Page 1 of 41

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0282

Standard Review Draft 5/15/2012

ENGINEER: 

PV (kg/yr):

Revision Notes / Assessment Overview: Note: This is the

CEB Reviewed version of the Standard Review Draft | | |

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 Hammond,

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

manufacturing 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
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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 sealants 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 likely

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 controls 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 cause

injury.

TLV/PEL:

none established

CRSS :

Chemical Name: Alkanes, C14-16, 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 ( LOWWT at ~30% chlorination) to
Page 3 of 41

C16H18Cl16

 high wt (at ~ 70%

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 in

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 release

and exposure estimates were based on a combination of

submitter provided data and data available in various

literature sources. The literature sources 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.. 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. // Note, all

exposure-based criteria were met.

POLLUTION PREVENTION CONSIDERATIONS:

EXPOSURE-BASED REVIEW: Yes (3 criteria met)
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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

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

Yes

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0282

MFG: Batch Manufacturing of PMN

Number of Sites/ Location: 2

Dover Chemical Corporation Dover OH 44622

Hammond Works Hammond IN 46327

Days/yr: 288

Basis: Per submission, 2 submitter sites, 288 bt/yr, 30

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: Alkanes, C14-16 charged to a reactor

at approximately 176 deg C ---> chlorine gas in fed to

reactor ---> QC sampling to check reaction completion

(PMN 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, antifoaming 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.

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.
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CEB assesses equipment cleaning residual releases to

incineration or landfill using a loss rate of 2%.

Landfill

Output 2: 2.2E+0 kg/site-day over 288 days/yr from 2 sites

or 1.3E+3 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

2.1E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 4

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 250 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 250 days/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.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0282

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: 288
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Basis: Per submission, 32 plastic compounding sites, 288

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 548.23 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 extruder

---> extrusion performed in the molten state ---> water

quenching 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 from the other sources

to the same medium. The release 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: 5.5E-3 kg/site-day over 288 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. The 2004 GS 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 be

released to water.

Water or Incineration

Submitter Estimate: 1.7E+1 kg/site-day over 288 days/yr

from 32 sites

or 1.6E+5 kg/yr

to: water or incineration (submission, GS)

from: Equipment Cleaning Losses of Liquids from
Page 7 of 41

Compounding Equipment

basis: User-Defined Loss Rate Model. The submission

esitmates 16.8 kg/day (16.8/548.23 = 3.1% 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 Residual model with releases to

water. Due to uncertainty at multiple downstream release

sites, the submitter estimate is used as a conservative

estimate for equipment cleaning residual releases with

releases assessed to water or incineration occuring once

per day.

Water or Incineration or Landfill

Submitter Estimate: 9.6E+0 kg/site-day over 174 days/yr

from 32 sites

or 5.3E+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 (~ 4.6% 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, the submitter estimate is used

as a conservative estimate for drum residual releases

with releases assessed to water, incineration, or

landfill.

Water or Incineration or Landfill

Submitter Estimate: 6.5E+0 kg/site-day over 58 days/yr

from 32 sites

or 1.2E+4 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

esitmates 1.7 kg/day (1.7/548.23 = 0.31%% 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 residual

releases to water, incineration, or landfill. Due to

uncertainty at multiple downstream release sites, the

submitter estimate is used as a conservative estimate for

drum residual releases with releases assessed to water,

incineration, or landfill.

Water or Incineration or Landfill

Suggested Value: 5.5E-2 kg/site-day over 288 days/yr from

32 sites

or 5.1E+2 kg/yr
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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 the 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: 5.5E-3 kg/site-day over 288 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. The 2004 GS 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 be

released to water.

RELEASE TOTAL

2.2E+5 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 250 days/yr

High End of Range: 4.4E+0 mg/day over 250 days/yr

Number of workers (all sites) with inhalation exposure:

Basis: Fugitive Air Emissions During High Temperature

Extrusion; User-defined Inhalation Model. The 2004 GS for

Plastics Compounding suggests that inhalation exposure is

negligible for non-volatile substances during compounding.

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.
Page 9 of 41

Results showed MCCP air concentrations ranging from <0.

003 to 0.44 mg/m3 with a median of 0.03 mg/m3 and a 90th

percentile of 0.15 mg/m3. It is unknown whether these

data represent area or personal monitoring data. As

conservative, 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, 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:

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-quantifiable (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 250 days/yr

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

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

2-Hand Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0282

USE1: Plastics Converting (43% of PV)

Number of Sites/ Location: 32

unknown sites

Days/yr: 250

Basis: The submission 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
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this use rate, CS calculates 1 end use site. Since the

calculated number of end use sites < number of upstream

processing sites, CEB assumes 1 customer per compounding

sites, or 32 convering sites. CS calcualtes an adjusted

use rate of 631.65 kg/site-day.

Process Description: Plastic pellets or other solid form

containing PMN (solid, 12-30%) are unloaded ---> forming

(heating) ---> 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 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: 4.7E-1 kg/site-day over 250 days/yr

from 32 sites

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

from: Fugitive Air Emissions During Forming 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 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: 6.3E-2 kg/site-day over 250 days/yr

from 32 sites

or 5.1E+2 kg/yr

to: water, incineration, or landfill (RM-2)

from: Spillage During Raw Material Handling

basis: User-Defined Loss Rate Model. TThe submission does
Page 11 of 41

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

Output 2: 6.3E+0 kg/site-day over 250 days/yr from 32

sites

or 5.1E+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 submission 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: 1.3E+1 kg/site-day over 250 days/yr from 32

sites

or 1.0E+5 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

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

water, incineration, or landfill.

Water or Landfill

Suggested Estimate: 1.6E+1 kg/site-day over 250 days/yr

from 32 sites

or 1.3E+5 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
Page 12 of 41

assesses a 2.5% loss rate with releases to water or

landfill based on the ESD.

Air

Suggested Estimate: 4.7E-1 kg/site-day over 250 days/yr

from 32 sites

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

from: Fugitive Air Emissions During Forming 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 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.

Air

Output 2: 1.4E-1 kg/site-day over 250 days/yr from 32

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 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.

5g/kg of plastic, or 2.25%.

Landfill

Output 2: 1.4E+1 kg/site-day over 250 days/yr from 32

sites

or 1.1E+5 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/kg of plastic x 0.3 = 22.

5g/kg of plastic, or 2.25%.

RELEASE TOTAL

4.0E+5 kg/yr - all sites
Page 13 of 41

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:

During unloading, the PMN is entrained in pellet sized

product. Therefore, inhalation exposure is not expected

from solid pellet handling.

Exposure to Particulate (Class I)

Output 1: 1.2E+1 mg/day over 250 days/yr

Output 2: 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 concentrations 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 estimates 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

 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 Exposure).
Page 14 of 41

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0282

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: 96

Basis: Per submission, 33 rubber compounding sites, 96

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 assess

exposures. CS calculates a use rate of 890.14 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 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 was chosen when evaluating releases for

downstream operations.

Water

Output 2: 8.9E-3 kg/site-day over 96 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. The 2004 GS 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 be

released to water.
Page 15 of 41

Water or Incineration or Landfill

EPA/OPPT Model: 6.2E+0 kg/site-day over 94 days/yr from 33

sites

or 1.9E+4 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 (6.4/890.13 = 0.72% of PV) released

to incineration or 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, the

EPA/OPPT model is used as a conservative estimate for

drum residual releases with releases assessed to water,

incineration, or landfill.

Water or Incineration or Landfill

EPA/OPPT Model: 4.2E+0 kg/site-day over 32 days/yr from 33

sites

or 4.4E+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 (1.7/890.13 = 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 landfill.

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.

Water or Incineration or Landfill

Output 2: 1.8E+1 kg/site-day over 96 days/yr from 33 sites

or 5.6E+4 kg/yr

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

from: Equipment Cleaning Losses of Liquids from Multiple

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 occuring 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 assessed to water, incineration, or landfill
Page 16 of 41

occuring once per day.

Water or Incineration or Landfill

Output 2: 8.9E-2 kg/site-day over 96 days/yr from 33 sites

or 2.8E+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 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 the 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 96 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. The 2004 GS 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 be

released to water.

RELEASE TOTAL

8.1E+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

multiple downstream sites.

Inhalation:

Inhalation exposure is expected to be negligible during

unloading of the raw material due to VP < 0.001 torr at

ambient temperatures. During loading, the PMN is

entrained in rubber sheet product. Therefore, inhalation

exposure is not expected from sheet handling.

Exposure to Particulate (Class I)

Low End of Range: 10.0E-2 mg/day over 96 days/yr
Page 17 of 41

High End of Range: 7.0E-1 mg/day over 96 days/yr

Number of workers (all sites) with inhalation exposure:

Basis: Fugitive Air Emission from High Temperature

Compounding; User-defined Inhalation Model. The 2004 GS

for Plastics Compounding suggests that inhalation

exposure is negligible for non-volatile substances during

compounding. 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 MCCP air concentrations ranging

from 0.01 to 0.07 mg/m3. It is unknown whether these data

represent area or personal monitoring data. 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 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 96 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.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0282

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
Page 18 of 41

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 341.82 kg/site-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 not 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: 8.5E-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 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 0.05%

with 50% to water and 50% to air.

Water or Incineration or Landfill

Suggested Estimate: 3.4E-2 kg/site-day over 250 days/yr

from 33 sites

or 2.8E+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 converting operations. A 1992 RM-2
Page 19 of 41

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: 6.8E+0 kg/site-day over 250 days/yr from 33

sites

or 5.6E+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 rate of 2% with releases to

water, incineration, or landfill.

Water or Incineration or Landfill

Output 2: 3.4E+0 kg/site-day over 250 days/yr from 33

sites

or 2.8E+4 kg/yr

to: water, incineration, or landfill (ESD)

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 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: 8.5E+0 kg/site-day over 250 days/yr

from 33 sites

or 7.1E+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
Page 20 of 41

landfill based on the ESD.

Air

Suggested Estimate: 8.5E-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 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 0.05%

with 50% to water and 50% to air.

Air

Output 2: 3.8E-2 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: 3.7E+0 kg/site-day over 250 days/yr from 33

sites

or 3.1E+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 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%.

RELEASE TOTAL

2.0E+5 kg/yr - all sites
Page 21 of 41

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:

During unloading, the PMN is entrained in sheet product.

Therefore, inhalation exposure is not expected from solid

sheet handling.

Exposure to Vapor (Class II)

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 from

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: II. Gas/vapor (all

substances in the gas form).

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

occur, dermal exposure to solids in this form are

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

Screening-Level Assessments of Dermal Exposure).

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0282

PROC3: Formulation of Metalworking Fluids (30% of PV)
Page 22 of 41

Number of Sites/ Location: 110

multiple sites - See Attachment 008 for a full list of

customers across all downstream operations

Days/yr: 38

Basis: Per submission, 110 MWF formulation sites, 38

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 843.29 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) ---> 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 releases

for downstream operations.

Water or Incineration or Landfill

High End: 6.2E+0 kg/site-day over 35 days/yr from 110

sites

or 2.4E+4 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 25.3 kg/day of PMN (25.

3/843 = 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.

Water or Incineration or Landfill

High End: 4.2E+0 kg/site-day over 12 days/yr from 110

sites

or 5.5E+3 kg/yr
Page 23 of 41

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 (1.7/843 = 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 38 days/yr from 110

sites

or 7.0E+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 16.8

kg/day of PMN (16.8/843 = 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 assuming cleaning once per

day.

Air

Output 2: 4.2E-1 kg/site-day over 38 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 estimates 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% release 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

Output 2: 1.7E+1 kg/site-day over 38 days/yr from 110

sites

or 7.0E+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

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
Page 24 of 41

source using the high end estimate with releases to

incineration or landfill.

RELEASE TOTAL

1.7E+5 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 880

Basis: The submission estimates range of 4 to 8

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 38 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 38 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.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0282

USE3: Use of Metalworking Fluids (30% of PV)

Number of Sites/ Location: 776

multiple sites - See Attachment 008 for a full list of

customers across all downstream operations

Days/yr: 247

Basis: Per submission, 28,200 MWF use sites, 300 exposure

days per year, PMN used at 1 - 10% (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: (3,

524,973 kg/yr) / (12,000 gal/site-yr x 1 kg/L x 3.785

L/gal x 0.1) = 776 sites. Environmental releases are of

concern for this PMN. As conservative, CEB assumes 247

days/yr of operation and the ESD estimate of 776 sites to

maximize kg/site-day release. CEB also assumes 10% PMN in

raw material, and 2.5% PMN during metalworking operations.

CS calcualtes a use rate of 18.3907 kg/site-day.
Page 25 of 41

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 776

sites

to: on-site WWTP or POTW (ESD)

from: Dragout Losses

basis: User-Defined Loss Rate Model. The submission

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 estimate 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.

Water or Incineration or Landfill

High End: 6.2E-1 kg/site-day over 218 days/yr from 776

sites

or 1.1E+5 kg/yr

to: water, incineration, or landfill (ESD)

from: Cleaning Liquid Residuals from Drums Used to
Page 26 of 41

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 the use rate derived from the

submission estimate of 29,200 sites) 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 776

sites

or 1.2E+6 kg/yr

to: water, incineration, or landfill (ESD)

from: Filter Media and Other 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, incineration, 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,

or landfill based on uncertainy at multiple downstream

use sites.

Water or Incineration or Landfill

Output 2: 8.2E+0 kg/site-day over 247 days/yr from 776

sites

or 1.6E+6 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 upstream

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 776

sites

to: air (2002 EU RA)

from: Misting/Evaporation

basis: User-Defined Loss Rate Model. The submission
Page 27 of 41

estimates 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

3.5E+6 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 74,496

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: 37,

Basis: Exposure During Metalworking Operation;

User-defined Inhalation Model. The 2011 ESD for MWF

Operations estimates typical mist concentrations ranging

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. CEB assumes the PMN is 25% of the mist.

 (GS assumes that water conc. is 60% and the PMN is then

estimated to be 10/40 = 25% of the mist.

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: 37,248

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT
Page 28 of 41

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: 37,248

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 estimate of dermal exposure during

MWF use due to uncertainty at downstream opeations.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0282

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: 34

Basis: Per submission, 15 formulation sites, 34 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

34 days/yr to maximize kg/site-day releases, 100% PMN in

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

of 460.78 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

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 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

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
Page 29 of 41

Output 2: 2.8E+0 kg/site-day over 34 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 17 days/yr from 15 sites

or 1.6E+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, CEB standard 3%

residual. The submission estimates 13.8 kg/day of PMN (13.

8/460.8 = 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

Conservative: 9.2E+0 kg/site-day over 34 days/yr from 15

sites

or 4.7E+3 kg/yr

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

from: Equipment Cleaning Losses of Liquids from Blending

Tank

basis: EPA/OPPT Multiple Process Vessel Residual Model,

CEB standard 2% residual. The submission estimates 8.3

kg/day of PMN (13.8/460.8 = 1.8%) release to incineration

or landfill from equipment cleaning. 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 using the

EPA/OPPT standard model loss fraction of 2%.

Water or Incineration or Landfill

High End: 4.2E+0 kg/site-day over 6 days/yr from 15 sites

or 3.7E+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 0.9

kg/day of PMN (20.9/460.8 = 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
Page 30 of 41

multiple downstream sites, CEB assesses releases to

uncertain media.

RELEASE TOTAL

8.1E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 225

Basis: The submission estimates 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)

Dermal:

Exposure to Liquid at 100.00% concentration

High End: 1.8E+3 mg/day over 34 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

High End: 7.1E+1 mg/day over 34 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.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0282

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

Number of Sites/ Location: 48

unknown sites

Days/yr: 250

Basis: Per submission, 48 commerical automotive sites,

250 days/yr, PMN in lube oil at 4%. CS calculates 15.6665

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

IRER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources
Page 31 of 41

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

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.

Incineration

Output 2: 1.3E+1 kg/site-day over 250 days/yr from 48

sites

or 1.6E+5 kg/yr

to: incineration or landfill (submission, GS)

from: Spent Oil Disposal

basis: User-Defined Loss Rate Model. The submission

estimates 11.3 kg/site-day of PMN (11.3/15.67 = 72%)

released to incineration and 1.09 kg/site-day of PMN (1.

09/15.67 = 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: 9.4E-2 kg/site-day over 250 days/yr from 48

sites

or 1.1E+3 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

standard 0.6% residual. The submission estimates 0.08

kg/site-day of PMN (0.08/15.67 = 0.5%) 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, CEB

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 48

sites

or 1.4E+4 kg/yr

to: incineration or landfill (submission, GS)

from: Spent Oil Disposal

basis: User-Defined Loss Rate Model. The submission

estimates 11.3 kg/site-day of PMN (11.3/15.67 = 72%)

released to incineration and 1.09 kg/site-day of PMN (1.

09/15.67 = 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,
Page 32 of 41

CEB uses the GS loss rate estimates.

RELEASE TOTAL

1.7E+5 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 240

Basis:

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: 240

Basis: Unloading Liquid Raw Material from Small

Containers; EPA/OPPT 2-Hand Dermal Contact with Liquids

Model.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0282

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: 5

Basis: Per submission, 33 formulation sites, 200-600

kg/bt, 5 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 conservatively

assess exposures. CS calculates 356.06 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
Page 33 of 41

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: 3.6E-2 kg/site-day over 5 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 with 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 2 days/yr from 33 sites

or 4.1E+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 10.7 kg/site-day of

PMN (10.7/356 = 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 model and assesses releases to water,

incineration, or landfill. As conservative, CEB assesses

these releases to water, incineration or landfill.

Water or Incineration or Landfill

High End: 4.2E+0 kg/site-day over 1 day/yr from 33 sites

or 1.4E+2 kg/yr

to: water, incineration, or landfill (ESD)

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 0.71

kg/site-day of PMN (0.71/356 = 0.2%) released to landfill

from drum residuals. This is in agreement with the

EPA/OPPT Bulk Container 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 model and assesses
Page 34 of 41

releases to water, incineration, or landfill. As

conservative, CEB assesses these releases to water,

incineration or landfill.

Water or Incineration or Landfill

Submitter Estimate: 7.1E+0 kg/site-day over 5 days/yr from

33 sites

or 1.2E+3 kg/yr

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

from: Equipment Cleaning Losses of Liquids from Mixing

Vessel

basis: User-Defined Loss Rate Model. The submission

estimates 5.7 kg/site-day of PMN (5.7/365 = 1.6%)

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 a a 2% loss rate.

Incineration or Landfill

Output 2: 3.2E-1 kg/site-day over 5 days/yr from 33 sites

or 5.3E+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 material 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: 3.6E+0 kg/site-day over 5 days/yr from 33 sites

or 5.9E+2 kg/yr

to: incineration or landfill (RM-2, ESD)

from: Filter Media Disposal

basis: User-Defined Loss Rate Model. The submission does

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

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: 1.8E+1 kg/site-day over 5 days/yr

from 33 sites
Page 35 of 41

or 2.9E+3 kg/yr

to: incineration or landfill (RM-2, 2002 EU RA)

from: Spoiled Batches

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 cleaning 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 releases to incineration or landfill.

RELEASE TOTAL

5.3E+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% concentration

High End: 1.8E+3 mg/day over 5 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 5 days/yr

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

Basis: Loading Liquid Product into Small Containers;

EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0282

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

of PV)

Number of Sites/ Location: 117

unknown sites
Page 36 of 41

Days/yr: 251

Basis: Per submission, 117 painting crews, 251 days/yr,

and PMN used at 5-15% (median 10%). CEB assumes 15% to

conservatively assess exposures. CS calculates a use rate

of 2 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 combination 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 177 days/yr from 117

sites

or 3.5E+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 (0.012/2 = 0.6%) released to landfill

from container residuals. 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.

Water or Incineration or Landfill

Conservative: 4.0E-2 kg/site-day over 251 days/yr from 117

sites

or 1.2E+3 kg/yr

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

from: Equipment Cleaning Losses of Liquids from Painting

Equipment

basis: EPA/OPPT Multiple Process Vessel Residual Model,

CEB standard 2% residual. The submission estimates 0.012
Page 37 of 41

kg/site-day of PMN (0.012/2 = 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 251 days/yr from 117

sites

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 spray coating resulting in 10%

releases to air and 90% to landfill.

Landfill

Output 2: 1.4E+0 kg/site-day over 251 days/yr from 117

sites

or 4.0E+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 spray coating resulting in 10%

releases to air and 90% to landfill.

RELEASE TOTAL

4.6E+4 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 702

Basis:

Inhalation:

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
Page 38 of 41

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 250 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 CSR 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 (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 15.00% concentration

High End: 2.6E+2 mg/day over 250 days/yr

Number of workers (all sites) with dermal exposure: 351

Basis: Unloading Liquid Raw Material from Small

Containers; EPA/OPPT 2-Hand Dermal Contact with Liquids

Model.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0282

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 operations

Days/yr: 294

Basis: Per submssion, 11 finishing sites, 294 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 18.1662 kg/site-day.

Process Description: PMN (liquid, 91.5 - 100%) is
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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 estimates 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 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 estimate was chosen when evaluating

releases for downstream operations.

Water

Output 2: 3.6E+0 kg/site-day over 294 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 (3.6/18.7 = 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 6 days/yr from 11 sites

or 4.1E+2 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 0.54 kg/site-day of

PMN (0.54/18.7 = 3%) released to landfill from drum

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

Residual Model. As conservative, CEB assesses these

releases to uncertain media due to uncertainty in

downstream operations.

Water or Incineration or Landfill

High End: 4.2E+0 kg/site-day over 2 days/yr from 11 sites

or 9.2E+1 kg/yr

to: uncertain
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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 0.04

kg/site-day of PMN (0.04/18.7 = 0.2%) released to

landfill from bulk container residuals. This is in

agreement with the EPA/OPPT Drum Residual Model. As

conservative, CEB assesses these releases to uncertain

media due to uncertainty in downstream operations.

RELEASE TOTAL

1.2E+4 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 250 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 250 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.

MEMORANDUM of TELEPHONE CONVERSATION

CALL BY: 

Organizati CEB

CALL TO: Don Stevenson

Organization: Dover Chemical Corporation

Date: 04/26/2012
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Time: 12:30pm

Phone: 330-365-3632

Concerning what TSCA ?

PMN: 12-0282

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 adding 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 our

customers such as use concentration, number of workers,

and number of downstream customers.

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