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INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0284

Standard Review Draft 5/15/2012

ENGINEER: 

PV (kg/yr):

Revision Notes / Assessment Overview: This version is the

CEB Reviewed Draft version of the engineering report. 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: 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
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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: 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: Octadecane, chloro

S-H20: 0.000005 g/L @

VP: 1.0E-6 torr @

MW: 358.00 %<500 %<1000

Physical State and Misc CRSS Info:

Neat: liquid Mfg: liquid Proc/Form: liquid End Use: 100%
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in final product. The chlorinated products would range

from C18H35Cl3 (at ~30% chlorination) to C18H20Cl18 (at

~70% chlorination).

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: 2D

NOTES & KEY ASSUMPTIONS:

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

PMN is a MCCP product that is manufactured domestically

and used as a lubricant in metal working fluids (MWFs).

// Note, the SAT information is not yet avaiable for this

PMN. // For MFG: Submitter estimates were used for

assessing releases and dermal exposure was assessed using

standard models. // For downstream processing and use

operations: The releases estimates were based on a

combination of submitter provided data and data available

in various literature sources. The literature sources

include those previous review by EPA as well as Generic

Scenarios and Emission Scenario Documents. The submitter

has stated that "Due to the large number of customers and

potential sites where the notification substances may be

used, 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)

1) # of workers exposed: 17,668 >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
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INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0284

MFG: Batch Manufacturing of PMN

Number of Sites/ Location: 1

Dover Chemical Corporation Dover OH 44622

Days/yr: 3

Basis: Per submission, 1 submitter site, 3 bt/yr, 22

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

100%. CEB uses 3 bt/yr as a basis and assumes PMN is

produced as liquid at 100% to conservatively assess

exposures. CS calculates 15,166.67 kg/bt.

Process Description: 1-octadecene 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. The submission provides releases

estimates for filter disposal and equipment cleaning.

Filter disposal releases are expected to landfill while

equipment cleaning releases are expected to incineration

or landfill. The equipment cleaning releases were

estimated by the submitter to be 2.7% of the total PV

which is equivalent to the CEB standard model loss rate.

Filter disposal was estimated by the submitter to account

for 0.011% of the total PV.

Incineration or Landfill

Submitter Estimate: 4.1E+2 kg/site-day over 1 day/yr from

1 site

or 4.1E+2 kg/yr

to: incineration or landfill (submission)

from: Equipment Cleaning Losses of Liquids from Multiple

Vessels

basis: User-Defined Loss Rate Model. 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 2.7% which is more

conservative than the standard model loss fraction. CEB

assesses equipment cleaning residual releases to 
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incineration or landfill using the submission estimated

loss rate of 2.7%.

Landfill

Output 2: 2.2E+0 kg/site-day over 3 days/yr from 1 site

or 6.8E+0 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

4.2E+2 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 3 days/yr

Number of workers (all sites) with dermal exposure: 4

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 3 days/yr

Number of workers (all sites) with dermal exposure: 4

Basis: Loading Liquid Product into Transport Containers;

EPA/OPPT 2-Hand Dermal Contact with Liquids Model.
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INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0284

PROC1: Formulation of Metalworking Fluids

Number of Sites/ Location: 24

multiple sites - See Attachment 008 for a full list of

customers across all downstream operations

Days/yr: 3

Basis: Per submission, 24 MWF formulation sites, 3 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 631.94 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 2 days/yr from 24 sites

or 3.0E+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 19 kg/day of PMN

(19/632= 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 1 day/yr from 24 sites
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or 10.0E+1 kg/yr

to: uncertain

from: Cleaning Liquid Residuals from Totes, Tank Trucks,

and Rail Cars Used to Transport the Raw Material

basis: EPA/OPPT Bulk Transport Residual Model, CEB

standard 0.2% residual. The submission estimates 1.26

kg/day of PMN (1.26/632 = 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: 1.3E+1 kg/site-day over 3 days/yr from 24

sites

or 9.1E+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% residual. The submission estimates 12.64

kg/day of PMN (12.64/632 = 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

Suggested Estimate: 3.2E-1 kg/site-day over 3 days/yr from

24 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

Suggested Estimate: 1.3E+1 kg/site-day over 3 days/yr from

24 sites

or 9.1E+2 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
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multiple downstream use sites, CEB includes this release

source using the high end estimate with releases to

incineration or landfill.

RELEASE TOTAL

2.2E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 192

Basis: The submission estimates up to 8 workers/site. As

conservative, CEB assesses all 8 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 3 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 Liquid at 10.00% concentration

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

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

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

Dermal Contact with Liquids Model.
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INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0284

USE1: Use of Metalworking Fluids

Number of Sites/ Location: 10

multiple sites - See Attachment 008 for a full list of

customers across all downstream operations

Days/yr: 247

Basis: Per submission, 364 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: (45,

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

0.1) = 10 sites. Environmental releases are of concern

for this PMN. As conservative, CEB assumes 247 days/yr of

operation and the ESD estimate of 10 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 18.4211 kg/site-day.

Process Description: Bulk MWF containing PMN (liquid,

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

---> transfer to mixing vessel ---> dilution of MWF ---> 

diluted MWF containing PMN (liquid, 1.25 - 2.5%, median 1.

875%) transferred to metal shaping trough ---> metal

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

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

ESD)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources

to the same medium. The releases estimates were based on

a combination of submitter provided data and data

available in various literature sources. A description of

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

The submitter has stated that "Due to the large number

of customers and potential sites where the notification

substances may be used, specific use information for each

site could not be obtained. Rather, these worker

exposures and environmental releases scenarios are

average scenarios for each particular use." Due to the

uncertainty at multiple downstream use sites, the most

conservative data were chosen when evaluating releases

for downstream operations.

Water

Output 2: 2.0E+0 kg/site-day over 247 days/yr from 10

sites

to: on-site WWTP or POTW (ESD)

from: Dragout Losses

basis: User-Defined Loss Rate Model. The submission
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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. // NOTE

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

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

chemical waste and grinding swarf dragout is estimated to

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

2010 EU CSR for MCCPs estimates overall process losses to

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

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

therefore used as the basis for releases.

Water or Incineration or Landfill

High End: 6.2E-1 kg/site-day over 219 days/yr from 10

sites

or 1.4E+3 kg/yr

to: water, incineration, or landfill (ESD)

from: Cleaning Liquid Residuals from Drums Used to

Transport the Raw Material

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

residual. The submission estimates 0.15 kg/site-day of

PMN (~3% based on 364 sites estimated by the submitter)

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 10

sites

or 1.6E+4 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,
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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 10

sites

or 2.0E+4 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 10

sites

to: air (2002 EU RA)

from: Misting/Evaporation

basis: User-Defined Loss Rate Model. The submission

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

4.5E+4 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 480

Basis: The submission estimates up to 9 workers/site. The

2011 ESD for MWF Use estimates 48 workers/site. CEB

assesses 48 workers/site as conservative, due to

uncertainty at downstream use sites.

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:
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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 and a PMN concentration of 25% in the

mist. (PMN at 10% concn. and assuming 60% water per GS)

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

mist concentrations from 1.6 to 3.4 mg/m3 based on the

95th percentile of data collected in the EU for oil-based

and water-based fluids. The data from the 2011 ESD are

more representative of U.S. operations since the data

were collected in the U.S.

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

solid or liquid droplets).

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit

 or data not specific to industry): Yes

2)a) Exposure level > 1 mg/day? Yes

 OR

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

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Exposure to Liquid at 10.00% concentration

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

Number of workers (all sites) with dermal exposure: 480

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

2-Hand Dermal Contact with Liquids Model.

Exposure to Mist at 2.50% concentration

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

Number of workers (all sites) with dermal exposure: 480

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.
Page 13 of 13

MEMORANDUM of TELEPHONE CONVERSATION

CALL BY: 

Organizati CEB

CALL TO: Don Stevenson

Organization: Dover Chemical Corporation

Date: 04/26/2012

Time: 12:30pm

Phone: 330-365-3632

Concerning what TSCA ?

PMN: 12-0284

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.