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INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0433

Standard Review Draft 8/10/2012

ENGINEER: M

PV (kg/yr): 

SUBMITTER: INEOS Chlor Americas

USE: 100% of the notification substance is used as a

lubricant in metal working fluids (MWFs). The

notification substance is blended into the MWFs

OTHER USES: 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 i

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

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.

MSDS: Yes Label: No

Gen Eqpt: If prolonged or excessive skin contact is

likely: Wear suitable protective clothing and gloves. //

If splashing or mist is likely to occur: Wear eye/face

protection.

Respirator: No information provided in MSDS.

Health Effects: Eye: may cause slight eye irritation. //

Skin: unlikely to cause skin irritation in man. //

Ingestion: unlikely to be hazardous if swallowed. //

Inhalation: unlikely to be hazardous by inhalation. //

Chronic Effects: repeated exposure to high levels may

product liver and kidney damage.
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TLV/PEL:

none established

CRSS :

Chemical Name: Alkanes, C18-20, chloro

S-H20: 0.000006 g/L @

VP: 4.0E-6 torr @

MW: 412.00 %<500 %<1000

Physical State and Misc CRSS Info:

Neat: liquid Mfg: liquid Proc/Form: liquid End Use: 15%

in final product. The chlorinated products would range

from C17H31Cl5 (at ~40% chlorination) to C20H34Cl8 (at

~50% chlorination). The parent hydrocarbon had a

measured composition : C17: 17.06% (max 20) C18: 64.71%

(45-70) C19: 13.67% (15-27) C20: 2.13% (4-12) The

chlorination content looks to range between roughly 40 - 

55%.

Consumer Use: No

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: 2C

NOTES & KEY ASSUMPTIONS:

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

PMN is a liquid LCCP product that is imported and used as

a lubricant in metal working fluids // Note, the SAT

information is not yet avaiable for this PMN. // Note,

one of four exposure based criteria were met. // For PROC:

This IRER assesses releases based on information

provided in EU RAs and a CSR provided by the submitter

and EPA/OPPT standard models. Dermal exposures were

assessed and inhalation exposure is expected to negl. (VP

< 0.001 torr). // For USE: This IRER assesses releases

based on the 2011 ESD for the Use of Metalworking Fluids

and EU RAs provided by the submitter. Dermal and

inhalation exposures were assessed per the ESD. // No

same-submitter, same-use past cases were identified. This

IRER uses the same release and exposure assessment

methodology t-submitter, same-use

past cases . The submitter of

this IRER p es that were used in

the assessment of MWF formulation and use for these past

cases and, therefore, this IRER performs an assessment a

similar manner.
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POLLUTION PREVENTION CONSIDERATIONS:

EXPOSURE-BASED REVIEW: Yes (1 criteria met)

1) # of workers exposed: 216 >1000? No

2) >100 workers with >10 mg/day inhalation exposure: No

3) (a) >100 workers w/1-10 mg/day inh. exp. & >100

days/yr: Yes

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

No

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0433

PROC: Formulation of Metalworking Fluids

Number of Sites/ Location: 3

unknown site(s)

Days/yr: 27

Basis: The submission does not provide information on the

number of customers and or use rate of the PMN in MWF

formulation. The submission states that the PMN is

formulated in MWFs at a conc of 10-20% for neat oils and

5% for emulsions with a typical conc of 15%. Based on

different-submitter, same-use past ca P12-0277 for a

similar PMN substance (liquid LCCP), fo es

were estimated for a production volum of .

Using this as a basis, CEB est

on sites for a PV of 

 ~ 3 sites. Batchsize

 Previous larger-scale related PMN submissions

(P-12-0277 and P-12-0357)estimated batchsizes at MW FLuid

formulation sites of greater tha 000 gallons. CEB

ass s a batchsize of at least gallons (equivalent

to kg of PMN chemical at 15% ncentration) to

est te the kg/batch and number of batches.

Process Description: PMN (liquid, 100%) is unloaded

import containers ---> feed into blending tank ---> 

packaging of metal working fluids containing PMN (10-20%

for neat oil and 5% for emulsions) (submission, past Std

Review cases for CPs)

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 data from documents provided by the

submitter as well as EPA/OPPT standard models.
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Water or Incineration or Landfill

High End: 8.6E+0 kg/site-day over 27 days/yr from 3 sites

or 6.9E+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 does not provide information to

estimate releases from container cleaning. Due to

uncertainty at multiple downstream sites, CEB assesses

releases to uncertain media using the standard model loss

fraction of 3%.

Water or Incineration or Landfill

Conservative: 5.7E+0 kg/site-day over 27 days/yr from 3

sites

or 4.6E+2 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%. The submission does not provide

inforamtion to estimates releases from equipoment

cleaning. Due to uncertainty at multiple downstream sites,

CEB assesses releases to uncertain media using the

standard model loss fraction of 2%.

Air

Suggested Estimate: 5.7E-1 kg/site-day over 27 days/yr

from 3 sites

to: fugitive air (2005 EU RA, 20009 EU RA)

from: Fugitive Air Emissions

basis: User-Defined Loss Rate Model. Data from a 2005 EU

RA for MCCP provided by the submitter estimates 16 kg/yr

of MCCP may be released to air from fugitive air

emissions generated by preheating and blen at a

ty l MWF formulation site (16 kg/yr / kg/site-yr

= for the current operations). A 200 RA for

LC provided by the submitter estimates a loss of 58

g/day, assuming 250 days/yr of operation

(14.5/ for current operations). Due to

uncert ple downstream use sites, CEB

includes this release source using the high end estimate.

Incineration or Land

Suggested Estimate: kg/site-day over 27 days/yr

from 3 sites

or 4.6E+2 kg/yr

to: incineration or landfill (2009 EU RA)

from: Off-Spec Material

basis: User-Defined Loss Rate Model. Data from a 2009 EU

RA for LCCPs 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
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includes this release source using the high end estimate

with releases to incineration or landfill.

L 

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 24

Basis: The submission does not provide an estimate for

te. Previous related submissions

indicated 4 to 8 workers per

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 100.00% concentration

High End: 1.8E+3 mg/day over 27 days/yr

Number of workers (all sites) with dermal exposure: 24

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

2-Hand Dermal Contact with Liquids Model.

Exposure to Liquid at 20.00% concentration

High End: 3.5E+2 mg/day over 27 days/yr

Number of workers (all sites) with dermal exposure: 24

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

Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0433

USE: Use of Metalworking Fluids

Number of Sites/ Location: 4

unknown site(s)

Days/yr: 247

Basis: The submission does not provide any information

for end use of MWFs. The submission estimates a typical

conc of PMN in MWFs of 15%. The 2011 ESD for MWF

Operations estimates 247 days/yr of

s.

 PMN. As

conservative, CEB assumes 247 days/yr of operation and

the ESD estimate of 4 sites. CEB also assumes up to 20%

PMN in raw material, and 2% PMN during m king

operations. CS calcualtes a use rate of 

kg/site-day.
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Process Description: Bulk MWF containing PMN (liquid,

10-20 percent neat oil or 5% emulsion) is unloaded from

transport containers ---> transfer to mixing vessel ---> 

dilution of MWF ---> diluted MWF containing PMN (liquid,

assume 1-2% for neat oil and 0.5% for emulsion assuming a

10 fold dilution) transferred to metal shaping trough

---> metal shaping operation ---> shaped metal part is

rinsed and dried ---> spent MWF is drained and discarded

(submission, ESD, past std review cases for CPs)

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

data provided in reports provided by the submitter as

well as the 2011 ESD for the Use of Metalworking Fluids.

Water

Output 2: kg/site-day over 247 days/yr from 4 sites

to: on-sit or POTW (ESD)

from: Dragout Losses

basis: User-Defined Loss Rate Model. A 2005 EU RA for

MCCPs and a 2009 EU RA for LCCPs provided by the

submission 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. 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.

The data from the 2011 ESD is most representative of U.S.

industry and is therefore used as the basis for releases.

Water or I ation or Landfill

Hig kg/site-day over 139 days/yr from 4 sites

or 

to: , 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 does not provide estimates for

releases during MWF use. Due to uncertainty at multiple

downstream sites, these releases are assessed to

uncertain media using a 3% loss rate per the ESD.
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Water or I ation or Landfill

Out kg/site-day over 247 days/yr from 4 sites

or 

to: , incineration, or landfill (ESD)

from: Filter Media and Other Recycling Waste

basis: User-Defined Loss Rate Model. 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 I ation or Landfill

Out kg/site-day over 247 days/yr from 4 sites

or 

to: , incineration, or landfill (ESD)

from: Spent Metalworking Fluid

basis: User-Defined Loss Rate Model. 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: kg/site-day over 247 days/yr from 4 sites

to: air (2 RA)

from: Misting/Evaporation

basis: User-Defined Loss Rate Model. A 2005 EU RA for

MCCP and a 2009 EU RA for LCCPs provided by the submitter

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.

E TOTAL

 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 192

Basis: The 2011 ESD for MWF Use estimates 48 workers/site.

. 

Inhalation:
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Exposure to Mist (non-volatile) (Class I)

Typical: 2.0E+0 mg/day over 247 days/yr

High End of Range: 7.1E+0 mg/day over 247 days/yr

Number of workers (all sites) with inhalation exposure:

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 water portion is 60% of

fluid. Based on up to 20$ concentration of PMN chemical

in the neat fluid, the concentration of the PMN chemical

in the mist could be as high as 50% (20%/40%). Note, a

2005 EU RA for MCCPs and a 2009 EU RA for LCCPs 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 20.00% concentration

High End: 3.5E+2 mg/day over 247 days/yr

Number of workers (all sites) with dermal exposure: 192

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

2-Hand Dermal Contact with Liquids Model.

Exposure to Mist at 20.00% concentration

Output 1: 3.9E+3 mg/day over 247 days/yr

Number of workers (all sites) with dermal exposure: 192

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
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MWF use due to uncertainty at downstream opeations. CEB

conservatively assessed straight oil where Fchem_trough =

Fchem_neat

MEMORANDUM of TELEPHONE CONVERSATION

CALL BY: 

Organizati CEB

CALL TO: 

Organization: 

Date: 04/26/2012

Time: 12:30pm

Phone: 

Concerning what TSCA ?

PMN: 

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.