### Page 1 of 46

INITIAL REVIEW ENGINEERING REPORT

PMN: 12

- 0283

Standard Review Draft 5/15/2012

ENGINEER:

PV (kg/yr):

Revision Notes / Assessment Overview: This version is the

CEB Reviewed version.| | On February 7, 2012, the U.S.

Environmental Protection Agency (EPA) and the U.S.

Department of Justice announed a settlement agreement

with Dover Chemical Corporation resulting from the

unauthorized manufacture of chemical substances at

facilities in Dover, Ohio and H ammond, Indiana. As a

result of the settlement, EPA has recieved several

premanufacure notices (PMN) from Dover Chemical

Corporation for various existing medium

- chain and

long

- chain chlorinated paraffin (MCCP and LCCP) products.

The review of these PMNs is complimented by EPA's current

initiative to conduct a review of the environmental and

health impacts of MCCPs and LCCPs as part of EPA's Work

Plan Chemicals Initiative. /// For each substance, Dover

Chemical has provided detailed information for the

manuf acturing and downstream processing and use as part

of the PMN submissions. Prior to recieving the

submissions, EPA conducted a literature review on release

and exposure data for the manufacture and downstream

processing and use of chloriated paraffins as a means to

supplement information provided by Dover Chemical and/or

fill any data gaps that may exist. Literature sources

that have been reviewed include: 1) previous EPA

assessments on chlorinated paraffins; 2) foreign risk

assessments on MCCPs and LCCPs (e.g. EU risk assessments);

3) EPA/OPPT Generic Scenarios; 4) OECD Emission Scenario

Documents; and 5) Toxics Release Inventory data. Data

provided by Dover Chemical, data identified in the

literature review, and EPA/OPPT standard models were

reviewed and the best available data were used to

assesses environmental releases and occupations exposures.

SUBMITTER: Dover Chemical

USE: Generic uses MCCP: 1) Forty

- three percent of the

notification substances are used as a flame

retardant/plasticizer in polymers. Typical

concentration in the plastic is 12

- 30%. 2) Thirty

percent of the notification substance is used as a

lubricant in metal working fluids (MWFs). The

notification substance is blended into the MWFs at 5

- 10%.

3) Two percent of the notification substances is used as

lubricants in automotives. The notification substance is

blended into the lubricant at 4%. [20% consumer uses].

4) Twenty

- four percent of the notification substance is

used as a flame retardant/plasticizer in rubber. Typical

### Page 2 of 46

total concentration of flame retardant/plasticizer in

the rubber is 1

- 10%, with a median value of 5.5%. 5)

One

- half of one percent of the notification substances

are used as a plasticizer in solvent based paints,

adhesives and sealants. The paints are specialty paints

for applications where weather resistant coatings are

needed, such as steel construction, industrial flooring,

road marking, and swimming pools. The notification

substance is blended into the paints at 5

- 15%. [0.1%

consumer use as sealant s in windows] and 6) One

- half of

one percent of the notification substances are applied as

a flame retardants/waterproofers to textiles. The

notification substance products are added at 5% of the

textile coating finishing solution.

OTHER USES:

MSDS: Yes Label: No

Gen Eqpt: Eng Controls: Ventilation should effectively

remove and prevent buildup of any vapor/mist/fume/dust

generated from the handling of this product. // Eye/Face:

Safety glasses with side

- shields. If splashes are l ikely

to occur, wear: face

- shield. // Skin: Normal work

clothing (long sleeved shirts and long pants) is

recommended. //

Respirator: No personal respiratory protective equipment

normally required. If mist is generated (heating,

spraying) and engineering co ntrols are not sufficient,

wear approved organic vapor respirator suitable for oil

mist.

Health Effects: Eye: Contact with eyes may cause

irritation // Skin: Prolonged and/or repeated skin

contact may result in mild irritation or redness //

Inhalation: Avoid breathing vapors or mists of this

product. May cause irritation of respiratory tract. //

Ingestion: Small amounts (a tablespoonful) swallowed

during normal handling operations are not likely to cause

injury; swallowing amounts larger than that may ca use

injury.

TLV/PEL:

none established

CRSS :

Chemical Name: Tetradecane, chloro

S

- H20: 0.00003 g/L @

VP: 1.0E

- 6 torr @

MW: 302.00 %<500 %<1000

Physical State and Misc CRSS Info:

Neat: liquid Mfg: liquid Proc/Form: variable End Use: 5

-

30% in final product. The average molecular formula would

range from C14H27Cl3 (at ~30% chlorination) to

### Page 3 of 46

C14H16Cl14 (~ 75% chlorination)

Consumer Use: Yes

SAT (concerns) :

Related Cases and Related Cases and Misc SAT Info:

SAT data not yet available

Migration to groundwater:

PBT rating: PBT SAT data not yet available

Health:

Eco:

OCCUPATIONAL EXPOSURE RATING: 2

- 3D

NOTES & KEY ASSUMPTIONS:

Generated by the 06/07/2005 version of ChemSTEER. This

PMN is a MCCP product that is manufactured domestically

and used in the following applications: 1) 43% as a

flame retardant/plasticizer in polymers. 2) 30% as a

lubricant in metal working fluids (MWFs). 3) 2% used as

lubricant in automotive engines (20% consumer, 80%

commerical) 4) 24% as a flame retardant/plasticizer i n

rubber 5) 0.5% as a plasticizer in solvent based paints,

adhesives and sealants and 6) 0.5% as a flame

retardants/waterproofers to textiles. // Note, the SAT

information is not yet avaiable for this PMN. // For MFG:

Submitter estimates were used for assessing releases and

dermal exposure was assessed using standard models. //

For downstream processing and use operations: The

releases estimates were based on a combination of

submitter provided data and data available in various

literature sources. The literature sources include those

previous review by EPA as well as Generic Scenarios and

Emission Scenario Documents. The submitter has stated

that "Due to the large number of customers and potential

sites where the notification substances may be used,

sp ecific use information for each site could not be

obtained. Rather, these worker exposures and

environmental releases scenarios are average scenarios

for each particular use." Due to the uncertainty at

multiple downstream use sites, the most conservative data

were chosen when evaluating releases for downstream

operations. // Note, all exposure

- based criteria were met.

POLLUTION PREVENTION CONSIDERATIONS:

EXPOSURE

- BASED REVIEW: Yes (3 criteria met)

1) # of workers exposed: 0 >1000? Yes

2) >100 workers with >10 mg/day inhalation exposure: Yes

3) (a) >100 workers w/1

- 10 mg/day inh. exp. & >100

days/yr: Yes

### Page 4 of 46

(b) Routine Dermal Cont: >250 workers & >100 days/yr:

Yes

### Page 5 of 46

INITIAL REVIEW ENGINEERING REPORT

PMN: 12

- 0283

MFG: Batch Manufacturing of PMN

Number of Sites/ Location: 2

Dover Chemical Corporation Dover OH 44622

Hammond Works Hammond IN 46327

Days/yr: 93

Basis: Per submission, 2 submitter sites, 93 bt/yr, 25.5

hr/bt, 20,412 kg/bt, PMN produced as a liquid at 91.5 to

100%. CEB assumes PMN is produced as liquid at 100% to

conservatively assess exposures.

Process Description: 1

- tetradecene charged to a reactor

at approximately 176 deg C

--- > chlorine gas in fed to

reactor

--- > QC sampling to check reaction completion

(P MN liquid, 91.5

- 100%)

--- > off

- gas is fed through

scrubber system

-- > when reaction is finished, turn off

chlorine

--- > nitrogen purge

--- > residual hydrochloric

acid is removed from the product by nitrogen blow, then

air blow

--- > mix with stabilizer, a ntifoaming agent, and

amine phosphate ester salt

--- > charge to storage tank

(optional)

--- > PMN (liquid, 91.5

- 100%) is charged to

tanks trucks (69% of PV), drums (23% of PV), totes (4% of

PV), and railcars (4% of PV) (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. The submission provides releases

estimates for filter disposal and equipment cleaning.

Filter disposal r eleases are expected to landfill while

equipment cleaning releases are expected to incineration

or landfill. The equipment cleaning releases were

estimated by the submitter to be 2% of the total PV which

is equivalent to the CEB standard model loss rate. F ilter

disposal was estimated by the submitter to account for 0.

011% of the total PV.

Incineration or Landfill

Conservative: 4.1E+2 kg/site

- day over 1 day/yr from 2

sites

or 8.2E+2 kg/yr

to: incineration or landfill (submission)

from: Equipment Cleaning Losses of Liquids from Multiple

Vessels

basis: EPA/OPPT Multiple Process Vessel Residual Model,

CEB standard 2% residual. The submission estimates 408.24

kg/bt of PMN are released to incineration or landfill

from equipment cleaning residuals with cleaning occuring

once per year. This is equivalent to a loss rate of 2%

which is the same as the standard model loss fraction.

CEB assesses equipment cleaning residual releases to

### Page 6 of 46

incineration or landfill using a loss rate of 2%.

Landfill

Output 2: 2.2E+0 kg/site

- day over 93 days/yr from 2 sites

or 4.2E+2 kg/yr

to: non

- hazardous waste landfill (submission)

from: Filter Waste Disposal

basis: User

- Defined Loss Rate Model. The submission

estimates 2.25 kg/bt of PMN is released to landfill from

filter waste disposal.

RELEASE TOTAL

1.2E+3 kg/yr

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 8

Basis: The submission estimates up to 4 workers/site

exposed to PMN at during various activities. As

conservative, CEB assesses dermal exposure for all

workers to liquid PMN at 100% during sampling (1

- hand)

and loading (2

- hand) activities.

Inhalation:

Inhalation exposure is expectd to be negligible (VP < 0.

001 torr)

Dermal:

Exposure to Liquid at 100.00% concentration

High End: 8.8E+2 mg/day over 93 days/yr

Number of workers (all sites) with dermal exposure: 8

Basis: Sampling Liquid Product; EPA/OPPT 1

- Hand Dermal

Contact with Liquids Model.

Exposure to Liquid at 100.00% concentration

High End: 1.8E+3 mg/day over 93 d ays/yr

Number of workers (all sites) with dermal exposure: 8

Basis: Loading Liquid Product into Transport Containers;

EPA/OPPT 2

- Hand Dermal Contact with Liquids Model.

### Page 7 of 46

INITIAL REVIEW ENGINEERING REPORT

PMN: 12

- 0283

PROC1: Plastics Compounding (43% of PV)

Number of Sites/ Location: 32

multiple sites

- See Attachment 008 for a full list of

customers across all downstream operations

Days/yr: 60

Basis: Per submission, 32 plastic compounding sites, 60

days/yr of operation, PMN used as a liquid at 91.5 to

100% and compounded to 12

- 30% in solid plastic pellets.

CEB assumes 100% PMN in raw material and 30% PMN in

plastic product to conservatively assesses exposures. CS

calculates a use rate of 846.4 kg/site

- bt.

Process Description: PMN (l iquid, 91.5

- 100%) is

unloaded from tanks trucks (69% of PV), drums (23% of PV),

totes (4% of PV), and railcars (4% of PV) into feeder

--- > feed into mechanical mixer

--- > charge to extruder

--- > extrusion performed in the molten state

--- > water

quenchi ng upon exit from extruder

--- > pelletizing

--- >

PMN (solid, 12

- 30%, median 21%) charged to bulk

container (submission)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

may coincide with daily releases fr om the other sources

to the same medium. The releases estimates were based on

a combination of submitter provided data and data

available in various literature sources. A description of

the data is provided in the release notes for each source.

The submitter has stated that "Due to the large number

of customers and potential sites where the notification

substances may be used, specific use information for each

site could not be obtained. Rather, these worker

exposures and environmental releases scen arios are

average scenarios for each particular use." Due to the

uncertainty at multiple downstream use sites, the most

conservative data was chosen when evaluating releases for

downstream operations.

Water

Output 2: 8.5E

- 3 kg/site

- day over 60 days/yr from 32 sites

to: water or air (GS, ESD)

from: Fugitive Air Emissions During High Temperature

Extrusion

basis: User

- Defined Loss Rate Model. The submission does

not address fugitive air emissions from the high

temperature extrusion process. Both the 2004 GS a nd ESD

for Plastics Compounding estimates a loss rate of 0.002%

to fugitive air for low volatility substances which would

include MCCP substances. 50% of the releases are expected

to remain in the air while the other 50% is expected to

### Page 8 of 46

be released to water.

Water or Incineration

Output 1: 1.7E+1 kg/site

- day over 60 days/yr from 32 sites

or 3.3E+4 kg/yr

to: water or incineration (submission, GS)

from: Equipment Cleaning Losses of Liquids from

Compounding Equipment

basis: User

- Defined Loss Rate Model. The submission

esitmates 16.9 kg/day (16.9/846 = 2% of PV) released to

incineration from equipment cleaning residuals with

cleaning occuring 1 day/yr. The 2004 GS for Plastics

Compounding estimates a loss rate of 2% based on the

EPA/OPPT Multiple Vessel Re sidual model with releases to

water. Due to uncertainty at multiple downstream release

sites, a 2% loss rate is used for for equipment cleaning

residual releases with releases assessed to water or

incineration occuring once per day.

Water or Incineration or Landfill

Output 1: 6.2E+0 kg/site

- day over 56 days/yr from 32 sites

or 1.1E+4 kg/yr

to: water, incineration, or landfill (submission, GS)

from: Cleaning Liquid Residuals from Drums Used to

Transport the Raw Material

basis: User

- Defined Loss Rate Model. The submission

esitmates 25.4 kg/day (25.4/846 = 3% of PV) released to

landfill from drum residual disposal. The 2004 GS for

Plastics Compounding estimates a loss rate of 3% based on

the EPA/OPPT Drum Residual model with releases to water,

incineration, or landfill. Due to uncertainty at multiple

downstream release sites, a 3% loss rate is used for drum

residual releases with releases assessed to water,

incineration, or landfill.

Water or Incineration or Landfill

Output 1: 4.2E+0 kg/site

- day over 19 days/yr from 32 sites

or 2.5E+3 kg/yr

to: water, incineration, or landfill (submission, GS)

from: Cleaning Liquid Residuals from Rail Cars, Tank

Trucks, and Totes Used to Transport the Raw Material

basis: User

- Defined Loss Rate Model. The submission

esitma tes 1.7 kg/day (1.7/846 = 0.2% of PV) released to

landfill from railcar, tank truck, and tote residual

disposal. The EPA/OPPT Bulk Transport Residual Model

estimates a loss rate of 0.2%. The 2004 GS for Plastics

Compounding estimates transport container re sidual

releases to water, incineration, or landfill. Due to

uncertainty at multiple downstream release sites, a 0.2%

loss rate is used for drum residual releases with

releases assessed to water, incineration, or landfill.

Water or Incineration or Landfill

Suggested Value: 8.5E

- 2 kg/site

- day over 60 days/yr from

### Page 9 of 46

32 sites

or 1.6E+2 kg/yr

to: water, incineration, or landfill (ESD, 1992 RM

- 2,

2002 EU RA)

from: Spillage During Raw Material Handling

basis: User

- Defined Loss Rate Model. The submission does

not ad dress potential releases from spillage during raw

material handling. A 1992 RM

- 2 assessment for SCCPs

estimated these releases to be 0.1% of the PV with 90% of

releases going to incineration landfill and 10% going to

water. the 2004 ESD for Plastics Compounding as well as a

2002 EU Risk assessment on MCCPs estimated these releases

to be 0.01% of PV with releases to water or solid waste.

The estimate from the 2004 ESD and the 2002 EU Risk

Assessment orginate from more recent data sources and is

theref ore used as the basis for estimating releases.

Air

Output 2: 8.5E

- 3 kg/site

- day over 60 days/yr from 32 sites

to: water or air (GS, ESD)

from: Fugitive Air Emissions During High Temperature

Extrusion

basis: User

- Defined Loss Rate Model. The submission doe s

not address fugitive air emissions from the high

temperature extrusion process. Both the 2004 GS and ESD

for Plastics Compounding estimates a loss rate of 0.002%

to fugitive air for low volatility substances which would

include MCCP substances. 50% of th e releases are expected

to remain in the air while the other 50% is expected to

be released to water.

RELEASE TOTAL

4.6E+4 kg/yr

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 768

Basis: The submission estimates up to 3 workers/site. The

GS for Plastics Compounding estimates 24 workers/site. As

conservative, 24 workers/site is estimated due to

multiple downstream sites.

Inhalation:

Exposure to Particulate (Class I)

Low End of Range: 3.0E

- 2 mg/day over 60 days/yr

High End of Range: 4.4E+0 mg/day over 60 days/yr

Number of workers (all sites) with inhalation exposure:

Basis: Fugitive Air Emissions During High Temperature

Extrusion; User

- defined Inhalation Model. A 2008 EU Risk

Assessment on MCCP contains monitoring data from plastic

compounding operations is the EU. The monitoring data is

based on 32 air samples from 4 sites. Results showed air

concentrations ranging from <0.003 to 0.44 mg/m3 with a

### Page 10 of 46

median of 0.03 mg/m3 and a 90th percentile of 0.15 mg/m3.

Exposures estimates are presented based on the low and

high of the range for these data.

NOTE: The respirator class is: I. Particulate (including

solid or liquid droplets).

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regu latory 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? No

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Only dermal exposure to liquid PMN during unloading is

assessed. PMN will be encapsulated in plastic pellets

during handling of plastic pellet product. While some

surface contact may occur, dermal exposure to solids in

this form are non

- quantifiabl e (2004 ESD; Cast Solids,

CEB Method for Screening

- Level Assessments of Dermal

Exposure).

Exposure to Liquid at 100.00% concentration

High End: 1.8E+3 mg/day over 60 days/yr

Number of workers (all sites) with dermal exposure: 768

Basis: Unloading Liquid R aw Material from Drums; EPA/OPPT

2

- Hand Dermal Contact with Liquids Model.

### Page 11 of 46

INITIAL REVIEW ENGINEERING REPORT

PMN: 12

- 0283

USE1: Plastics Converting (43% of PV)

Number of Sites/ Location: 32

unknown sites

Days/yr: 250

Basis: The subm ission does not provide information on

plastic converting. Per submission, the upstream

compounding process yields plastic pellets containing 12

- 30% (median 21%) PMN. CEB assumes 30% as conservative

for expsoures. The 2004 GS for Plastics Converting is

referenced to estimate general facility estimates. The GS

assumes 250 days/yr of operation. Based on literaure data,

PVC is the most common plastic in which CPs are used as

flame retardants and plasticizers. Using annual

production volume of PVC from the GS, the use rate is

calculated as: 6,680,000,000 kg plastic/yr / 12,191 total

sites / 250 days/yr x 0.12 = 18,265 kg/site

- day. based on

this use rate, CS calculates 1 end use site. Since the

calculated number of end use sites < number of upstream

processin g sites, CEB assumes 1 customer per compounding

sites, or 32 convering sites. CS calcualtes an adjusted

use rate of 203.14 kg/site

- day.

Process Description: Plastic pellets or other solid form

containing PMN (solid, 12

- 30%) are unloaded

--- > forming

(heat ing) --- > molding and shaping using various

processes (injection molding, extrusion, casting,

calendaring, etc.)

--- > trimming

--- > finishing

--- >

finishing plastic article (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. The submission does not address the

potential for plastics converting operations after

compounding into plastic pellets. The technical contact

indicated that these operations were considered but

estimates were not provided due to lack of information on

downstream processes after compounding. The releases

estimates are based data available in various literature

sources. A description of the data is provided in t he

release notes for each source. Due to the uncertainty at

multiple downstream use sites, the most conservative data

were chosen when evaluating releases for downstream

operations.

Water

Suggested Estimate: 1.5E

- 1 kg/site

- day over 250 days/yr

from 32 sit es

to: water or air (ESD, 2010 EU CSR)

from: Fugitive Air Emissions During Forming and Molding

### Page 12 of 46

basis: User

- Defined Loss Rate Model. The submission does

not address plastic converting operations. Data from

various literature sources suggests that fugitive a ir

emissions generated during forming and molding can range

between 0.002 to 0.15% with engineering controls

depending on the type of coversion process (e.g.

extrusion, injection molding, calendaring). The 2004 ESD

for Plastics Converting estimates that 50% of air

emissions will settle and be ultimately released to water

while the other 50% remains in air. As conservative, CEB

assesses fugitive air emissions at a loss rate of 0.15%

with 50% to water and 50% to air.

Water or Incineration or Landfill

Suggested Estimate: 2.0E

- 2 kg/site

- day over 250 days/yr

from 32 sites

or 1.6E+2 kg/yr

to: water, incineration, or landfill (RM

- 2)

from: Spillage During Raw Material Handling

basis: User

- Defined Loss Rate Model. The submission does

not address plastic conve rting operations. A 1992 RM

- 2

assessment for SCCPs estimated releases from spills to be

0.1% of the PV with 90% of releases going to incineration

landfill and 10% going to water. A 2010 EU CSR assessment

on MCCPs estimated these releases to be 0.01% of PV with

releases to water or solid waste. The 2010 EU CSR

estimate is derived from more recent data sources and is

therefore used as a basis to estimate releases from

spillage.

Water or Incineration or Landfill

Output 2: 2.0E+0 kg/site

- day over 250 days/yr f rom 32

sites

or 1.6E+4 kg/yr

to: water, incineration, or landfill (GS)

from: Cleaning Solid/ Powder Residuals from Containers

Used to Transport the Raw Material

basis: EPA/OPPT Solid Residuals in Transport Containers

Model, CEB standard 1% residual. The su bmission does not

address plastic converting operations. The 2004 ESD for

Plastics Converting estimates releases from containiner

cleaning using the EPA/OPPT model for solid residuals

with releases to water, incineration, or landfill.

Water or Incineration or Landfill

Conservative: 4.1E+0 kg/site

- day over 250 days/yr from 32

sites

or 3.3E+4 kg/yr

to: water, incineration, or landfill (ESD)

from: Equipment Cleaning Losses from Multiple Vessels

basis: EPA/OPPT Multiple Process Vessel Residual Model

, CEB standard 2% residual. The submission does not address

plastic converting operations. The 2004 ESD for Plastics

Converting estimates releases from equipment cleaning

### Page 13 of 46

using the EPA/OPPT model loss rate of 2% with releases to

water, incineration, or lan dfill.

Water or Landfill

Suggested Estimate: 5.1E+0 kg/site

- day over 250 days/yr

from 32 sites

or 4.1E+4 kg/yr

to: water or landfill (ESD)

from: Scrap Material

basis: User

- Defined Loss Rate Model. The submission does

not address plastic converting operations. A 1992 RM

- 2

assessment for SCCPs estimated scrap from trimming to be

1% of the PV with 90% of releases going to landfill. The

2004 ESD for Plastics Converting estimated these releases

to be 2.5% of PV with releases to water or landfill. This

is based on the assumption that large pieces of scrap

material will be disposed to landfill via solid waste and

dust generated during trimming will settle to the floor

and be washed away to wastewater during cleaning. Due to

multiple unknown downstream sites, CEB conservatively

assesses a 2.5% loss rate with releases to water or

landfill based on the ESD.

Air

Suggested Estimate: 1.5E

- 1 kg/site

- day over 250 days/yr

from 32 sites

to: water or air (ESD, 2010 EU CSR)

from: Fugitive Air Emissions During Form ing and Molding

basis: User

- Defined Loss Rate Model. The submission does

not address plastic converting operations. Data from

various literature sources suggests that fugitive air

emissions generated during forming and molding can range

between 0.002 to 0. 15% with engineering controls

depending on the type of coversion process (e.g.

extrusion, injection molding, calendaring). The 2004 ESD

for Plastics Converting estimates that 50% of air

emissions will settle and be ultimately released to water

while the ot her 50% remains in air. As conservative, CEB

assesses fugitive air emissions at a loss rate of 0.15%

with 50% to water and 50% to air.

Air

Output 2: 4.6E

- 2 kg/site

- day over 250 days/yr from 32

sites

to: air or landfill w/ 99% dust collection efficiency

(R M

- 2)

from: Dust Generation During Trimming

basis: User

- Defined Loss Rate Model. The submission does

not address plastic converting operations. A 1992 RM

- 2

Assessment of SCCPs estimates a loss rate of 75g/kg of

plastic produced with 1% of releases to air and 99% to

landfill based on a 99% dust collection efficiency. Based

on a MCCP concentration of 30%, the loss rate for PMN

during plastic converting is 75g/kg of plastic x 0.3 = 22.

### Page 14 of 46

5g/kg of plastic, or 2.25%.

Landfill

Output 2: 4.5E+0 kg/site

- day ov er 250 days/yr from 32

sites

or 3.6E+4 kg/yr

to: air or landfill w/ 99% dust collection efficiency

(RM

- 2)

from: Dust Generation During Trimming

basis: User

- Defined Loss Rate Model. The submission does

not address plastic converting operations. A 1992 RM

- 2

Assessment of SCCPs estimates a loss rate of 75g/kg of

plastic produced with 1% of releases to air and 99% to

landfill based on a 99% dust collection efficiency. Based

on a MCCP concentration of 30%, the loss rate for PMN

during plastic converting is 75g/k g of plastic x 0.3 = 22.

5g/kg of plastic, or 2.25%.

RELEASE TOTAL

1.3E+5 kg/yr

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 1,536

Basis: The submission does not address converting

processes. The 2004 ESD for Plastic Converting estimates

up to 48 workers/site.

Inhalation:

Exposure to Particulate (Class I)

2008 EU RA Data: 1.2E+1 mg/day over 250 days/yr

OSHA PEL: 4.5E+1 mg/day over 250 days/yr

Number of workers (all sites) with inhalation exposure : 1,

Basis: Inhalation Exposure During Converting Process;

User

- defined Inhalation Model. A 2008 EU RA on MCCPs and

a 2010 EU CSR on MCCPs contains monitoring data from PVC

converting operations is the EU. The monitoring data

suggest MCCP air concentration s ranging from <0.01 to 1.2

mg/m3 depending on the type of converting process. These

data are based on a over 28 samples taken from 4 sites.

It is unknown whether these data represent area or

personal monitoring data. The 2004 ESD for Plastics

Converting e stimates exposures during converting using

the OSHA PEL Limiting Model. Based on uncertainty in

multiple downstream use sites and the fact that these

data are only basd on 1 site, CEB assesses exposures

based on the high end of the EU data range (1.2 mg/m3 )

and the OSHA PEL (15 mg/m3 x 0.3 = 4.5 mg/m3).

NOTE: The respirator class is: I. Particulate (including

solid or liquid droplets).

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit

### Page 15 of 46

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? No

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

PMN will be encapsulated in plastic pellets during

handling of plastic raw material. While some surface

contact may occur, dermal exposure to solids in this form

are non

- quantifiable (2004 ESD; Cast Solids, CEB Method

for Screening

- Level Assessments of Dermal Exposur e).

### Page 16 of 46

INITIAL REVIEW ENGINEERING REPORT

PMN: 12

- 0283

PROC2: Rubber Compounding (24% of PV)

Number of Sites/ Location: 33

multiple sites

- See Attachment 008 for a full list of

customers across all downstream operations

Days/yr: 31

B asis: Per submission, 33 rubber compounding sites, 31

days/yr of operation, PMN used as a liquid at 91.5 to

100% and compounded to 1

- 10% (median of 5.5%) in solid

rubber sheets. CEB assumes 100% PMN in raw material and

10% PMN in plastic product to conservatively assesse

exposures. CS calculates a use rate of 886.63 kg/site

- bt.

Process Description: PMN (liquid, 91.5

- 100%) is

unloaded from tanks trucks (69% of PV), drums (23% of PV),

totes (4% of PV), and railcars (4% of PV) into feeder

--- > feed into mechanical mixer

--- > charge to

calendering machine

--- > solid sheets formed containing

PMN (solid, 1

- 10%, median 5.5%) loaded for shipment

(submission)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source bel ow

may coincide with daily releases from the other sources

to the same medium. The releases estimates were based on

a combination of submitter provided data and data

available in various literature sources. A description of

the data is provided in the release notes for each source.

The submitter has stated that "Due to the large number

of customers and potential sites where the notification

substances may be used, specific use information for each

site could not be obtained. Rather, these worker

exposures and environmental releases scenarios are

average scenarios for each particular use." Due to the

uncertainty at multiple downstream use sites, the most

conservative data was chosen when evaluating releases for

downstream operations.

Water

Output 2: 8.9E

- 3 kg/site

- day over 31 days/yr from 33 sites

to: water or air (GS, ESD)

from: Fugitive Air Emission from High Temperature

Compounding

basis: User

- Defined Loss Rate Model. The submission does

not address fugitive air emissions from the high

temperature extrusion process. Both the 2004 GS and ESD

for Plastics Compounding estimates a loss rate of 0.002%

to fugitive air for low volatility substances which would

include MCCP substances. 50% of the releases are expected

to remain in the air while the other 50% is ex pected to

be released to water.

### Page 17 of 46

Water or Incineration or Landfill

Submitter Estimate: 1.5E+0 kg/site

- day over 30 days/yr

from 33 sites

or 1.5E+3 kg/yr

EPA/OPPT Model: 6.2E+0 kg/site

- day over 30 days/yr from 33

sites

or 6.2E+3 kg/yr

to: water, incineration , or landfill (submission, GS)

from: Cleaning Liquid Residuals from Drums Used to

Transport the Raw Material

basis: EPA/OPPT Drum Residual Model. The submission

esitmates 6.4 kg/day (6.4/886.6 = 0.72% of PV) released

to incineration or landfill from drum r esidual disposal.

The 2004 GS for Plastics Compounding estimates a loss

rate of 3% based on the EPA/OPPT Drum Residual model with

releases to water, incineration, or landfill. Due to

uncertainty at multiple downstream release sites, the

EPA/OPPT model is used as a conservative estimate for

drum residual releases with releases assessed to water,

incineration, or landfill. /// CEB NOTE: The submitter

estimate based on a loss rate of 0.72% is also presented

to provide a range of estimates.

Water or Incinerat ion or Landfill

Submitter Estimate: 3.1E+0 kg/site

- day over 10 days/yr

from 33 sites

or 1.0E+3 kg/yr

EPA/OPPT Model: 4.2E+0 kg/site

- day over 10 days/yr from 33

sites

or 1.4E+3 kg/yr

to: water, incineration, or landfill (submission, GS)

from: Cleaning Liquid Residuals from Rail Cars, Tank

Truck, or Totes Used to Transport the Raw Material

basis: EPA/OPPT Bulk Transport Residual Model, CEB

standard 0.2% residual. The submission esitmates 1.35

kg/day (1.35/886.6 = 0.15%% of PV) released to

incineration or landfill from railcar, tank truck, and

tote residual disposal. The EPA/OPPT Bulk Transport

Residual Model estimates a loss rate of 0.2%. The 2004 GS

for Plastics Compounding estimates transport container

residual releases to water, incineration, or landfi ll.

Due to uncertainty at multiple downstream release sites,

the EPA/OPPT model is used as a conservative estimate for

bulk container residual releases with releases assessed

to water, incineration, or landfill. /// CEB NOTE: The

submitter estimate based on a loss rate of 0.15% is also

presented to provide a range of estimates.

Water or Incineration or Landfill

Output 2: 1.8E+1 kg/site

- day over 31 days/yr from 33 sites

or 1.8E+4 kg/yr

to: water, incineration, or landfill (submission, GS)

from: Equipment C leaning Losses of Liquids from Multiple

### Page 18 of 46

Vessels

basis: EPA/OPPT Multiple Process Vessel Residual Model.

The submission esitmates 17.8 kg/day (17.8/890.13 = 2% of

PV) released to incineration or landfill from equipment

cleaning residuals with cleaning occur ing 1 day/yr. The

2004 GS for Plastics Compounding estimates a loss rate of

2% based on the EPA/OPPT Multiple Vessel Residual model

with releases to water. A loss rate of 2% is used. Due to

uncertainty at multiple downstream release sites,

releases are ass essed to water, incineration, or landfill

occuring once per day.

Water or Incineration or Landfill

Suggested Estimate: 8.9E

- 2 kg/site

- day over 31 days/yr

from 33 sites

or 9.1E+1 kg/yr

to: water, incineration, or landfill (ESD, 1992 RM

- 2,

2002 EU RA)

from: Spillage During Raw Material Handling

basis: User

- Defined Loss Rate Model. The submission does

not address potential releases from spillage during raw

material handling. A 1992 RM

- 2 assessment for SCCPs

estimated these releases to be 0.1% of the PV with 90% of

releases going to incineration landfill and 10% going to

water. the 2004 ESD for Plastics Compounding as well as a

2002 EU Risk assessment on MCCPs estimated these releases

to be 0.01% of PV with releases to water or solid waste.

The estimate from t he 2004 ESD and the 2002 EU Risk

Assessment orginate from more recent data sources and is

therefore used as the basis for estimating releases.

Air

Output 2: 8.9E

- 3 kg/site

- day over 31 days/yr from 33 sites

to: water or air (GS, ESD)

from: Fugitive Air Em ission from High Temperature

Compounding

basis: User

- Defined Loss Rate Model. The submission does

not address fugitive air emissions from the high

temperature extrusion process. Both the 2004 GS and ESD

for Plastics Compounding estimates a loss rate of 0.0 02%

to fugitive air for low volatility substances which would

include MCCP substances. 50% of the releases are expected

to remain in the air while the other 50% is expected to

be released to water.

RELEASE TOTAL

2.6E+4 kg/yr

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 792

Basis: The submission estimates up to 5 workers/site. The

GS for Plastics Compounding estimates 24 workers/site. As

conservative, 24 workers/site is estimated due to

### Page 19 of 46

multiple dow nstream sites.

Inhalation:

Exposure to Particulate (Class I)

Low End of Range: 10.0E

- 2 mg/day over 31 days/yr

High End of Range: 7.0E

- 1 mg/day over 31 days/yr

Number of workers (all sites) with inhalation exposure:

Basis: Fugitive Air Emission from High Temperature

Compounding; User

- defined Inhalation Model. A 2008 EU

Risk Assessment on MCCP contains monitoring data from

rubber manufacturing operations is the EU. The monitoring

data is based on air samples from 1 site. Results showed

air concentrations ra nging from 0.01 to 0.07 mg/m3

Exposures estimates are presented based on the low and

high of the range.

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? No

OR

b) Hazard Rating for health of 2 or greater? No

Inhalation Monitoring Data Desired? No

Dermal:

Only dermal exposure to liquid PMN during unloading is

assessed. PMN will be encapsulated in rubber sheets

during handling of rubber product. While some surface

contact may occur, dermal exposure to solids in this form

are non

- quantifiable (2004 ESD; Cast Solid s, CEB Method

for Screening

- Level Assessments of Dermal Exposure).

Exposure to Liquid at 100.00% concentration

High End: 1.8E+3 mg/day over 31 days/yr

Number of workers (all sites) with dermal exposure: 792

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT

2

- Hand Dermal Contact with Liquids Model.

### Page 20 of 46

INITIAL REVIEW ENGINEERING REPORT

PMN: 12

- 0283

USE2: Rubber Converting (24% of PV)

Number of Sites/ Location: 33

unknown sites

Days/yr: 250

Basis: The submission does not provide information on

rubber converting. Per submission, the upstream

compounding process yields rubber sheets containing 1

- 10% (median 5.5%) PMN. CEB assumes 10% as conservative

for expsoures and 250 days/yr based on 2004 ESD for

Plastic Converting. Calculation using the 2004 ESD yields

the number of end use sites < number of upstream

processing sites. Therefore, CEB assumes 1 customer per

compounding sites, or 33 convering sites. CS calcualtes

an adjusted use rate of 109.94 kg/sit e- day.

Process Description: Rubber sheets or other solid form

containing PMN (solid, 1

- 10%, median, 5.5%) are unloaded

--- > forming (heating)

--- > molding and shaping using

various processes (injection molding, extrusion, casting,

calendaring, etc.) ---> trimming --- > finishing

--- >

finishing rubber article (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. The submission does n ot address the

potential for rubber converting operations after

compounding into rubber sheets.The technical contact

indicated that these operations were considered but

estimates were not provided due to lack of information on

downstream processes after compounding. The releases

estimates are based data available in various literature

sources. A description of the data is provided in the

release notes for each source. Due to the uncertainty at

multiple downstream use sites, the most conservative data

were chosen when evaluating releases for downstream

operations.

Water

Suggested Estimate: 2.7E

- 1 kg/site

- day over 250 days/yr

from 33 sites

to: water or air (ESD, 2010 EU CSR)

from: Fugitive Air Emission During Forming and Molding

basis: User

- Defined Loss Rat e Model. The submission does

not address rubber converting operations. Data from

various literature sources suggests that fugitive air

emissions generated during rubber converting can range

between 0.002 to 0.05% with engineering controls

depending on the type of coversion process (e.g.

extrusion, injection molding, calendaring). The 2004 ESD

### Page 21 of 46

for Plastics Converting estimates that 50% of air

emissions will settle and be ultimately released to water

while the other 50% remains in air. As conservative, CEB

as sesses fugitive air emissions at a loss rate of 0.05%

with 50% to water and 50% to air.

Water or Incineration or Landfill

Suggested Estimate: 1.1E

- 2 kg/site

- day over 250 days/yr

from 33 sites

or 9.1E+1 kg/yr

to: water, incineration, or landfill (RM

- 2)

fro m: Spillage During Raw Material Handling

basis: User

- Defined Loss Rate Model. TThe submission does

not address plastic converting operations. A 1992 RM

- 2

assessment for SCCPs estimated releases from spills to be

0.1% of the PV with 90% of releases going to incineration

landfill and 10% going to water. A 2010 EU CSR assessment

on MCCPs estimated these releases to be 0.01% of PV with

releases to water or solid waste. The 2010 EU CSR

estimate is derived from more recent data sources and is

therefore used as a basis to estimate releases from

spillage.

Water or Incineration or Landfill

Conservative: 2.2E+0 kg/site

- day over 250 days/yr from 33

sites

or 1.8E+4 kg/yr

to: water, incineration, or landfill (ESD)

from: Equipment Cleaning Losses of from Multiple Vessels

basis: EPA/OPPT Multiple Process Vessel Residual Model,

CEB standard 2% residual. The submission does not address

rubber converting operations. The 2004 ESD for Plastics

Converting estimates releases from equipment cleaning

using the EPA/OPPT model loss r ate of 2% with releases to

water, incineration, or landfill.

Water or Incineration or Landfill

Output 2: 1.1E+0 kg/site

- day over 250 days/yr from 33

sites

or 9.1E+3 kg/yr

to: water, incineration, or landfill (ESD)

from: Cleaning Solid/ Powder Residuals fr om Containers

Used to Transport the Raw Material

basis: EPA/OPPT Solid Residuals in Transport Containers

Model, CEB standard 1% residual. The submission does not

address rubber converting operations. The 2004 ESD for

Plastics Converting estimates releases from containiner

cleaning using the EPA/OPPT model for solid residuals

with releases to water, incineration, or landfill.

Water or Landfill

Suggested Estimate: 2.7E+0 kg/site

- day over 250 days/yr

from 33 sites

or 2.3E+4 kg/yr

### Page 22 of 46

to: water or landfill (ESD)

f rom: Scrap Material

basis: User

- Defined Loss Rate Model. The submission does

not address rubber converting operations. A 1992 RM

- 2

assessment for SCCPs estimated scrap from trimming to be

1% of the PV with 90% of releases going to landfill. The

2004 ESD fo r Plastics Converting estimated these releases

to be 2.5% of PV with releases to water or landfill. This

is based on the assumption that large pieces of scrap

material will be disposed to landfill via solid waste and

dust generated during trimming will set tle to the floor

and be washed away to wastewater during cleaning. Due to

multiple unknown downstream sites, CEB conservatively

assesses a 2.5% loss rate with releases to water or

landfill based on the ESD.

Air

Suggested Estimate: 2.7E

- 1 kg/site

- day over 250 days/yr

from 33 sites

to: water or air (ESD, 2010 EU CSR)

from: Fugitive Air Emission During Forming and Molding

basis: User

- Defined Loss Rate Model. The submission does

not address rubber converting operations. Data from

various literature sources suggests that fugitive air

emissions generated during rubber converting can range

between 0.002 to 0.05% with engineering controls

depending on the type of coversion process (e.g.

extrusion, injection molding, calendaring). The 2004 ESD

for Plastics Conver ting estimates that 50% of air

emissions will settle and be ultimately released to water

while the other 50% remains in air. As conservative, CEB

assesses fugitive air emissions at a loss rate of 0.05%

with 50% to water and 50% to air.

Air

Output 2: 1.2E

- 3 kg/site

- day over 250 days/yr from 33

sites

to: air or landfill w/ 99% dust collection efficiency

(RM

- 2)

from: Dust Generation During Trimming

basis: User

- Defined Loss Rate Model. The submission does

not address plastic converting operations. A 1992 RM

- 2

Assessment of SCCPs estimates a loss rate of 11g/kg of

rubber produced with 1% of releases to air and 99% to

landfill based on a 99% dust collection efficiency. Based

on a MCCP concentration of 10%, the loss rate for PMN

during plastic converting is 11g/kg of plastic x 0.1 = 1.

1g/kg of plastic, or 0.11%.

Landfill

Output 2: 1.2E

- 1 kg/site

- day over 250 days/yr from 33

sites

or 9.9E+2 kg/yr

to: air or landfill w/ 99% dust collection efficiency

### Page 23 of 46

(RM

- 2)

from: Dust Generation During Trimming

basis: User

- Defined Loss Rate Model. The submission does

not address plastic converting operations. A 1992 RM

- 2

Assessment of SCCPs estimates a loss rate of 11g/kg of

rubber produced with 1% of releases to air and 99% to

landfill based on a 99% dust collection efficiency. Bas ed

on a MCCP concentration of 10%, the loss rate for PMN

during plastic converting is 11g/kg of plastic x 0.1 = 1.

1g/kg of plastic, or 0.11%.

RELEASE TOTAL

5.6E+4 kg/yr

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 1,584

Basis: The submission does not address converting

processes. The 2004 ESD for Plastic Converting estimates

up to 48 workers/site.

Inhalation:

Exposure to Particulate (Class I)

2008 EU RA Data: 7.0E

- 1 mg/day over 250 days/yr

OSHA PEL: 1.5E+1 mg/day over 250 days/yr

Number of workers (all sites) with inhalation exposure: 1,

Basis: Inhalation Exposure During Coverting Process;

User

- defined Inhalation Model. A 2008 EU RA on MCCPs and

a 2010 EU CSR on MCCPs contains monitoring data fro m

rubber manufacturing operations in the EU. The monitoring

data suggest MCCP air concentrations ranging from 0.01 to

0.07 mg/m3 based on monitoring conducted at 1 site. It is

unknown whether these data represent area or personal

monitoring data. Based on uncertainty in multiple

downstream use sites and the fact that these data are

only basd on 1 site, CEB assesses exposures based on the

high end of the EU data range (0.07 mg/m3) and the OSHA

PEL (15 mg/m3 x 0.1 = 1.5 mg/m3).

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? No

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

PMN will be encapsulated in rubber sheets during handling

of rubber raw material. While some surface contact may

### Page 24 of 46

occur, dermal exposure to solids in this form are

non

- quantifiable (2004 ESD; Cast Solids, CEB Method for

Screening

- Level Assessments of Dermal Exposure).

### Page 25 of 46

INITIAL REVIEW ENGINEERING REPORT

PMN: 12

- 0283

PROC3: Formulation of Metalworking F luids (30% of PV)

Number of Sites/ Location: 110

multiple sites

- See Attachment 008 for a full list of

customers across all downstream operations

Days/yr: 12

Basis: Per submission, 110 MWF formulation sites, 12

bt/yr, PMN used as a liquid at 91.5 to 100% and

formulated to 5

- 10% (median 7.5%). CEB assumes 100% PMN

in raw material and 10% PMN in plastic product to

conservatively assess exposures. CS calculates a use rate

of 858.93 kg/site

- bt.

Process Description: PMN (liquid, 91.5

- 100%) is

unloaded f rom tanks trucks (69% of PV), drums (23% of PV),

totes (4% of PV), and railcars (4% of PV)

--- > feed

into blending tank

--- > packaging of metal working fluids

containing PMN (5

- 10%, median 7.5%) (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. The releases estimates were based on

a combination of submitter provided data and data

available in various literature sources. A description of

the data is provided in the release notes for each source.

The submitter has stated that "Due to the large number

of customers and potential sites where the notification

substances may be used, specific use information for each

site could not be obtained. Rather, these worker

exposures and environmental releases scenarios are

average scenarios for each particular use." Due to the

uncertainty at multiple downstream use sites, the most

conservative data were chosen when evaluating rele ases

for downstream operations.

Water or Incineration or Landfill

High End: 6.2E+0 kg/site

- day over 11 days/yr from 110

sites

or 7.6E+3 kg/yr

to: uncertain

from: Cleaning Liquid Residuals from Drums Used to

Transport the Raw Material

basis: EPA/OPPT Drum Residual Model, CEB standard 3%

residual. The submission estimates 25.8 kg/day of PMN (25.

8/859 = 3%) release to incineration or landfill from drum

cleaning. This is consistent with the EPA/OPPT Drum

Residual standard model. Due to uncertainty at multiple

downstream sites, CEB assesses releases to uncertain

media.

### Page 26 of 46

Water or Incineration or Landfill

High End: 4.2E+0 kg/site

- day over 4 days/yr from 110 sites

or 1.8E+3 kg/yr

to: uncertain

from: Cleaning Liquid Residuals from Totes, Tank Trucks,

and Rail Cars Used to Transport the Raw Material

basis: EPA/OPPT Bulk Transport Residual Model, CEB

standard 0.2% residual. The submission estimates 1.7

kg/day of PMN (1.7/859 = 0.2%) release to incineration or

landfill from tote, tank truck, and rail car cleaning.

This is consistent with the EPA/OPPT Bulk Transport

Residual standard model. Due to uncertainty at multiple

downstream sites, CEB assesses releases to uncertain

media.

Water or Incineration or Landfill

Conservative: 1.7E+1 kg/site

- day over 12 days/yr from 110

sites

or 2.3E+4 kg/yr

to: uncertain

from: Equipment Cleaning Losses of Liquids from a Mixing

Tank

basis: EPA/OPPT Multiple Process Vessel Residual Model,

CEB standard 2% residual. The submission estimates 17.1

kg/day of PMN (17.1/843 = 2%) released to incineration or

landfill from equipment cleaning with cleaning occuring

once per year. This is consistent with the EPA/OPPT

Multiple Vessel Cleaning standard model. Due to

uncertainty at multiple downstream sites, CEB assesses

releases to uncertain media a ssuming cleaning once per

day.

Air

Suggested Estimate: 4.3E

- 1 kg/site

- day over 12 days/yr

from 110 sites

to: fugitive air (2002 EU RA, 2010 Japan RA)

from: Fugitive Air Emissions

basis: User

- Defined Loss Rate Model. Data from a 2002 EU

RA for MCCP estimat es 16 kg/yr of MCCP may be released to

air from fugitive air emissions generated by preheating

and blending at a typical MWF formulation site (16kg/yr /

32,0145 kg/site

- yr = 0.05% for the current operations). A

2010 Japanese RA for SCCPs suggests 0.005% re lease to air

during MWF formulation. Due to uncertainty at multiple

downstream use sites, CEB includes this release source

using the high end estimate.

Incineration or Landfill

Suggested Estimate: 1.7E+1 kg/site

- day over 12 days/yr

from 110 sites

or 2.3E+ 4 kg/yr

to: incineration or landfill (2002 EU RA)

from: Off

- Spec Material

basis: User

- Defined Loss Rate Model. Data from a 2002 EU

### Page 27 of 46

RA estimates a 1

- 2% loss rate from disposal of off

- spec

batches released to solid waste. Due to uncertainty at

multiple downstream use sites, CEB includes this release

source using the high end estimate with releases to

incineration or landfill.

RELEASE TOTAL

5.5E+4 kg/yr

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 8 80

Basis: The submission estimates up to 4 workers/site. As

conservative, CEB assesses all 4 workers to PMN at 100%

(unloading) and 10% (loading).

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 100.00% concentration

High End: 1 .8E+3 mg/day over 12 days/yr

Number of workers (all sites) with dermal exposure: 440

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT

2

- Hand Dermal Contact with Liquids Model.

Exposure to Liquid at 10.00% concentration

High End: 1.8E+2 mg/day over 12 days/yr

Number of workers (all sites) with dermal exposure: 440

Basis: Loading Liquid Product into Drums; EPA/OPPT 2

- Hand

Dermal Contact with Liquids Model.

### Page 28 of 46

INITIAL REVIEW ENGINEERING REPORT

PMN: 12

- 0283

USE3: Use of Metalwork ing Fluids (30% of PV)

Number of Sites/ Location: 250

multiple sites

- See Attachment 008 for a full list of

customers across all downstream operations

Days/yr: 247

Basis: Per submission, 9,070 MWF use sites, 300 exposure

days per year, PMN used at 1 - 1 0% (median 7.5%) and

diluted to 1.25

- 2.5% (median 1.875%) during use. The

2011 ESD for MWF Operations estimates 247 days/yr of

operation. The ESD estimates the number of sites as: (1,

133,784 kg/yr) / (12,000 gal/site

- yr x 1 kg/L x 3.785

L/gal x 0.1) = 250 sites. Environmental releases are of

concern for this PMN. As conservative, CEB assumes 247

days/yr of operation and the ESD estimate of 250 sites to

maximize kg/site

- day release. CEB also assumes 10% PMN in

raw material, and 2.5% PMN during metalworkin g operations.

CS calcualtes a use rate of 18.3609 kg/site

- day.

Process Description: Bulk MWF containing PMN (liquid,

5- 10%, median 7.5%) is unloaded from transport containers

--- > transfer to mixing vessel

--- > dilution of MWF

--- >

diluted MWF containing PMN (liquid, 1.25

- 2.5%, median 1.

875%) transferred to metal shaping trough

--- > metal

shaping operation

--- > shaped metal part is rinsed and

dried

--- > spent MWF is drained and discarded (submission,

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. The releases estimates were based on

a combination of submitter provided data and data

available in various literature sources. A description of

the data is provided in the release notes for each source.

The submitter has stated that "Due to the large number

of customers and potential sites where the notification

substances may be used, specific use information for each

site could not be obtained. Rather, these worker

exposures and environmental releases scenarios are

average scenarios for each particular use." Due to the

uncertainty at multiple downstream use sites, the most

conservative data were chosen when evaluating releases

for downstream operations.

Water

Output 2: 2.0E+0 kg/site

- day over 247 days/yr from 250

sites

to: on

- site WWTP or POTW (ESD)

from: Dragout Losses

basis: User

- Defined Loss Rate Model. The submission

### Page 29 of 46

estimates an aggregared loss of 1% from

misting/evaporation and dragout with releases to POTW.

The 2011 ESD for MWF Operations estimates a loss rate of

11% from dragout with releases to on

- site WWTP or POTW.

These data are based on U.S. industry data collected

during the development of effluent guidelines for the

metalworking industry. These data provide the best

representation of U.S. operations and are more

conservative than the submitter estimates. Due to

uncertainty at multiple downstream sites, CEB assesses

dragout releases using the ESD est imate of 11% and

accounting for upstream losses from container cleaning:

(1

- 0.03) x 0.11 = 0.1067. Releases are assessed to water

via on

- site WWTP or POTW per submission and ESD. // NOTE

FOR CEB DRAFT: A 2002 EU RA for MCCPs estimates workpiece

dragout to account for 1 to 2% with releases water or

chemical waste and grinding swarf dragout is estimated to

be 30 to 90% with relesaes to incineration or landfill. A

2010 EU CSR for MCCPs estimates overall process losses to

be 1 to 6% with releases to water. The data from the 2011

ESD is most representative of U.S. industry and is

therefore used as the basis for releases.

Water or Incineration or Landfill

High End: 6.2E

- 1 kg/site

- day over 218 days/yr from 250

sites

or 3.4E+4 kg/yr

to: water, incineration, or landfill (ESD)

from: Cleaning Liquid Residuals from Drums Used to

Transport the Raw Material

basis: EPA/OPPT Drum Residual Model, CEB standard 3%

residual. The submission estimates 0.15 kg/site

- day of

PMN (~3% based on use at 9,070 sites estimated by the

s ubmission) released to landfill from container residuals.

The 2011 ESD for MWF Operations estimates releases using

the EPA/OPPT drum residual model (3% loss rate) with

releases to water, incineration, or landfill. Due to

uncertainty at multiple downstream sites, these releases

are assessed to uncertain media using a 3% loss rate.

Water or Incineration or Landfill

Output 2: 6.4E+0 kg/site

- day over 247 days/yr from 250

sites

or 4.0E+5 kg/yr

to: water, incineration, or landfill (ESD)

from: Filter Media and O ther Recycling Waste

basis: User

- Defined Loss Rate Model. The submission does

not address releases from recycling or filter media

losses. The 2011 ESD for MWF Operations estimates these

releases to account for a 36% loss rate with releases to

water, incine ration, or landfill (water

- based fluids) or

incineration or landfill (straight

- oil). Accounting for

upstream container cleaning losses: (1

- 0.03) x 0.36 = 0.

3492. CEB assesses these releases to water, incineration,

### Page 30 of 46

or landfill based on uncertainy at multip le downstream

use sites.

Water or Incineration or Landfill

Output 2: 8.2E+0 kg/site

- day over 247 days/yr from 250

sites

or 5.1E+5 kg/yr

to: water, incineration, or landfill (ESD)

from: Spent Metalworking Fluid

basis: User

- Defined Loss Rate Model. The submission

assesses the remaining fluid to POTW from spent MWF

disposal with bath changouts occuring 5 times/yr. The

2011 ESD for MWF Operations also assesses 100% release

with the spent MWF disposed to water (water

- based fluids)

or incineration or landfill (straight oil fluids) with at

least one bath changeout occuring per day at a facility

with multiple baths in use. Based on uncertainty at

multiple downstream use sites, CEB assesses the spent MWF

to water, incineration, or landfill. Account for up stream

losses, the loss rate is calculated as: (1

- 0.03) x (1

- 0.

05

- 0.11

- 0.38) = 0.4462.

Air

Output 2: 8.9E

- 1 kg/site

- day over 247 days/yr from 250

sites

to: air (2002 EU RA)

from: Misting/Evaporation

basis: User

- Defined Loss Rate Model. The submission

est imates an aggregate loss rate of 1% from

misting/evaporation and dragout. A 2002 EU RA for MCCP

estimates misting/evaporation losses to range from 2 to

5% depending on the type of MWF begin used. Based on

uncertainty at multiple downstream sites, CEB uses the

most conservative estimate of 5% loss to air from

misting/evaporation. Account for upstream losses from

container cleaning: (1

- 0.03) x 0.05 = 0.0485.

RELEASE TOTAL

1.1E+6 kg/yr

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers ex posed via assessed routes: 24,000

Basis:

Inhalation:

Exposure to Mist (non

- volatile) (Class I)

Typical: 9.8E

- 1 mg/day over 247 days/yr

High End of Range: 3.6E+0 mg/day over 247 days/yr

Number of workers (all sites) with inhalation exposure: 12,

Basis: Ex posure During Metalworking Operation;

User

- defined Inhalation Model. The 2011 ESD for MWF

Operations estimates typical mist concentrations ranging

### Page 3 1 of 46

from 0.19 to 0.39 mg/m3 and high end concentrations

ranging from 0.87 to 1.42 mg/m3 depending on the type of

MWF used. These estimates are based on the geometric mean

(typical) and 90th percentile data (high end) of data

collected by NIOSH from 942 machinists at 79 shops across

the U.S. A range of inhalation exposure estimates are

based the high end for the range of geometric means and

90th percentiles and a PMN concentration of 2.5% in the

mist. // NOTE FOR CEB DRAFT: A 2002 EU RA for MCCPs

estimates mist concentrations from 1.6 to 3.4 mg/m3 based

on the 95th percentile of data collected in the EU for

oil

- based and water

- based fluids. The data from the 2011

ESD are more representative of U.S. operations since the

data were collected in the U.S.

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? No

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Exposure to Liquid at 10.00% concentration

High End: 1.8E+2 mg/day over 247 days/yr

Number of workers (all sites) with dermal exposure: 12,000

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT

2

- Hand Dermal Contact with Liquids Model.

Exposure to Mist at 2.50% concentration

Output 1: 4.9E+2 mg/day over 247 days/yr

Number of workers (all sites) with dermal exposure: 12,000

Basis: Exposure During Metalworking Operation;

User

- defined Dermal Model. The 2011 ESD for MWF

Operations estimates an average dermal surface loading

rate for MWFs of 2.9 mg/cm2

- hr during metalworking

operations. These data are more conservative than the

EPA/OPPT 2

- Hand Dermal Contact Model and are used to

provide a conservative est imate of dermal exposure during

MWF use due to uncertainty at downstream opeations.

### Page 32 of 46

INITIAL REVIEW ENGINEERING REPORT

PMN: 12

- 0283

PROC4: Formulation of Engine Lubricants (2% of PV)

Number of Sites/ Location: 15

multiple sites

- See Attachment 008 for a full list of

customers across all downstream operations

Days/yr: 12

Basis: Per submission, 15 formulation sites, 12 exposure

days per year, PMN used at 91.5

- 100% and formulated to

4%. The 2000 GS for Lube Oil Additives estimates 300

days/yr of operation. CEB assumes submission estimate of

12 days/yr to maximize kg/site

- day releases, 100% PMN in

raw material and 4% in product. CS calculates a use rate

of 419.92 kg/site

- day.

Process Description: PMN (liquid, 91.5

- 100%) is

unloaded from tanks trucks (69% of PV), drums (23% of PV),

totes (4% of PV), and railcars (4% of PV)

--- > feed

into blending tank

--- > packaging of lubricant containing

PMN (liquid, 4%) into small containers (submission)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

I RER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources

to the same medium. The releases estimates were based on

a combination of submitter and estimates from the 2000 GS

for Lube Oil Additives.The submitter has stated that "Due

to the large number of customers and potential sites

where the notification substances may be used, specific

use information for each site could not be obtained.

Rather, these worker exposures and environmental releases

scenar ios are average scenarios for each particular use."

Due to the uncertainty at multiple downstream use sites,

the most conservative data were chosen when evaluating

releases for downstream operations.

Water

Output 2: 2.8E+0 kg/site

- day over 12 days/yr from 15 sites

to: water (GS)

from: Spills During Raw Material Transfer

basis: User

- Defined Loss Rate Model. The 2001 GS for Lube

Oil Additives estimates 0.7 kg/site

- day of PMN released

based on 1% concentration in lube oil. For 4%, the

equivalent release would be 2.8 kg/site

- day. Due to

uncertainty at multiple downstream processing sites, CEB

includes this release in the assessment.

Water or Incineration or Landfill

High End: 6.2E+0 kg/site

- day over 6 days/yr from 15 sites

or 5.6E+2 kg/yr

to: water, incineration, or landfill (submission, GS)

from: Cleaning Liquid Residuals from Drums Used to

### Page 33 of 46

Transport the Raw Material

basis: EPA/OPPT Drum Residual Model, CEB standard 3%

residual. The submission estimates 12.6 kg/day of PMN (12.

6/420 = 3%) release to incineration or landfill from drum

cleaning. This is consistent with the EPA/OPPT Drum

Residual standard model. The 2001 GS for Lube Oil

Additives assesses all wastes to water. Due to

uncertainty at multiple downstream sites, CEB assesses

releases to water , incineration, or landfill.

Water or Incineration or Landfill

Submitter Estimate: 9.2E+0 kg/site

- day over 12 days/yr

from 15 sites

or 1.7E+3 kg/yr

to: water, incineration, or landfill (submission, GS)

from: Equipment Cleaning Losses of Liquids from Blen ding

Tank

basis: User

- Defined Loss Rate Model. The submission

estimates 9.2 kg/day of PMN (9.2/420 = 2.2%) release to

incineration or landfill from equipment cleaning. The

2001 GS for Lube Oil Additives assesses all wastes to

water using the EPA/OPPT model. Due to uncertainty at

multiple downstream sites, CEB assesses releases to water,

incineration, or landfill using the submitter estimated

loss rate of 2.2%.

Water or Incineration or Landfill

High End: 4.2E+0 kg/site

- day over 2 days/yr from 15 site s

or 1.2E+2 kg/yr

to: water, incineration, or landfill (submission, GS)

from: Cleaning Liquid Residuals from Totes, Tanks Truck,

and Rail Cars Used to Transport the Raw Material

basis: EPA/OPPT Bulk Transport Residual Model, CEB

standard 0.2% residual. The submission estimates 0.8

kg/day of PMN (0.8/420 = 3%) release to incineration or

landfill from bulk container cleaning. This is consistent

with the EPA/OPPT Bulk Container Residual standard model.

The 2001 GS for Lube Oil Additives assesses all wastes to

water. Due to uncertainty at multiple downstream sites,

CEB assesses releases to uncertain media.

RELEASE TOTAL

2.9E+3 kg/yr

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 225

Basis: The submission est imates up to 8 workers/site. The

2000 GS for Lube Oil Additives estimates 15 workers/site

exposed during formulation. As conservative, CEB assesses

15 workers/site.

Inhalation:

negligible (VP < 0.001 torr)

### Page 34 of 46

Dermal:

Exposure to Liquid at 100.00% concentration

High End: 1.8E+3 mg/day over 12 days/yr

Number of workers (all sites) with dermal exposure: 225

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT

2

- Hand Dermal Contact with Liquids Model.

Exposure to Liquid at 4.00% concentration

Hig h End: 7.1E+1 mg/day over 12 days/yr

Number of workers (all sites) with dermal exposure: 225

Basis: Loading Liquid Product into Small Containers;

EPA/OPPT 2

- Hand Dermal Contact with Liquids Model.

### Page 35 of 46

INITIAL REVIEW ENGINEERING REPORT

PMN: 12

- 0283

USE4: Commerical Use of Engine Lubricants (1.6% of PV)

Number of Sites/ Location: 16

unknown sites

Days/yr: 250

Basis: Per submission, 16 commerical automotive sites,

250 days/yr, PMN in lube oil at 4%. CS calculates 15.1171

kg/site

- day of PMN.

Process Description: Lube oil containing PMN (liquid, 4%)

is unloaded from small containers

--- > lube oil added to

engine

--- > after service life, spent oil removed from

engine and disposed of (submission, GS)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRE R Note: The daily releases listed for any source below

may coincide with daily releases from the other sources

to the same medium. The releases estimates were based on

a combination of submitter and estimates from the 2000 GS

for Lube Oil Additives.The submitter has stated that "Due

to the large number of customers and potential sites

where the notification substances may be used, specific

use information for each site could not be obtained.

Rather, these worker exposures and environmental releases

scenario s are average scenarios for each particular use."

Due to the uncertainty at multiple downstream use sites,

the most conservative data were chosen when evaluating

releases for downstream operations.

Incineration

Output 2: 1.3E+1 kg/site

- day over 250 days/y r from 16

sites

or 5.0E+4 kg/yr

to: incineration or landfill (submission, GS)

from: Spent Oil Disposal

basis: User

- Defined Loss Rate Model. The submission

estimates 10.9 kg/site

- day of PMN (10.9/15.12= 72%)

released to incineration and 1.09 kg/site

- day of PMN (1.

05/15.12 = 7%) released to landfill from spent oil

disposal. The 2000 GS for Lube Oil Additives estimates 83.

2% to incineration and 7.7% to landfill. As conservative,

CEB uses the GS loss rate estimates.

Incineration or Landfill

High End: 9.1E

- 2 kg/site

- day over 250 days/yr from 16

sites

or 3.6E+2 kg/yr

to: incineration or landfill (submission, GS)

from: Cleaning Liquid Residuals from Small Containers

Used to Transport the Raw Material

basis: EPA/OPPT Small Container Residual Model, CEB

### Page 36 of 46

standard 0.6% residual. The submission estimates 0.08

kg/site

- day of PMN (0.08/15.1 = 0.53%) released to

landfill from container residuals. The 2000 GS for Lube

Oil Additives assesses releases to incineration or

landfill. Due to uncertainty at multiple use sites, C EB

assesses these releases to incineration or landfill using

the EPA/OPPT small container loss rate of 0.6%.

Landfill

Output 2: 1.2E+0 kg/site

- day over 250 days/yr from 16

sites

or 4.8E+3 kg/yr

to: incineration or landfill (submission, GS)

from: Spent Oil Disposal

basis: User

- Defined Loss Rate Model. The submission

estimates 10.9 kg/site

- day of PMN (10.9/15.12= 72%)

released to incineration and 1.09 kg/site

- day of PMN (1.

05/15.12 = 7%) released to landfill from spent oil

disposal. The 2000 GS for Lube Oil Additives estimates 83.

2% to incineration and 7.7% to landfill. As conservative,

CEB uses the GS loss rate estimates.

RELEASE TOTAL

5.5E+4 kg/yr

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 80

Basi s: The submission estimates 5 workers/site. The 2000

GS for Lube Oil Additives estimates 3 workers/site for

general automotive and 6 workers/site for pure lube shops.

The submitter estimate is in line with the GS estimates.

Inhalation:

negligible (VP < 0 .001 torr)

Dermal:

Exposure to Liquid at 4.00% concentration

High End: 7.1E+1 mg/day over 250 days/yr

Number of workers (all sites) with dermal exposure: 80

Basis: Unloading Liquid Raw Material from Small

Containers; EPA/OPPT 2

- Hand Dermal Contact with Liquids

Model.

### Page 37 of 46

INITIAL REVIEW ENGINEERING REPORT

PMN: 12

- 0283

PROC5: Formulation of Paints, Sealants, and Adhesives (0.

5% of PV)

Number of Sites/ Location: 33

multiple sites

- See Attachment 008 for a full list of

customers across all downstream operations

Days/yr: 2

Basis: Per submission, 33 formulation sites, 200

- 600

kg/bt, 2 bt/yr, PMN used in raw material at 91.5

- 100%

and formulated to 5

- 15% (median, 10%). CEB assumes 100%

PMN in raw material and 15% in product to conservat ively

assess exposures. CS calculates 286.31 kg/bt.

Process Description: PMN (liquid, 91.5

- 100%) is

unloaded from tanks trucks (69% of PV), drums (23% of PV),

totes (4% of PV), and railcars (4% of PV)

--- > feed

into mixing tank with other components

- -- > filtration

--- > packaging of paint, coating, or adhesive product

containing PMN (liquid, 5

- 15%) into small containers

(submission, 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. The releases estimates were based on

a combination of submitter provided data and data

available in various literature sources. A description of

the data is provided in the release notes for each s ource.

The submitter has stated that "Due to the large number

of customers and potential sites where the notification

substances may be used, specific use information for each

site could not be obtained. Rather, these worker

exposures and environmental re leases scenarios are

average scenarios for each particular use." Due to the

uncertainty at multiple downstream use sites, the most

conservative data were chosen when evaluating releases

for downstream operations.

Water

Output 2: 2.9E

- 2 kg/site

- day over 2 days/yr from 33 sites

to: water, incineration, or landfill (RM

- 2)

from: Spillage During Raw Material Handling

basis: User

- Defined Loss Rate Model. A 1992 RM -2

Assessment for SCCPs estimates a loss rate of 0.1% from

spillage during raw material handling wit h 10% to water

and 90% to landfill or incineration. As conservative, CEB

assesses these releases due to uncertainty at multiple

downstream sites.

Water or Incineration or Landfill

High End: 6.2E+0 kg/site

- day over 1 day/yr from 33 sites

### Page 38 of 46

or 2.1E+2 kg/yr

to: water, incineration, or landfill (ESD)

from: Cleaning Liquid Residuals from Drums Used to

Transport the Raw Material

basis: EPA/OPPT Drum Residual Model, CEB standard 3%

residual. The submission estimates 8.5 kg/site

- day of PMN

(8.5/286 = 3%) released to landfill from drum residuals.

This is in agreement with the EPA/OPPT Drum Residual

Model. The 2010 ESD for the Formulation of Radiation

Curable Coatings, Inks, and Adhesives and the 2011 GS for

the Formulation of Waterborn Coatings use the EPA/OPPT

mode l and assesses releases to water, incineration, or

landfill. As conservative, CEB assesses these releases to

water, incineration or landfill.

Water or Incineration or Landfill

Submitter Estimate: 7.2E+0 kg/site

- day over 2 days/yr from

33 sites

or 4.7E+2 k g/yr

to: incineration or landfill (submission, ESD)

from: Equipment Cleaning Losses of Liquids from Mixing

Vessel

basis: User

- Defined Loss Rate Model. The submission

estimates 7.1 kg/site

- day of PMN (7.1/286 = 2.5%)

released to incineration from equipment cleaning. The

2010 ESD for the Formulation of Radiation Curable

Coatings, Inks, and Adhesives uses the EPA/OPPT Single

Vessel Residual model and assesses releases to

incineration, or landfill. The 2011 GS for the

Formulation of Waterborn Coatings uses a 2% loss rate

with releases to water, incineration, or landfill. As

conservative, CEB assesses these releases to water,

incineration, or landfill using the submitter estimated

loss rate of 2.5%.

Incineration or Landfill

Output 2: 2.6E

- 1 kg/site

- day over 2 da ys/yr from 33 sites

or 1.7E+1 kg/yr

to: water, incineration, or landfill (RM

- 2)

from: Spillage During Raw Material Handling

basis: User

- Defined Loss Rate Model. A 1992 RM

- 2

Assessment for SCCPs estimates a loss rate of 0.1% from

spillage during raw materia l handling with 10% to water

and 90% to landfill or incineration. As conservative, CEB

assesses these releases due to uncertainty at multiple

downstream sites.

Incineration or Landfill

Output 2: 2.9E+0 kg/site

- day over 2 days/yr from 33 sites

or 1.9E+2 kg /yr

to: incineration or landfill (RM

- 2, ESD)

from: Filter Media Disposal

basis: User

- Defined Loss Rate Model. TThe submission does

not address spent fitler waste. Both the 2010 ESD for the

### Page 39 of 46

Formulation of Radiation Curable Coatings, Inks, and

Adhesives and the 1992 RM

- 2 Assessment for SCCPs

estimates 1% loss from spent filter disposal with

releases to incineration or landfill. The 2011 GS for the

Formulation of Waterborn Coatings use a loss rate of 0.

02% with releases to incineration. As conservative, the

RM

- 2 and ESD estimate of 1% with releases to incineration

or landfill is used.

Incineration or Landfill

2002 EU RA Estimate: 1.4E+1 kg/site

- day over 2 days/yr

from 33 sites

or 9.4E+2 kg/yr

to: incineration or landfill (RM

- 2, 2002 EU RA)

from: Spoiled Batc hes

basis: User

- Defined Loss Rate Model. A 1992 RM

- 2

Assessment for SCCPs estimates a loss rate of 0.2% from

spoiled batches with releases to incineration or landfill.

A 2002 EU RA for MCCPs estimates a loss rate of 5% from

scrap material and equipment cl eaning with releases to

incineration or landfill. The 2011 GS for the Formulation

of Waterborn Coatings uses a loss rate of 1.2% for

off

- spec material with releases to incineration. As

conservative, CEB estimates up to 5% loss from scrap

material with rele ases to incineration or landfill.

RELEASE TOTAL

1.8E+3 kg/yr

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 1,287

Basis: The submission estimates 4 workers/site. The 2010

ESD for the Formulation of Radiation Curable Coatings,

Inks, and Adhesives estimates 39 workers/site. As

conservative, CEB assesses 39 workers/site due to

uncertainty at multiple downstream sites.

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 100.00% co ncentration

High End: 1.8E+3 mg/day over 2 days/yr

Number of workers (all sites) with dermal exposure: 1,287

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT

2

- Hand Dermal Contact with Liquids Model.

Exposure to Liquid at 15.00% concentration

High End: 2.6E+2 mg/day over 2 days/yr

Number of workers (all sites) with dermal exposure: 1,287

### Page 40 of 46

Basis: Loading Liquid Product into Small Containers;

EPA/OPPT 2

- Hand Dermal Contact with Liquids Model.

### Page 41 of 46

INITIAL REVIEW ENGINEERING REPORT

PMN: 12

- 0283

USE5: Application of Paints, Sealants, and Adhesives (0.5%

of PV)

Number of Sites/ Location: 38

unknown sites

Days/yr: 249

Basis: Per submission, 38 painting crews, 249 days/yr,

and PMN used at 5

- 15% (median 10%). CEB assumes 15% to

conservatively assess exposures. CS calculates a use rate

of 1.9971 kg/site

- day.

Process Description: Paint or coating containing PMN

(liquid, 5

- 15%; median 10%) is unloaded from containers

--- > painting and coating of surfaces

--- > curing

--- >

PMN entrained in solid coating (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. The releases estimates were based on

a combina tion of submitter and estimates from the 2011

ESD for the Application of Radiation Curable Coatings,

Inks, and Adhesives.The submitter has stated that "Due to

the large number of customers and potential sites where

the notification substances may be used, specific use

information for each site could not be obtained. Rather,

these worker exposures and environmental releases

scenarios are average scenarios for each particular use."

Due to the uncertainty at multiple downstream use sites,

the most conservative data were chosen when evaluating

releases for downstream operations.

Water or Incineration or Landfill

High End: 1.7E

- 2 kg/site

- day over 175 days/yr from 38

sites

or 1.1E+2 kg/yr

to: water, incineration, or landfill (submission, 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. The submission estimates 0.012

kg/site

- day of PMN (0.012/1.9971 = 0.6%) released to

landfill from container res iduals. This is consistent

with the EPA/OPPT Small Container Residual model. The

2011 ESD for the Application of Radiation Curable

Coatings, Inks, and Adhesives assesses these releases to

water, incineration, or landfill using the EPA/OPPT

models. Due to uncertainty at multiple use sites, CEB

assesses these releases to water, incineration, or

landfill.

### Page 42 of 46

Water or Incineration or Landfill

ESD Estimate: 4.0E

- 2 kg/site

- day over 249 days/yr from 38

sites

or 3.8E+2 kg/yr

to: water, incineration, or landfill (sub mission, ESD)

from: Equipment Cleaning Losses of Liquids from Painting

Equipment

basis: User

- Defined Loss Rate Model. The submission

estimates 0.012 kg/site

- day of PMN (0.012/1.9971 = 0.6%)

released to landfill or POTW from container residuals.

The 2011 ESD for the Application of Radiation Curable

Coatings, Inks, and Adhesives assesses these releases to

incineration, or landfill using the EPA/OPPT Muliple

Vessel Residual Model. Due to uncertainty at multiple use

sites, CEB assesses these releases to water , incineration,

or landfill using the EPA/OPPT model loss rate of 2%.

Air

Output 2: 1.5E

- 1 kg/site

- day over 249 days/yr from 38

sites

to: air or landfill (spray model)

from: Coating Using Hand

- Held Spray Gun

basis: EPA/OPPT Automobile Refinish Coating Ov erspray

Loss Model (non

- volatiles). The submission does not

estimate releases from coating application and does not

provided information on the type of coating method. The

submission does indicate that the coatings may be used in

road marking applications. As conservative, spray coating

is assumed. The EPA/OPPT model estimates a filter capture

efficiency of 90% during spray coating resulting in 10%

releases to air and 90% to landfill.

Landfill

Output 2: 1.3E+0 kg/site

- day over 249 days/yr from 38

sites

or 1.3E+4 kg/yr

to: air or landfill (spray model)

from: Coating Using Hand

- Held Spray Gun

basis: EPA/OPPT Automobile Refinish Coating Overspray

Loss Model (non

- volatiles). The submission does not

estimate releases from coating application and does not

provided information on the type of coating method. The

submission does indicate that the coatings may be used in

road marking applications. As conservative, spray coating

is assumed. The EPA/OPPT model estimates a filter capture

efficiency of 90% during s pray coating resulting in 10%

releases to air and 90% to landfill.

RELEASE TOTAL

1.5E+4 kg/yr

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 114

### Page 43 of 46

Basis: The submission estimates 3 workers/site.

Inhalat ion:

The submission does not provide definitive information on

the type of application method used. The submission does

indicate that "exposures will be mitigated by the use of

personal protective equipment when necessary, and also by

the use of equipment such as "striping" machines for the

application of road markings which spray the paint

directly on the road surface." This indicates that the

coatings may be used in road painting applications.

Exposure to Mist (non

- volatile) (Class I)

What

- If: 9.0E+1 mg/day over 249 days/yr

Number of workers (all sites) with inhalation exposure:

Basis: Coating Using Hand

- Held Spray Gun; EPA/ OPPT

Automobile Refinish Spray Coating Inhalation Model

(non

- volatile non

- polyisocyanates). A 2002 EU RA on MCCPs

and a 2010 EU C SR on MCCPs presents air monitoring data

from paint spray application with values ranging from 0.

002 to 0.19 mg/m3 with a median of 0.04 mg/m3 and a 90th

percentile of 0.085 mg/m3. The EPA/OPPT Autorefinishing

Spray Coating Model calculates an exposure of 9 mg/m3.

The EPA/OPPT model is used to provide a conservative

estimate due to uncertainy in downstream use sites.

NOTE: The respirator class is: I. Particulate (including

solid or liquid droplets).

INHALATION MONITORING DATA REVIEW

1) Uncertainty (esti mate 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? No

Inhalation Monitoring Data Desired? Yes (b oth criteria

met)

Dermal:

Exposure to Liquid at 15.00% concentration

High End: 2.6E+2 mg/day over 249 days/yr

Number of workers (all sites) with dermal exposure: 114

Basis: Unloading Liquid Raw Material from Small

Containers; EPA/OPPT 2

- Hand Dermal Contact with Liquids

Model.

Exposure to Liquid at 15.00% concentration

High End: 1.3E+3 mg/day over 249 days/yr

Number of workers (all sites) with dermal exposure: 114

Basis: Coating Using Hand

- Held Spray Gun; EPA/OPPT 2

- Hand

Dermal Immersion in Liquid Mo del.

### Page 44 of 46

INITIAL REVIEW ENGINEERING REPORT

PMN: 12

- 0283

USE6: Plasticizer/Flame Retardant in Textiles (0.5% of PV)

Number of Sites/ Location: 11

multiple sites

- See Attachment 008 for a full list of

customers across all downstream opera tions

Days/yr: 95

Basis: Per submssion, 11 finishing sites, 95 days/yr, PMN

used at 91.5

- 100% and formulated to 5% in finishing

bath. CEB assumes 100% in raw material. CS calculates a

use rate of 18.0827 kg/site

- day.

Process Description: PMN (liquid, 9 1.5

- 100%) is

unloaded from tanks trucks (69% of PV), drums (23% of PV),

totes (4% of PV), and railcars (4% of PV)

--- > feed

into finishing solution tank with other components (PMN,

liquid, 5%)

--- > fabric is moved through the bath

--- >

transfer heated rollers

--- > PMN entrained in coating on

fabric (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. The releases estimat es were based on

submitter due to lack of information from other sources.

The 1994 GS for Fabric Finishing was referenced for

comparison. The submitter has stated that "Due to the

large number of customers and potential sites where the

notification substan ces may be used, specific use

information for each site could not be obtained. Rather,

these worker exposures and environmental releases

scenarios are average scenarios for each particular use."

Due to the uncertainty at multiple downstream use sites,

the most conservative estimate was chosen when evaluating

releases for downstream operations.

Water

Output 2: 3.6E+0 kg/site

- day over 95 days/yr from 11 sites

to: POTW (submission, GS)

from: Dumping of Finishing Bath

basis: User

- Defined Loss Rate Model. The submission

estimates 3.6 kg/site

- day of PMN (3.6/18.1 = 20%)

released to POTW from dumping the finishing bath. The

1994 GS for Fabric Finishing estimates a fabric pick up

between 60 and 100% with bath dumping to water. The

submission estimates are in general agreement with GS

estimates.

Water or Incineration or Landfill

High End: 6.2E+0 kg/site

- day over 2 days/yr from 11 sites

or 1.4E+2 kg/yr

to: uncertain

### Page 45 of 46

from: Cleaning Liquid Residuals from Drums Used to

Transport the Raw Material

basis: EPA/OPPT Dr um Residual Model, CEB standard 3%

residual. The submission estimates 0.54 kg/site

- day of

PMN (0.54/18.1 = 3%) released to landfill from drum

residuals. This is in agreement with the EPA/OPPT Drum

Residual Model. As conservative, CEB assesses these

release s to uncertain media due to uncertainty in

downstream operations.

Water or Incineration or Landfill

Submitter Estimate: 4.6E+0 kg/site

- day over 1 day/yr from

11 sites

or 5.0E+1 kg/yr

to: uncertain

from: Cleaning Liquid Residuals from Totes, Tank Trucks,

a nd Rail Cars Used to Transport the Raw Material

basis: User

- Defined Loss Rate Model. The submission

estimates 0.04 kg/site

- day of PMN (0.04/18.1 = 0.22%)

released to landfill from bulk container residuals. This

estimate is slightly more conservative that t he EPA/OPPT

Bulk Transport Residual Model. As conservative, CEB

assesses these releases to uncertain media using the

submission estimate due to uncertainty in downstream

operations.

RELEASE TOTAL

4.0E+3 kg/yr

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 33

Basis: the submission estimates 2 workers/site. CEB

assesses the default minimum of 3 workers/site.

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 5.00% concentration

High End: 4.3E+2 mg/day over 95 days/yr

Number of workers (all sites) with dermal exposure: 33

Basis: Exposure During Finishing; EPA/OPPT 2

- Hand Dermal

Immersion in Liquid Model.

Exposure to Liquid at 100.00% concentration

High End: 1.8E+3 mg/day over 95 days/yr

Number of workers (all sites) with dermal exposure: 33

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT

2

- Hand Dermal Contact with Liquids Model.

### Page 46 of 46

MEMORANDUM of TELEPHONE CONVERSATION

CALL BY:

Organizati CEB

CALL TO: Don Stevenson

Organization: Dover Chemical Corporation

Date: 04/26/2012

Time: 12:30pm

Phone: 330

- 365

- 3632

Concerning what TSCA ?

PMN: 12

- 0283

Q1: Process information and releases and exposure

information are provided for plastic and rubber

compounding. However, information for plastics and rubber

converting into final articles is not addressed. Do you

have similar information available for downstream plastic

and rubber converting operations?| A1: We do not have

sufficient information for any downstream converting

opreations. We have discussed this particular issue

during the preparation of the PMN submissions. We felt

that we did not have enought information on this process

to feel comfortable a dding the information to the

submission. | | Q2: Can you provide some detail as to how

release estimates were calculated for downstream use? |

A2: We used EPA models to calculate most of the releases.

We also asked for voluntary information from some of ou r

customers such as use concentration, number of workers,

and number of downstream customers.