INITIAL REVIEW ENGINEERING REPORT PMN: 14-0364

Focus Ready Draft 3 / 17 / 2014

PV (kg / yr): 9,999 ENGINEER: Austin \ AFD

SUBMITTER: Ethox Chemicals, LLC USE: Polymerizable emulsifier for manufacturing emulsion polymers and alkyd resins, and a pigment dispersant for waterborne and solventborne paints (95%); chemical intermediate to prepare anionic dispersants (5%). The propenyl group increases the binding of th e substance to the polymers and dispersed. Synthetic sequence: P-14-364 -> 68. All analogs are for the same
uses.

OTHER USES: None found.

MSDS: No L abel: No

TLV / PEL: none established.

CRSS (03 / 06 / 2014): Chemical Name: Phenol, styrenated, reaction products with polyethylene glycol and 2-[(2-propen-1-yloxy)methyl]oxirane S-H20: Dispersible g / L @

Physical State and Misc CRSS Info: MW: 1093.00 0.69%<500 16.98%<1000 VP: 1.0E-6 torr @

Neat: Liquid Mfg: Liquid Proc/Form: Dispersion: PMN substance in aqeuous monomer emulsion; NA End Use: Destroyed; Destroyed. The structure as drawn is representative. The submitter states that the number of styrene units on the phenol is 1-3, the number of allylic moieties is ca. 1, and the number of ethylene oxide units ranges from 5-45. The mole ratios of feedstocks is ca. 1/1/15 for the typical di-styrenated phenol/allyl glycidyl ether/ethylene oxide; this ratio yields a calculated MW of 1077. MW NAVG = 1093 w ith 0.69% < 500 and 16.98% < 1000, by GPC. Submitted Data: Liquid; density = 1.1098; pH = 10.3 (5% conc.); hydroxyl value = 58.84 mg KOH/g (yields a calculated MW of 953 g/mole). A FTIR spectrum is provided. Estimated Data: BP > 500°C (High MW); VP < 0.000001 torr (High MW); dispersible in water (structure and use). Cont'd on 6.

Consumer Use: No SAT (concerns) (03 / 07 / 2014):

Analogs: L-97-270 = L-95-159, P-97-48 = P-96-1252. Related Cases and Misc SAT Info:
Migration to groundwater: Slow PBT rating: P1B1T1 Health: 2 Inhalation Eco: 2 Water (All releases to water with a CC = 170 ppb)INITIAL REVIEW ENGINEERING REPORT PMN: 14-0364 MFG:Batch

Ethox Chemicals, LLC Greenville SC 29605 Number of Sites / Location: 1

Days / yr: 2

Basis: Submission states that 4500 kg/batch of the PMN (100%, liquid) is manufactured at the submitter site. CS calculates 2 batches/year (consistent with submission).

Process Description: Reactants are charged into reactor --> PMN formed in ethoxylation reaction --> Loaded into drums (per submission)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources to the same medium.

Water Conservative: 10.0E+1 kg / site

- d ay over 2 days / yr from 1 site or 2.0E+2 kg/site-yr from 1 site or 2.0E+2 kg/yr-all sites to: On-site WWT --> POTW (per technical). from: Equipment Cleaning Losses of Liquids from Multiple Vessels basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual. Submitter does not provide release estimates for equipment cleaning. Technical contact indicates wastes sent to onsite WWT (biological treatment) before being sent to POTW.

RELEASE TOTAL 2.0E+2 kg / yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 0 Basis:Inhalation:
negligible (VP < 0.001 torr)

Dermal:
None required, per SAT.INITIAL REVIEW ENGINEERING REPORT PMN: 14-0364 USE 1: Site-Limited Intermediate (5%)

Ethox Chemicals, LLC Greenville SC 29605 Number of Sites / Location: 1

Days / yr: 2

Basis: Submission states that 5% o f the PV is used as a site- l imited chemical intermediate. CEB calculates 225 kg/batch by multiplying the MFG PV of 4,500 kg/batch by 0.05. CS calculates 2 batches/year.

Process Description:

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources to the same medium.

Water High End: 7.5E+0 kg / site- d ay over 2 days / yr from 1 site or 1.5E+1 kg/site-yr from 1 site or 1.5E+1 kg/yr-all sites to: Water (per submission) from: Cleaning Liquid Residuals from Containers Used to Transport the Raw Material basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. CEB assesses container cleaning to water (per submission).

RELEASE TOTAL 1.5E+1 kg / yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 3 Basis: Submission does not indicate how many workers exposed during the USE operation, CEB assesses for 3 workers/site.Inhalation:
negligible (VP < 0.001 torr)

Dermal:
None required, per SAT.

Exposure to Liquid at 100.00% concentration High End: > Potential Dose Rate: 2.2E+3 mg / day over 2 days / yr > Lifetime Average Daily Dose: 1.0E

- 1 mg / day over 2 days / yr > Average Daily Dose: 1.8E

- 1 mg / day over 2 days / yr > Acute Potential Dose: 3.2E+1 mg / day over 2 days / yr Number of workers (all sites) with dermal exposure: 3 Basis: Unloading Liquid Raw Material from Containers; EPA/OPPT 2

- H and Dermal Contact with Liquids Model.INITIAL REVIEW ENGINEERING REPORT PMN: 14-0364 PROC 2: Formulation of Waterborne Paints (47.5%)

unknown site(s) Number of Sites / Location: 1

Days / yr: 250

Basis: The Waterborne Coatings GS was referenced for the number of sites (rounded to 1), batches/year (250 days/year), and %PMN in product (5%, liquid). Nsites = (4500 kg/batch)/((2.7x10^6)*(0.05)) = 0.033 = 1 site. CS calculates 37.9962 kg/site-batch.

Process Description: Raw materials unloaded (100%, liquid) -- > Mixed -->Grinded --> Blended --> Filtered -- > Packaged (liquid, 35%) (per 2013 GS for Waterborne Coatings)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARYWater or Incineration or Landfill High End: 5.7E-1 kg / site- d ay over 250 days / yr from 1 site or 1.4E+2 kg/site-yr from 1 site or 1.4E+2 kg/yr

- a ll sites to: uncertain (per ESD) from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. 2013 Waterborne Coatings indicates container cleaning waste to water, incineration, or landfill.

Water or Incineration or Landfill Conservative: 3.8E-1 kg / site

- d ay over 250 days / yr from 1 site or 9.5E+1 kg/site-yr from 1 site or 9.5E+1 kg/yr-all sites to: uncertain (per ESD) from: Equipment Cleaning Losses of Liquids from Multiple Vessels basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual. 2013 Waterborne Coatings indicates equipment cleaning waste to water, incineration, or landfill.

Incineration or Landfill Output 2: 3.8E-3 kg / site- d ay over 250 days / yr from 1 site or 9.5E-1 kg/site-yr from 1 site or 9.5E

- 1 kg/yr

- a ll sites to: Incineration or Landfill (per ESD) from: Filter Media Changeout basis: User-Defined Loss Rate Model. 2013 Waterborne Coatings indicates filter waste to incineration, or landfill.

RELEASE TOTAL 2.4E+2 kg / yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 0 Basis:Inhalation:
negligible (VP < 0.001 torr)

Dermal:
None required, per SAT.INITIAL REVIEW ENGINEERING REPORT PMN: 14-0364 USE 2: Automotive Refinishing Spray Coating (non

- v olatile liquid) Number of Sites / Location: 241

Days / yr: 250

Basis: The June 2010 Emission Scenario Document (ESD) on Coating Application via Spray Painting in the Automobile Refinishing Industry provides default values of 250 operating days/year; 1.58 kg coating containing chemical of interest/site- d ay; and 5% PMN in coating product (per ESD).

Process Description: Unload coating product containing the assessed chemical from shipping container (liquid, 5% PMN) - > Mix and/or store (optional) -> Transfer to spray gun feed system (liquid, 5%) - > Apply coating to automobile surfaces (some sprayed coating does not remain on the surfaces - it passes into the booth ventilation system and is either captured in exhaust controls or is exhausted into the air through the stack) -> Bake/cure coating at high temperatures (assessed chemical is destroyed or fixed to the coated surface) (per ESD).

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources to the same medium. Per the ESD on Coating Application via Spray Painting in the Automotive Refinishing Industry, EPA assumes a solvent- b ased coating unless the chemical use information specifically state s that it is to be used in a waterborne coating formulation.Air Typical: 1.1E-3 kg / site-day over 250 days / yr from 241 sites or 2.8E-1 kg/site-yr from 241 sites or 6.7E+1 kg/yr

- all sites Worst Case: 2.5E-3 kg / site

- d ay over 250 days / yr from 241 sites or 6.3E-1 kg/site-yr from 241 sites or 1.5E+2 kg/yr-all sites to: Air (4%), Incineration or Landfill (96%) (per ESD). from: Spray Coating basis: EPA/OPPT Automobile Refinish Coating Overspray Loss Model (non-volatiles). Per the ESD on Coating Applicati o n via Spray Painting in the Automotive Refinishing Industry, EPA recommends that the range in spray gun transfer efficiencies be used to estimate typical (65% for HVLP spray guns) and worst-case (20% for conventional spray guns) releases from automotive refinishing spray applications. The oversprayed coating, in the form of a mist, either settles to the floor and walls of the spray booth or other workspace where spraying occurs or is captured by the ventilation system; most spray booths and prep stations use a dry filter to capture coating mist and dust from the exhaust prior to the final emission. The oversprayed coating particles that are captured by the controls are disposed to either incineration or landfill (per ESD). EPA recommends assuming that shops use a dry filter with an average capture efficiency of 96%; the remaining 4% is released to air.

Incineration or Landfill High End: 1.1E-3 kg / site- d ay over 104 days / yr from 241 sites or 1.2E-1 kg/site-yr from 241 sites or 2.8E+1 kg/yr-all sites to: Incineration or Landfill (per ESD) from: Cleaning Liquid Residuals from Small Containers Used to Transport the Raw Material basis: EPA/OPPT Small Container Residual Model, CEB standard 0.6% residual. Per the ESD on Coating Application via Spray Painting in the Automotive Refinishing Industry, EPA suggests using a default container size of 1-gallon cans in the absence of site-specific information; therefore, the EPA/OPPT Small Container Residual Model may be used to estimate this release. The media of re l ease for this source is uncertain; in these cases, EPA assumes that disposal may be to landfill or incineration. If the chemical is used in a waterborne coating product, EPA recommends assuming that the containers are rinsed with water, which is subsequently discharged from the shop (i.e., waterborne coating product container residues disposed to water). Per ESD, solvent- b ased coatings should be used as default unless the chemical use information specifically states PMN use in waterborne coating formulations; therefore, CEB assesses this release to incineration or landfill.

Incineration or LandfillConservative: 1.6E-3 kg / site

- d ay over 250 days / yr from 241 sites or 4.0E-1 kg/site-yr from 241 sites or 9.5E+1 kg/yr-all sites to: Incineration or Landfill (per ESD) from: Equipment Cleaning Losses of Liquids from Multiple Vessels basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual. Per the ESD on Coating Application via Spray Painting in the Automotive Refinishing Industry, the amount of residual coating product remaining in the spray coating equipment (e.g., mixing cup and spray gun) may be estimated using the EPA/OPPT Multiple Process Vessel Residual Model; this model assumes that no more than two percent of the daily amount of coating product that is mixed and transferred into the spray gun remains in the mixing equipment and spray gun as residue that is disposed as equipment cleaning waste. EPA suggests that these residues may be disposed to inciner a tion or landfill. If the chemical of interest is used in a waterborne coating product, EPA recommends assuming that the equipment is rinsed with water, which is subsequently discharged from the shop (i.e., waterborne coating product container residues disposed to water). Per ESD, solvent- b ased coatings should be used as default unless the chemical use information specifically states PMN use in waterborne coating formulations; therefore, CEB assesses this release to incineration or landfill.

Incineration or Landfill Typical: 2.7E-2 kg / site-day over 250 days / yr from 241 sites or 6.6E+0 kg/site-yr from 241 sites or 1.6E+3 kg/yr-all sites Worst Case: 6.1E-2 kg / site

- d ay over 250 days / yr from 241 sites or 1.5E+1 kg/site-yr from 241 sites or 3.7E+3 kg/yr-all sites to: Air (4%), Incineration or Landfill (96%) (per ESD). from: Spray Coating basis: EPA/OPPT Automobile Refinish Coating Overspray Loss Model (non-volatiles). Per the ESD on Coating Application via Spray Painting in the Automotive Refinishing Industry, EPA recommends that the range in spray gun transfer efficiencies be used to estimate typical (65% for HVLP spray guns) and worst-case (20% for conventional spray guns) releases from automotive refinishing spray applications. The oversprayed coating, in the form of a mist, either settles to the floor and walls of the spray booth or other workspace where spraying occurs or is captured by the ventilation system; most spray booths and prep stations use a dry filter to capture coating mist and dust from the exhaust prior to the final emission. The oversprayed coating particles that are captured by the controls are disposed to either incineration or landfill (per ESD). EPA recommends assuming that shops use a dry filter with an average capture efficiency of 96%; the remaining 4% is released to air.

RELEASE TOTAL3.9E+3 kg / yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 3,856 Basis: The ESD on Coating Application via Spray Painting in the Automotive Refinishing Industry conservatively estimates 8 workers per site exposed during application process activities; it can also be conservatively estimated that all workers are exposed during each activity.Inhalation:
Note that the ESD specifies inhalation exposures for all workers from oversprayed coating mists.

Exposure to Mist (non-volatile) (Class I) Typical: > Potential Dose Rate: 5.8E

- 1 mg / day over 250 days / yr > Lifetime Average Daily Dose: 3.3E

- 3 mg / kg

- d ay over 250 days / yr > Average Daily Dose: 5.7E

- 3 mg / day over 250 days / yr > Acute Potential Dose: 8.3E

- 3 mg / day over 250 days / yr High End: > Potential Dose Rate: 9.4E+1 mg / day over 250 days / yr > Lifetime Average Daily Dose: 5.3E

- 1 mg / kg

- d ay over 250 days / yr > Average Daily Dose: 9.2E

- 1 mg / day over 250 days / yr > Acute Potential Dose: 1.3E+0 mg / day over 250 days / yr Number of workers (all sites) with inhalation exposure: 1,928 Basis: Spray Coating; User

- d efined Inhalation Model. Per the ESD on Coating Application via Spray Painting in the Automotive Refinishing Industry, EPA recommends estimating exposures based on a typical value of 1 mg/m3 (downdraft booth and HVLP spray gun) for a duration of 28 minute/day and a high-end value of 32 mg/m3 (crossdraft booth - conventional or HVLP) for a duration of 141 minute/day.

NOTE: The respirator class is: I. Particulate (including solid or liquid droplets).

INHALATION MONITORING DATA REVIEW 1) Uncertainty (estimate based on model, regulatory limit, or data not specific to industry): Yes 2)a) Exposure level > 1 mg / day? Yes OR b) Hazard Rating for health of 2 or greater? 2 Yes => Inhalation Monitoring Data Desired? **No**
Dermal: Note that the ESD specifies dermal exposures from the following activities: (1) Unloading Liquid Coating Products; (2) Cleaning Empty Coating Product Containers; (3) Transfer of Coating from Mixing Cup to Spray Gun; (4) Equipment Cleaning; and (5) Oversp r ay during Application. Dermal exposure from the first two activities is estimated using the EPA/OPPT 2-Hand Dermal Contact with Liquid Model. Activities (3) through (5) estimate dermal exposure using the Automotive Refinishing Coating Equipment Cleaning Dermal Model. The EPA/OPPT 2- H and Dermal Contact with Liquid Model is more conservative; therefore, this scenario only presents one exposure for all workers.Exposure to Liquid at 5.00% concentration High End: > Potential Dose Rate: 1.1E+2 mg / day over 2 50 days / yr > Lifetime Average Daily Dose: 6.3E

- 1 mg / day over 250 days / yr > Average Daily Dose: 1.1E+0 mg / day over 250 days / yr > Acute Potential Dose: 1.6E+0 mg / day over 250 days / yr Number of workers (all sites) with dermal exposure: 1,928 Basis: Cleaning Liquid Residuals from Small Containers Used to Transport the Raw Material; EPA/OPPT 2- H and Dermal Contact with Liquids Model. Per ESD on Coating Application via Spray Painting in the Automotive Refinishing Industry, workers may be exposed to the chemical while rinsing or otherwise handling the empty containers used to transport the coating product. To perform a conservative estimate, EPA recommends that the containers are assumed to be rinsed by the painters at the automobile refinishing sites.INITIAL REVIEW ENGINEERING REPORT PMN: 14-0364 USE 3: Polymerizable Emulsifier (47.5%) Number of Sites / Location: 1

Days / yr: 250

Basis: Submitter does not provide end

- u se information. CEB estimates the number of sites based on past cases P05-0551, P08-0061, and P09- 0 400. All past cases assessed 1 site for PVs ranging from 2,000 kg/st- y r to ~23,000 kg/st-yr. CEB assumes 1 site, 250 days/yr, and 100% PMN in raw material. CS calculates a use rate of 37.9962 kg/site-batch.

Process Description: PMN (liquid, 100%) unloaded

- > Charged to reactor with monomer, water, initiators, stabilizers -> Polymerization reaction -> PMN destroyed or entrained in polymer (per past case P09-0400, P08-0061, P05-0551; technical contact; CRSS)

ENVIRONMENTAL RELEASES EST I MATE SUMMARY

IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources to the same medium.

Water or Incineration or Landfill High End: 5.7E-1 kg / site- d ay over 250 days / yr from 1 site or 1.4E+2 kg/site-yr from 1 site or 1.4E+2 kg/yr-all sites to: uncertain from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. C EB conservatively assesses releases to uncertain media using the standard model for drum residuals.

RELEASE TOTAL 1.4E+2 kg / yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 0 Basis:Inhalation:
negligible (VP < 0.001 torr)

Dermal:
None required, per SAT.