### Page 1 of 21

INITIAL REVIEW ENGINEERING REPORT

PMN: 12

- 0453

Standard Review Draft 8/10/2012

ENGINEER: M

PV (kg/yr):

Revision Notes / Assessment Overview: The assessment of

this PMN is based on data provided by the submitter as

well as data that was collected during EPA previous

efforts to assesses environmental releases and

occupational exposures during the manufacturing,

processing, and use of MCCPs and LCCPs. Additional

literature sources that have been revie wed 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 the submitter, 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

occupational exposures.

SUBMITTER: Ineos

USE: 1) Seventeen percent (17%) of the notification

substances are used as a flame retardant/plasticizer in

polymers. Typical concentration in the plastic is 15%.

2) Seventy

- four percent (74%) of the notification

substance is used as a lubricant in metal working fluids

(MWFs). The notification substance is blended into the

MWFs at 15%. 3) Two percent (2%) of the notification

substances is used as lubricants in sealants (formulated

at 10%); and finally 4) Seven percent (7%) of PV is used

as plasticizer in adhesives at about 20% formulation.

OTHER USES: Generic uses MCCP based on open lit & other

PMN submissions : 1) used as lubricants in automotives.

The notification substance i blended into the lubricant

at 4%. [20% consumer uses]. 2) used as a flame

retardant/plasticize r in rubber. Typical total

concentration of flame retardant/plasticizer in the

rubber is 1

- 10%, 3) used as a plasticizer in solvent

based paints, adhesives and sealants. The paints can be

specialty paints for applications where weather resistant

coatin gs are needed, such as steel construction,

industrial flooring, road marking, and swimming pools.

Often blended into the paints at 5

- 15%. 4) One

- half of

one percent of the notification substances are applied as

a flame retardants/waterproofers to textiles . Can be at

5% of the textile coating finishing solution.

MSDS: Yes Label: No

### Page 2 of 21

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.

Health Effects: Eye: Contact with eyes may cause

irritation // Skin: Unlikely to cause skin irritation //

Inhalation: Unlikely to be hazardous by inhalation. //

Ingestion: Unlikely to be hazardous if swallowed. //

Chronic Effects: repeated exposure to high levels may

produce live and kidney damage.

TLV/PEL:

none established

CRSS :

Chemical Name: Alkanes, C14

- 17, chloro

S

- H20: 0.00003 g/L @

VP: 2.0E

- 5 torr @

MW: 336.00 %<500 %<1000

Physical State and Misc CRSS Info:

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

- 20% in final product. The average molecular formula would

range from C14H26Cl4 ( LOWWT at ~40% chlorination) to

C17H26Cl10

high wt (at ~ 60% chlorination).

C# : % (range) C14: 36 (30

- 40); C15: 30 (25

- 35);

C16: 24 (20

- 30); and C17: 10 (8

- 18) ChemSpider EPI est

for 1,2

- dichlorotetradecane : BP 339 / VP < 1 E

- 3 mm

Hg / s

- H2O < 6 E

- 6 g/L P

- Chem values reported are est /

measured s upplied by INEOS

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: 2

- 3D

NOTES & KEY ASSUMPTIONS:

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

PMN is a MCCP product that is imported and used in the

following applications: 1) 16.8%as a plasticiser in PVC

production 2) 78.3 % as a lubricant in metal working

fluids (MWFs) 3) 7.4% used in adhesives and 4) 2% used

in sealants // Note, the SAT information is not yet

avaiable for this PMN. // For downstream processing and

### Page 3 of 21

use operations: The releases estimates were based on a

combination of submitter provided data and data ava ilable

in various literature sources. The literature sources

include those previous review by EPA as well as Generic

Scenarios and Emission Scenario Documents. Many of the

sources reviewed by EPA were also provided by the

submitter (2005 EU RA on MCCPs, 2010 CSR). Due to the

uncertainty at multiple downstream use sites, the most

conservative data were chosen when evaluating releases

for downstream operations. This assessmet approach is

consistent with the approached used for previous standard

g

. This

ion and

use which is a use that was not listed in the previous

assessments. The formulation of adhesives/sealan ts

assessment was based on information provided in sources

from the submitter and the 2009 ESD for the Formulation

of Adhesives. The end use of adhesives/sealants was based

on the 2008 ESD for the Use of Adhesives. // Note, all

exposure

- based criteria were met.

POLLUTION PREVENTION CONSIDERATIONS:

EXPOSURE

- BASED REVIEW: Yes (3 criteria met)

1) # of workers exposed: 13,834 >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: Y es

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

Yes

INITIAL REVIEW ENGINEERING REPORT

PMN: 12

- 0453

PROC1: Formulation of Metalworking Fluids (73.8% of PV)

Number of Sites/ Location: 59

unknown site(s)

Days/yr: 84

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. Based on different

- submit ter, me

- use

PV of

~ 59 sit

### Page 4 of 21

assumes at least a mixing l to estimate

daily throughput of cal of and 84 days/yr.

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

import containers

--- > feed into blending t ank --- >

blending

--- > packaging of metal working fluids

containing PMN (10

- 20% for neat oils, 5% for emulsions)

(submission, CRSS, previous Std Review past cases for

MCCPs)

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.

Due to the uncertainty at multiple downstream use sites,

the most conservative data were chosen when evaluating

releases for downstream operations.

Water or I ation or Landfill

Hig kg/site

- day over 84 days/yr from 59 sites

or

to: tain

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 an estimate for

rel eases from drum residuals. Due to uncertainty at

multiple downstream sites, CEB assesses releases to

uncertain media using the EPA/OPPT Drum residual model.

Water or Incin n or Landfill

Conservative: kg/site

- day over 84 days/yr from 59

sit

o r kg/yr

to: tain

from: Equipment Cleaning Losses of Liquids from a Mixing

Tank

basis: EPA/OPPT Multiple Process Vessel Residual Model,

CEB standard 2% residual. The submission does not provide

an estimate for releases from equipment cleaning. Due to

uncertainty at multiple downstream sites, CEB assesses

releases to uncertain media using the EPA/OPPT Multiple

Vessel Model.

Air

Suggested Estimate: kg/site

- day over 84 days/yr

from 59 sites

to: fugitive air (2005 EU RA from submission, 2010 Japan

RA)

from: Fugitive Air Emissions

basis: User

- Defined Loss Rate Model. Data from a 2005 EU

### Page 5 of 21

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

of MCCP may be released to air from fugitive air

emissions generated by preheating and blending at a

ty pical MWF formulation site (16kg/yr / 31,850 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 based on the 2005 EU RA.

Incineration or Land

Suggested Estimate: kg/site

- day over 84 days/yr

fro ites

or kg/yr

to: eration or landfill (2005 EU RA from submission)

from: Off

- Spec Material

basis: User

- Defined Loss Rate Model. Data from a 2005 EU

RA for MCCPs provided by the submitter 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 rel ease source using the

high end estimate with releases to incineration or

landfill.

RELEASE TOTAL

1.3E+5 kg/yr

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 472

Basis: The submission does not provide a n estimate for

te. Previous related submissions

dindicated 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 84 days/yr

Number of workers (all sites) with dermal exposure: 472

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 84 days/yr

Number of workers (all sites) with dermal exposure: 472

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

- Hand

Dermal Contact with Liquids Model.

### Page 6 of 21

INITIAL REVIEW ENGINEERING REPORT

PMN: 12

- 0453

USE1: Use of Metalworking Fluids (73.8% of PV)

Number of Sites/ Location: 207

unknown sites

Days/yr: 247

Basis: The submission does not provide an estimates for

the number of metalworking fluid use sites. The 2011 ESD

for MWF Operations estimates 247 days/yr of opera tion.

The Assuming imates the number

of sites as: gal/site

- yr x 1

kg/L x 3.785 nvironmental

releases are of concern for this PMN. As conservative,

CEB assumes 247 days/yr of operation and the ESD estimate

of 207 sites to maximize kg/site

- day release. CEB assumes

up to 20% PMN in raw material for straight oils. Per ESD,

straight oils are not expected to be diluted prior to

MWF use; therefore, CEB assumes 20% PMN d se to

maximize exposure to mist. CS calculates

kg/site

- day.

Process Description: Bulk MWF containing PMN (liquid,

10

- 20% for neat oils, 5% for emulsions) is unloaded from

transport containers

--- > transfer to mixing vessel

--- >

dilution of MWF

--- > dil uted MWF containing PMN (liquid,

10

- 20% for straight oil, assume 10

- fold dilution for

water

- based emulsions, 0.5%) transferred to metal shaping

trough

--- > metal shaping operation

--- > shaped metal

part is rinsed and dried

--- > spent MWF is drained and

dis carded (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 su bmitter provided data and 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 evalua ting

releases for downstream operations.

Water

Output 2: kg/site

- day over 247 days/yr from 207

sites

to: on

- site WWTP or POTW (ESD)

from: Dragout Losses

basis: User

- Defined Loss Rate Model. 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

### Page 7 of 21

2010 EU CSR for MCCPs estimates overall process losses to

be 1 to 6% with releases to water. The 2011 ESD for MWF

Operatio ns 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 I ation or Landfill

High End: kg/site

- day over 218 days/yr from 207

sit

or kg/yr

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 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 I ation or Landfill

Output 2: kg/site

- day over 247 days/yr from 207

sit

or kg/yr

to: , 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 I ation or Landfill

Output 2: kg/site

- day over 247 days/yr from 207

sit

or kg/yr

to: , incineration, or landfill (E SD)

from: Spent Metalworking Fluid

basis: User

- Defined Loss Rate Model. The submission

assesses the remaining fluid to POTW from spent MWF

### Page 8 of 21

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 as sesses 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 207

sites

to: air (2005 EU RA from submi ssion)

from: Misting/Evaporation

basis: User

- Defined Loss Rate Model. A 2005 EU RA for

MCCP 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 downs tream 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.

L

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 9,936

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

Inhalation:

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 24 7 days/yr

Number of workers (all sites) with inhalation exposure: 9,

Basis: Exposure During Metalworking Operation;

User

- defined Inhalation Model. A 2005 EU RA for MCCPs

provided by the submitter 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.The 2011 ESD for MWF Operations

estimates typical mist con centrations 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

N IOSH from 942 machinists at 79 shops across the U.S. A

range of inhalation exposure estimates are based the high

### Page 9 of 21

end for the range of geometric means and 90th percentiles.

For water

- based fluids, the PMN chemical could be as

high as 50% of the mist (20% neat concentration/40%

non

- water per generic scenario). Therefore,

concentrations are estimated to range from (0.5 x 0.39) =

0.195 mg/m3 to (0.5 x 1.42) = 0.71 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 grea ter? 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: 9,936

Basis: Unloading Liquid Raw Ma terial 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: 9,936

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 operations. CEB

conservatively assumed straight oil where Fchem_trough =

Fchem_neat.

INITIAL REVIEW ENGINEERING REPORT

PMN: 12

- 0453

PROC2: PVC Compounding (16.8% of PV)

Number of Sites/ Location: 8

unknown site(s)

Days/yr: 126

Basis: Per submission, PMN is used at 100% and is present

in compounded PVC at ies of

recent related estimated

an average of k in per

site

- yr for th category. CEB estimates 8 use sites

### Page 10 of 21

based on this data. These same cases also estimated

average kg/site

- day for the chlorinated paraffin of

kg/site

- da ed on the PV for this use category,

sites and kg/site

- day, CEB estimates 126

days/site

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

transport containers into feeder

--- > feed into

mechanical mixer

--- > extrusion, injection molding,

calendaring or other process to form compounded shapes (i.

e pellets, sheets)

---- > PMN (solid, 15%) charged to bulk

container (GS)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

may coincide wit h 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.

Due to the uncertainty at multiple downstream use sites,

the most conservative data was chosen when evaluating

releases for downstream operations.

Water

Output 2: kg/site

- day over 126 days/yr from 8 sites

to: water (GS)

from: Fugiti ve Air Emissions During High Temperature

Extrusion

basis: User

- Defined Loss Rate Model. 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 I ation

Out kg/site

- day over 126 days/yr from 8 sites

or

to: or incineration (GS)

from: Equipment Cleaning Losses of Liquids from

Compounding Equipment

basis: User

- Defined Loss Rate Model. 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.

Water or I ation or Landfill

Out kg/site

- day over 126 days/yr from 8 sites

or

to: , incineration, or landfill (GS)

from: Cleaning Liquid Residuals from Drums Used to

Transport the Raw Material

basis: User

- Defined Loss Rate Model. The 2004 GS for

### Page 11 of 21

Plastics Compounding estimates a loss rate of 3% based on

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

incineration, or landfill.

Water or Incinera r Landfill

Suggested Value: kg/site

- day over 126 days/yr from

8 s

or kg/yr

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

from: Spillage During Raw Material Handling

basis: User

- Defined Loss Rate Model. A 2005 EU RA for

MCCPs provided by the submitter and the 2004 ESD for

Plastic Compounding estimates a loss rate of 0.01% from

spillage during raw material handling with releases to

water, incineration, or landfill.

Air

Output 2: kg/site

- day over 126 days/yr from 8 sites

to: water (GS)

from: Fugitive Air Emissions During High Temperature

Extrusion

basis: User

- Define d Loss Rate Model. 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.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 192

Basis: The GS for Plastics Compounding estimates 24

workers/site.

Inhalation:

Exposure to Particulate (Class I)

Low End of Range: 3.0E

- 2 mg/day over 126 days/yr

High End of Range: 4.4E+0 mg/day over 126 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 provided by the

submitter contains monitoring data from plastic

compou nding operations is the EU. The monitoring data is

based on 32 air samples from 4 sites. 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

### Page 12 of 21

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

Inha lation 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 126 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.

INITIAL REVIEW ENGINEERING REPORT

PMN: 12

- 0453

USE2: PVC Converting (16.8% of PV)

Number of Sites/ Location: 8

unknown sites

Days/yr: 250

Basis: Per submission, the upstream compounding process

yields PVC containing 15% PMN. CEB assumes the numberof

converting sites is equal to the number of compounding

sites and estimates up to 250 days/suite

- es timate a

daily throughput for the PMN chemical of /site

- day.

Process Description: PVC pellets or other solid form

containing PMN (solid, 15%) 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

### Page 13 of 21

may coincide with daily releases from the other sour ces

to the same medium. 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 conservati ve data were chosen when evaluating

releases for downstream operations.

Water

Suggested Estimate: kg/site

- day over 250 days/yr

from 8 sites

to: water or air (ESD, 2010 CSR and 2005 EU RA provided

by the submitter)

from: Fugitive Air Emissions Durin g Forming and Molding

basis: User

- Defined Loss Rate Model. Data from sources

provided by the submitter 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 Incineratio andfill

Suggested Estimate: kg/site

- day over 250 days/yr

fro tes

or kg/yr

to: , incineration, or landfill (2010 CSR provided

by the submitter)

from: Spillage During Raw Material Handling

basis: User

- Defined Loss Rate Model. A 2010 EU CSR

assessment on MCCPs provided by the submitter estimated

these releases to be 0.01% of PV with releases to water

or solid waste.

Wate r or I ation or Landfill

Out kg/site

- day over 250 days/yr from 8 sites

or

to: , 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 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 Incin n or Landfill

Conservative: kg/site

- day over 250 days/yr from 8

sit

or kg/yr

### Page 14 of 21

to: water, incineration, or landfill (ESD)

from: Equipment Cleaning Losses from Multiple Vessels

basis: EPA/OPPT Multiple Process Vessel Residual Mod el,

CEB standard 2% residual. 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: kg/site

- day over 250 days/yr

fro tes

or kg/yr

to: or landfill (ESD)

from: Scrap Material

basis: User

- Defined Loss Rate Model. A 1992 RM -2

assessment for SCCPs estimated scrap from trimming to be

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

2004 ESD for Plastics Converting estimated these releases

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

is based on the assumption that large pieces of scrap

material will be disposed to landfill via solid waste and

dust generated during trimming will settle to the floor

and be washed away to wastewater during cleaning. Due to

multiple unknown downstream sites, CEB conservatively

assesses a 2.5% loss rate with releases to water or

landfill based on the ESD.

Air

Suggested Estimate: kg/site

- day over 250 days/yr

from 8 sites

to: water or air (ESD, 2010 CSR and 2005 EU RA provided

by the submitter)

from: Fugitive Air Emissions During Forming and Molding

basis: User

- Defined Loss Rate Model. Data from sources

provided by the submitter sug gests 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: kg/site

- day over 250 days/yr from 8 sites

to: air or ill w/ 99% dust removal efficiency (RM

- 2)

from: Dust Generation During Trimming

basis: User

- Defined Loss Rate Model. A 1992 RM -2

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

plastic produ ced with 1% of releases to air and 99% to

landfill based on a 99% dust collection efficiency. Based

on a MCCP concentration of 15%, the loss rate for PMN

### Page 15 of 21

during plastic converting is 75g/kg of plastic x 0.15 =

11.25 g/kg of plastic, or 1.125%.

Landfill

Out kg/site

- day over 250 days/yr from 8 sites

or

to: r landfill w/ 99% dust removal efficiency (RM

- 2)

from: Dust Generation During Trimming

basis: User

- Defined Loss Rate Model. 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 15%, the loss rate for PMN

during plastic converting is 75g/kg of plastic x 0.15 =

11.25 g/kg of plastic, or 1.125%.

E TOTAL

kg/yr

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 384

Basis: 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)

EU Data from Submitter: 1.2E+1 mg/day over 250 days/yr

OSHA PEL: 2.2E+1 mg/day over 250 days/yr

Number of workers (all sites) with inhalation exposure:

Basis: Inhalation Exposure During Converting Process;

User

- defined Inhalation Model. A 2005 EU RA on MCCPs and

a 2010 EU CSR on MCCPs provided by the submitter contains

monitoring data from PV C 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

da ta 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 0.15 = 2.25 mg/m3).

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

solid or liquid droplets).

INHALATION MONITORING DATA REVIEW

1 ) Uncertainty (estimate based on model, regulatory limit

### Page 16 of 21

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, C EB Method

for Screening

- Level Assessments of Dermal Exposure).

INITIAL REVIEW ENGINEERING REPORT

PMN: 12

- 0453

PROC3: Formulation of Adhesives and Sealants (9.4% of PV)

Number of Sites/ Location: 3

unknown site(s)

Days/yr: 200

Basis: The submission estimates 5% PMN in adhesives and

10

- 30% in sealants. The 2009 ESD for the Formulation of

Adhesives an adhesive production rate of 17,000,000

kg/site

- yr for large sites and 1,600,000 kg/site

- yr for

small sites. CEB assumes small sites based on production

volume of PMN. Assuming 5% conc to maximize the number of

site ites

as: ~ 3

site as

follows: = 400 bt/yr.

CEB assum vely assess

exposures. CS calculates a use rate of kg/bt.

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

containers

--- > transfer to mixing vessel --- > mixing

assuming unsealed process

--- > PMN (5% in adhesives,

10

- 30% in sealants) packaged for shipment to customers

(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 sources provided by the submitter and

estimates from the 2009 ESD for Adhesive Formulation. Due

to the uncertainty at multiple downstream use sites, the

most conservative data were chosen when evaluating

releases for downstream operations.

### Page 17 of 21

Water or I ation or Landfill

Hig kg/site

- day over 200 days/yr from 3 sites

or

to: , incineration, or landfill (ESD)

from: Cleani ng Liquid Residuals from Drums Used to

Transport the Raw Material

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

residual. The 2009 GS for Adhesive Formulation assesses

container residuals to uncertain media using the drum

residual model.

Water or I ation or Landfill

Out kg/site

- day over 200 days/yr from 3 sites

or

to: , incineration, or landfill (2005 EU RA from the

submitter, ESD)

from: Equipment Cleaning Losses of Liquids from Blending

Tank

basis: User

- Defined Loss Rate Model. A 2005 EU RA for

MCCPs provided by the submitter estimates a loss rate of

up to 5% from equipment cleanout with releases to

incineration or landfill. The 2009 GS for Adhesives

Formulation assesses equipment cleaning wastes to

uncertain med ia using a 2% loss fraction.

Water or I ation or Landfill

Out kg/site

- day over 4 days/yr from 3 sites

or

to: , incineration, or landfill (ESD)

from: Off

- Spec Material

basis: User

- Defined Loss Rate Model. The 2009 ESD fo r

Adhesive Formulation estimates releases from off

- spec

batches with 1% of batches being off

- spec and released to

water, incineration, or landfill. is equal to (400

bt/site

- yr x 0.01) = 4 bt/yr. At /bt and 1

off

- spec bt/day, it is assumed th kg/site

- day

will be released over 4 days/yr.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 66

Basis: The 2009 ESD for Adhesive Formulation estimates 22

workers/s ite exposed during formulation.

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

### Page 18 of 21

Exposure to Liquid at 100.00% concentration

High End: 1.8E+3 mg/day over 200 days/yr

Number of workers (all sites) with dermal exposure: 66

Basis: Unloading Liquid Raw Ma terial from Drums; EPA/OPPT

2- Hand Dermal Contact with Liquids Model.

Exposure to Liquid at 30.00% concentration

High End: 5.3E+2 mg/day over 200 days/yr

Number of workers (all sites) with dermal exposure: 66

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

- Hand

Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT

PMN: 12

- 0453

USE3: Use of Adhesives and Sealants (9.4% of PV)

Number of Sites/ Location: 58

unknown sites

Days/yr: 250

Basis: The submission estimates 5% PMN in adhesives and

10

- 30% in sealants. The 2008 ESD for Adhesives Use

estimates a default adhesive use rate of 13,504

kg/site

- yr. Assuming 30% conc to maximize t se per

mates as:

) ~ 58 sit is a

m formulators. The ESD

estimates 250 days/yr. CS calculates a use rateof 16.5071

kg/site

- day.

Process Description: PMN (5% in adhesive, 10

- 30% in

sealants) unloaded from containers

- -- > dilute and mix

(optional)

--- > transfer to application resevoir or

apparatus

--- > apply adhesive/sealant to substrate

--- >

drying/curing

--- > product finishing (optional) (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 2008 ESD for Adhesives Use is

used as a basis for estimating releases from the

industrial use of adhesives and sealants.

Water or I

igh End:

7.2E+3

: 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 2008 ESD for Adhesives Use estimates

releases from container cleaning to uncertain media using

the 3% drum residual model.

### Page 19 of 21

Water or Incin n or Landfill

Conservative: kg/site

- day over 250 days/yr from 58

sit

or kg/yr

to : , incineration, or landfill (ESD)

from: Equipment Cleaning Losses of Liquids from Multiple

Vessels

basis: EPA/OPPT Multiple Process Vessel Residual Model,

CEB standard 2% residual. The 2008 ESD for Adhesives Use

estimates releases from equipment cleaning to uncertain

media using the 2% multiple equipment residual model.

Air

Output 2: kg/site

- day over 250 days/yr from 58

sites

to: air (90%) or landfill (10%) (model)

from: Application Losses

basis: EPA/OPPT Automobile Refinish Coating Overspray

Loss Model (non

- volatiles). The submission does not

provided information as to the type of end use

applications for adhesives and sealants containing the

PMN. They only indicate that they are for industrial

applications. As conservative, CEB assumes adhesives and

sealants will be spray applied and uses the

autorefinishing spray model with a transfer efficiency of

25% and a filter capture efficiency of 90% which is

consistent with the 2008 ESD for Adhesives Use.

Landfill

Output 2: kg/site

- day o ver 250 days/yr from 58

sit

or kg/yr

to: 0%) or landfill (10%) (model)

from: Application Losses

basis: EPA/OPPT Automobile Refinish Coating Overspray

Loss Model (non

- volatiles). The submission does not

provided information as to the type of end use

applications for adhesives and sealants containing the

PMN. They only indicate that they are for industrial

applications. As conservative, CEB assumes adhesives and

sealants will be spray applied and uses the

autorefinishing spray model with a tran sfer efficiency of

25% and a filter capture efficiency of 90% which is

consistent with the 2008 ESD for Adhesives Use.

E TOTAL

kg/yr

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 2,784

Basis: The most recent version of the ESD for Adhesives

Use (2012) estimates 26 to 90 workers/site exposed for

### Page 20 of 21

depending on end use market. The average for the 5 end

use markets covered in the scenario is 48 workers per

site.

Inhalation:

negligible (VP < 0.001 torr)

Exposure to Mist (non

- volatile) (Class I)

What

- If: 2.3E+1 mg/day over 250 days/yr

Number of workers (all sites) with inhalation exposure: 2,

Basis: Application Losses; EPA/OPPT Automobile OEM Spray

Coating Inhalation Model (non

- volatile

non

- po lyisocyanates). The 2008 ESD for Adhesives Use

recommends using the automobile OEM spray coating model

to assess inhalation exposure during spray coating.

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? N o

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Exposure to Liquid at 30.00% concentration

High End: 5.3E+2 mg/day over 250 days/yr

Number of workers (all sites) with dermal exposure: 2,784

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:

Organization: INEOS Chlor Americas

Date: 07/23/2012

Time: 10:00am

### Page 21 of 21

Phone:

Concerning what TSCA

PMN: 12

- 0453

Q1: Can you provide clarification on whether the PMN is

imported as formulated product or if it is imported as

pure material and sold to formulators?| A1: The product

is imported as a pure material. | | Q2: Do have an

estimate for how many customers you will sell to for each

use category? | A2: We primary sell our product to 5 or 6

distributors who then sell to formulators and end users.

We do not have a sense of how many customers each

distributor sells to for each market sector. | | Q3: Is

there any repackaging or QC sampling that occurs at the

distribution sites? | A3: No. We sell the products in

drums to the distributors for direct sale to formulators

and end uses.