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 the 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 Label: 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 with 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-day 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% of the PV is used as a site-limited 

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-day 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-Hand 

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 SUMMARY
Water or Incineration or Landfill 

High End: 5.7E-1 kg/site-day 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 (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-day 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-day 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: 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-volatile 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-day; 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-based coating unless the 

chemical use information specifically states 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-day 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 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. 

Incineration or Landfill 

High End: 1.1E-3 kg/site-day 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 release 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-based 

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 
Conservative: 1.6E-3 kg/site-day 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 incineration 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-based 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-day 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 TOTAL 
3.9E+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-day 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-day 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-defined 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) Overspray 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-Hand 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 250 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-Hand 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-use information. CEB estimates 

the number of sites based on past cases P05-0551, P08-0061, and P09-0400. 

All past cases assessed 1 site for PVs ranging from 2,000 kg/st-yr 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 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 or Incineration or Landfill 

High End: 5.7E-1 kg/site-day 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. CEB 

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.