.
Based
on
(
1)
a
review
of
the
individual
qualitative
guiding
factors
and
their
associated
groupings
presented
in
the
table
above,
and
(
2)
consideration
of
how
each
qualitative
guiding
factor
interrelates
collectively,
Eastman
has
been
assigned
to
the
high
prioritization
grouping
utilizing
the
MACT­
based
prioritization
strategy.
In
addition,
when
compared
with
the
12
other
facilities
included
in
this
summary
report,
Eastman
clearly
exhibits
multiple
complicating
factors
that
individually
and
collectively
support
its
designation
in
the
high
prioritization
grouping.
This
designation
is
intended
to
heighten
the
awareness
of
several
key
factors
that
indicate
the
potential
for
remaining
adverse
risk
impacts
even
after
compliance
with
future
MACT
Standards.
Specifically,
the
decision
to
assign
Eastman
into
the
high
prioritization
grouping
is
supported
by
the
following
key
factors:


Presence
of
80
million
pounds
per
year
of
highly
variable
hazardous
waste
received
primarily
from
off­
site
sources
that
are
known
or
permitted
to
contain
chemicals
not
expected
to
be
covered
under
MACT
standards
(
e.
g.,
non­
dioxin
PICs,
10
of
the
12
PBTs,
and
other
toxic
metals).
Since
current
MACT
limits
do
not
apply
to
all
stack
emissions
(
and
future
MACT
limits
are
not
expected
to
apply),
the
potential
for
adverse
health
impacts
from
these
emissions
exists.
In
comparison
with
the
lower
prioritization
groupings,
Eastman
exhibits
multiple
site­
specific
characteristics
and
complex
individual
and
additive
qualitative
guiding
factors
that
indicate
an
increased
potential
from
those
facilities
in
the
low
and
medium
groupings.


Presence
of
other
significant
on­
site
fugitive
emission
sources
(
e.
g.,
980,000
pounds
of
emissions
from
fugitive
sources
as
reported
in
1999
TRI
inventory).
Fugitive
emission
sources
were
not
evaluated
in
the
national
MACT
risk
assessment
conducted
to
support
development
of
current
Phase
I
MACT
Standards,
nor
are
they
expected
to
be
considered
during
in
the
national
MACT
risk
assessment
conducted
during
development
of
future
Phase
II
MACT
Standards.
The
presence
of
potentially
significant
amounts
of
fugitive
emissions
indicates
a
clear
increased
potential
for
adverse
impacts.
In
addition,
when
compared
with
facilities
ed
to
the
lower
prioritization
groupings,
Eastman
is
capable
of
emitting
more
known
risk
drivers
as
fugitive
emissions
due
to
its
highly
variable
waste
feed
than
the
facilities
in
the
low
and
medium
groupings.


Utilizing
the
same
modeling
methodologies
presented
in
the
national
MACT
risk
assessment
for
selecting
the
appropriate
terrain
option
would
result
in
the
misclassification
of
terrain
in
the
Eastman
assessment
area.
This
mis­
classification
increases
the
potential
that
concentration
and
deposition
will
be
underestimated
in
QUALITATIVE
RISK
CHECK
SUMMARY
REPORT
SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
141
areas
with
increased
terrain.
This
issue
is
especially
important
in
the
Eastman
assessment
area
since
many
exposure
scenario
locations
are
located
in
areas
of
increased
terrain.
Since
areas
with
increased
terrain
elevation
are
present
in
the
assessment
area,
and
many
of
them
are
known
or
capable
of
supporting
the
default
exposure
pathways,
there
is
an
increased
potential
that
the
national
MACT
risk
assessment
that
supported
Phase
I
MACT
limits
underestimated
risk
in
these
areas.
As
a
result,
there
is
an
increased
potential
that
the
Phase
I
and
Phase
II
MACT
limits
will
result
in
higher
risk
estimates
than
originally
predicted.
Therefore,
protection
of
human
health
and
the
environment
under
the
Phase
I
and
Phase
II
MACT
standards
cannot
be
confirmed
without
introducing
of
additional
site­
specific
information
and
a
site­
specific
refinement
to
air
dispersion
modeling
methodologies.


Particle
size
distributions
utilized
in
the
national
MACT
risk
assessment
to
support
Phase
I
MACT
standards
were
not
source­
specific,
but
were
generalized
based
on
combustion
unit
type.
As
stated
above,
it
is
assumed
that
the
national
MACT
risk
assessment
to
support
Phase
II
MACT
standards
will
utilize
the
same
methodologies
as
those
used
in
the
national
MACT
risk
assessment
to
support
Phase
I
MACT
standards.
Defining
particle
size
distribution
by
combustion
unit
type
introduces
significant
uncertainty,
thereby
resulting
in
the
inability
to
accurately
quantify
risk
impacts.
Due
to
this
potentially
significant
uncertainty,
protection
based
on
compliance
with
current
and
future
MACT
Limits
cannot
be
inferred
based
on
this
methodology,
but
will
require
additional
site­
specific
risk
assessment
activities,
including
introduction
of
representative
particle
size
distribution
data
collected
as
part
of
a
trial
burn
designed
to
support
a
site­
specific
risk
assessment.


The
national
MACT
risk
assessment
conducted
to
support
Phase
I
MACT
limits
did
not
include
an
evaluation
of
acute
exposure,
and
it
is
assumed
that
the
national
MACT
risk
assessment
to
support
Phase
II
MACT
standards
will
utilize
the
same
methodologies.
Since
actual
and
potential
acute
exposure
scenario
locations
are
located
in
close
proximity
to
the
facility,
no
definitive
conclusions
regarding
the
protectiveness
of
MACT
standards
can
be
made
without
additional
risk
assessment
activities.


Residential
exposure
scenario
locations
are
located
in
close
proximity
(
i.
e.,
within
1
kilometer)
to
the
Eastman
facility.
The
Phase
I
national
MACT
risk
assessment
utilized
16­
sector
based
grid
averaging.
Based
on
the
assumption
that
the
same
approach
will
be
utilized
in
future
MACT
risk
assessments,
this
approach
(
when
applied
on
a
sitespecific
basis)
may
result
in
the
averaging
of
locally
elevated
media
concentrations
(
hotspots),
resulting
in
the
potential
underestimation
of
upper­
bound
risk
estimates
for
those
exposure
scenarios
located
in
close
proximity
to
Eastman.
Due
to
this
potential
underestimation,
protection
based
on
compliance
with
current
and
future
MACT
limits
alone
cannot
be
inferred,
which
further
establishes
the
need
for
additional
risk
assessment
activities.
QUALITATIVE
RISK
CHECK
SUMMARY
REPORT
SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
142

The
selection
of
representative
water
bodies
in
the
national
MACT
risk
assessment
to
support
Phase
I
MACT
limits
may
have
been
biased
to
meet
multiple
selection
criteria,
resulting
in
the
potential
to
overlook
more
heavily
impacted
water
bodies
and
their
associated
watersheds,
which
may
result
in
the
underestimation
of
risk
to
receptors.
Assuming
that
the
national
MACT
risk
assessment
expected
to
be
conducted
to
support
Phase
II
MACT
limits
will
follow
the
same
methodology,
protection
based
on
compliance
with
current
and
future
MACT
limits
alone
cannot
be
inferred,
which
further
establishes
the
need
for
additional
risk
assessment
activities.


Established
presence
of
significant
ecological
habitats
in
close
proximity
to
the
Eastman
facility
and
ecological
receptors,
including
over
60
threatened
or
endangered
species.
The
national
MACT
risk
assessment
did
not
include
a
separate
analysis
or
consideration
of
threatened
or
endangered
species.
Based
on
the
assumption
that
future
MACT
risk
assessment
will
also
not
include
an
evaluation
of
threatened
or
endangered
species,
there
is
an
increased
potential
that
current
and
future
MACT
standards
may
not
ensure
protection
of
human
health
and
the
environment.

For
a
detailed
discussion
on
site­
specific
qualitative
guiding
factors,
refer
to
the
Eastman
Qualitative
Risk
Check
Report
(
EPA
2001g).
Further
justification
for
assigning
Eastman
to
the
high
prioritization
group
is
based
on
the
fact
that
while
some
of
the
qualitative
guiding
factors
evaluated
for
this
facility
have
been
individually
assigned
to
the
medium
or
low
group,
these
individual
guiding
factors
alone
do
not
justify
demoting
the
facility
to
a
lower
prioritization
grouping.
Additionally,
the
site­
specific
characteristics
at
the
Eastman
facility
exhibits
the
complex
interplay
or
additive
relationships
between
guiding
factors
typically
found
in
the
facilities
assigned
to
the
high
prioritization
group.
Therefore,
based
on
a
review
of
sitespecific
characteristics
and
a
comparison
to
the
other
facilities
in
this
report,
it
has
been
determined
that,

for
the
MACT­
based
prioritization
grouping,
Eastman
is
best
represented
by
facilities
assigned
to
the
high
priority
grouping
and
exhibits
multiple
site­
specific
characteristics
that
clearly
indicate
an
increased
potential
for
adverse
health
impacts.

As
discussed
in
Section
1.2,
placement
into
the
high
prioritization
group
confirms
the
need
for
conducting
additional
site­
specific
risk
assessment
activities
at
the
Eastman
facility
in
order
to
quantify
risk
impacts
to
human
health
and
the
environment
since
facilities
in
this
grouping
have
the
largest
potential
for
contributing
to
adverse
health
impacts.
Therefore,
consistent
with
the
Eastman
Qualitative
Risk
Check
Report
(
EPA
2001g),
additional
site­
specific
risk
assessment
activities
are
warranted
and
will
help
both
the
facility
and
permitting
authority
demonstrate
that
compliance
with
current
and
future
MACT
standards
meet
the
requirements
of
the
RCRA
omnibus
provisions.
QUALITATIVE
RISK
CHECK
SUMMARY
REPORT
SEPTEMBER
2001
FACILITY
PRIORITIZATION
GROUPING
143
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and
Environmental
Control.
October.

EPA.
2000.
Personal
correspondence
between
Tim
Jarosch,
Project
Manager,
Tetra
Tech
EM
Inc.
and
EPA
Region
4.
November
28.

EPA.
2001a.
LWD,
Inc.
Qualitative
Risk
Check
Report.
February
21.

EPA.
2001b.
Catalytica
Pharmaceuticals,
Inc.
Qualitative
Risk
Check
Report.
April
2.

EPA.
2001c.
First
Chemical
Corporation
Qualitative
Risk
Check
Report.
April
17.

EPA.
2001d.
Giant
Cement
Company
Qualitative
Risk
Check
Report.
May
22.

EPA.
2001e.
Monsanto
Company
Qualitative
Risk
Check
Report.
June
5.

EPA.
2001f.
Mallinckrodt
Chemical
Company
Qualitative
Risk
Check
Report.
June
14.

EPA.
2001g.
Tennessee
Eastman
Qualitative
Risk
Check
Report.
June
15.

EPA.
2001h.
Diversified
Scientific
Services,
Inc.
Qualitative
Risk
Check
Report.
June
21.

EPA.
2001i.
Albemarle
Corporation
Qualitative
Risk
Check
Report.
June
22.

EPA.
2001j.
DSM
Chemicals
North
America,
Inc.
Qualitative
Risk
Check
Report.
June
25.

EPA.
2001k.
3V,
Inc.
Qualitative
Risk
Check
Report.
June
27.

EPA.
2001l.
GlaxoSmithKline,
Inc.
Qualitative
Risk
Check
Report.
June
27.

EPA.
2001m.
Rohm
and
Haas
Company
Qualitative
Risk
Check
Report.
June
29.
