OCCUPATIONAL EXPOSURE RATING: 1

- 2 B NOTES & KEY ASSUMPTIONS: Generated by the 09/30/2013 version of ChemSTEER. This PMN is a site-limited chemical intermediate: synthetic 5-0573 i s used to make all chemicals in consolidated set . The SAT report lists concern for dermal, drinking water, and inhalation exposures, as well as releases to water with a CoC of 220 ppb. This IRER assesses all release media and exposure activities. // No same submitter, similar use past cases were found. The following different submitter, si consistency: were manufactured and used as volatile liquids, and assessed air releases and inhalation exposures (consistent with th is IRER). L15- 0 257 was manufactu impor olid particulate (not consistent with this IRER). and referenced the updated March 2015 guidance for estimating equipment g during chemical intermediate use (consistent with this IRER); was generated prior to March 2015.

POLLUTION PREVENTION CONSIDERATIONS: P2 Claim: This chemical is being utilized as an intermediate in production of furoate esters, which are expected to displace the use of toluene (and in some cases benzene and xylene) as a raw starting material for the production of solvents and plasticizers. Furoate esters exhibit the same functional properties as benz o ate esters, which are used as both solvents and plasticizers.

EXPOSURE-BASED REVIEW: NoINITIAL REVIEW ENGINEERING REPORT PMN: 15-0573 Manufacturing: Continuous Production Facility Albuquerque NM 87112 Number of Sites / Location: 1
Days / yr: 250 Basis: The submission indicated a continuous process at 1 submitter-controlled site. The submission estimates 40 kg/day (max), 18 hr/day, 260 days/yr. To scale up to the 3rd year PV and to maximize exposure and release estimates, EPA assumes 250 days/yr. CS calculates 60 kg/day. PMN is produced at 50-90%. Process Description: Raw materials charged to reaction vessel

- - > Solid/liquid separation --> Liquid/liquid separation --> Stabilization --> Packaging (liquid, 50-90%) (per 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.Air Output 2: 2.2E-2 kg / site- day over 250 days / yr from 1 site or 5.4E+0 kg/site-yr from 1 site or 5.4E+0 kg/yr

- a ll sites to: air from: Equipment Cleaning Losses of Liquids from Multiple Vessels basis: EPA/OPPT Mass Transfer Coefficient Model. Air Typical: 1.3E-5 kg / site-day over 250 days / yr from 1 site or 3.2E-3 kg/site-yr from 1 site or 3.2E

- 3 kg/yr

- a ll sites Worst Case: 2.5E-5 kg / site

- day over 250 days / yr from 1 site or 6.4E-3 kg/site-yr from 1 site or 6.4E-3 kg/yr-all sites to: air from: Loading Liquid Product into Drums basis: EPA/OAQPS AP-42 Loading Model. Incineration Conservative: 1.2E+0 kg / site

- day over 1 day / yr from 1 site or 1.2E+0 kg/site-yr from 1 site or 1.2E+0 kg/yr-all sites to: TSDF (amendment) from: Equipment Cleaning Losses of Liquids from Multiple Vessels basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual. The submission does not discuss equipment cleaning. Because of a continuous process, EPA assumes equipment cleaning once per year (at the end of a campaign). The additional information sent in for P15-477 (product of P-15- 5 73) indicates that the equipment cleaning waste is sent to TSDF (permitted Treatment, storage and disposal facilites)

RELEASE TOTAL 6.7E+0 kg / yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 3 Basis: The submission estimates up to 3 workers potentially exposed.Inhalation: Exposure to Vapor (volatile) (Class II) Typical: > Potential Dose Rate: 6.1E

- 3 mg / day over 250 days / yr > Lifetime Average Daily Dose: 3.4E

- 5 mg / kg

- day over 250 days / yr > Average Daily Dose: 6.0E

- 5 mg / day over 250 days / yr > Acute Potential Dose: 8.7E

- 5 mg / day over 250 days / yr Worst Case: > Potential Dose Rate: 3.7E

- 1mg / day over 250 days / yr > Lifetime Average Daily Dose: 2.1E

- 3 mg / kg

- day over 250 days / yr > Average Daily Dose: 3.6E

- 3 mg / day over 250 days / yr > Acute Potential Dose: 5.2E

- 3 mg / day over 250 days / yr Number of workers (all sites) with inhalation exposure: 3 Basis: Loading Liquid Product into Drums; EPA / OPPT Mass Balance Model. 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? No OR b) Hazard Rating for health of 2 or greater? 2 Yes => Inhalation Monitoring Data Desired? **No** Dermal: Exposure to Liquid at 90.00% concentration High End: > Potential Dose Rate: 2.0E+3 mg / day over 250 days / yr > Lifetime Average Daily Dose: 1.1E + 1 mg / day over 250 days / yr > Average Daily Dose: 2.0E+1 mg / day over 250 days / yr > Acute Potential Dose: 2.9E+1 mg / day over 250 days / yr Number of workers (all sites) with dermal exposure: 3 Basis: Loading Liquid Product into Drums; EPA/OPPT 2

- Hand Dermal C ontact with Liquids Model.INITIAL REVIEW ENGINEERING REPORT PMN: 15-0573 Use: Site-Limited Chemical Intermediate Production Facility Albuquerque NM 87112 Number of Sites / Location: 1
Days / yr: 203 Basis: Chemical is a site-limited intermediate. The submi es not provide process details. The product of the reaction, indicates a batch process, 138 batches/yr. The standard review for the subsequent chemical assumed 203 days/year. Assume the same.
Process Description: uid, 50

- 9 0%) added to reaction vessel

- - > Reaction to produce -- > PMN destroyed (per submission and CRSS). 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.Water or Incineration or Landfill High End: 5.6E+0 kg / site- day over 80 days / yr from 1 site or 4.5E+2 kg/site-yr from 1 site or 4.5E+2 kg/yr

- a ll sites to: from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. Submission does not discuss container cleaning and were not able to get more information from the company. EPA assesses re l ease to uncertain media as conservative.
Air Typical: 1.6E-5 kg / site-day over 203 days / yr from 1 site or 3.2E-3 kg/site-yr from 1 site or 3.2E-3 kg/yr-all sites Worst Case: 3.2E-5 kg / site

- day over 203 days / yr from 1 site or 6.5E-3 kg/site-yr from 1 site or 6.5E-3 kg/yr-all sites to: air from: Unloading Liquid Raw Material from Drums basis: EPA/OAQPS AP-42 Loading Model. Air Output 2: 1.4E-6 kg / site- day over 80 days / yr from 1 site or 1.1E-4 kg/site-yr from 1 site or 1.1E

- 4kg/yr

- a ll sites to: air from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Penetration Model. Air Output 2: 5.4E-3 kg / site- day over 203 days / yr from 1 site or 1.1E+0 kg/site-yr from 1 site or 1.1E+0 kg/yr-all sites to: air from: Equipment Cleaning Losses of Liquids from a Single, Large Vessel basis: EPA/OPPT Mass Transfer Coefficient Model. Incineration Output 1: 7.4E-3 kg / site- day over 203 days / yr from 1 site or 1.5E+0 kg/site-yr from 1 site or 1.5E+0 kg/yr-all sites Output 2: 3.7E-2 kg / site- day over 203 days / yr from 1 site or 7.5E+0 kg/site-yr from 1 site or 7.5E+0 kg/yr-all sites to: TSDF (amendment) from: Equipment Cleaning Losses of Liquids from a Single, Large Vesselbasis: User-Defined Loss Rate Model. The submission does not discuss equipment cleaning. Per March 2015 guidance on assessing releases of a chemical intermediate from reactor cleaning, EPA assumes 95-99% reaction, with 1% residual. Therefore, LF = (1- 0 .95 to 0.9 01 = 0.0001 to 0. e additional information sent in for (product of ) indicates that the equipment cleaning waste is sent to TSDF (permitted Treatment, storage and disposal facilites)

RELEASE TOTAL 4.6E+2 kg / yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 7 Basis: P15-0474C, the next step in the synthetic sequence estimates up to 7 workers potentially exposed during the USE operation.Inhalation: Exposure to Vapor (volatile) (Class II) Typical: > Potential Dose Rate: 7.6E

- 3 mg / day over 203 days / yr > Lifetime Average Daily Dose: 3.5E

- 5 mg / kg

- day over 203 days / yr > Average Daily Dose: 6.1E

- 5 mg / day over 203 days / yr > Acute Potential Dose: 1.1E

- 4mg / day over 203 days / yr Worst Case: > Potential Dose Rate: 4.6E

- 1mg / day over 203 days / yr > Lifetime Average Daily Dose: 2.1E

- 3 mg / kg

- day over 203 days / yr > Average Daily Dose: 3.6E

- 3 mg / day over 203 days / yr > Acute Potential Dose: 6.5E

- 3 mg / day over 203 days / yr Number of workers (all sites) with inhalation exposure: 7 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT Mass Balance Model. 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? No OR b) Hazard Rating for health of 2 or greater? 2 Yes => Inhalation Monitoring Data Desired? **No** Dermal: Exposure to Liquid at 90.00% concentration High End: > Potential Dose Rate: 2.0E+3 mg / day over 203 days / yr > Lifetime Average Daily Dose: 9.2E+0 mg / day over 203 days / yr > Average Daily Dose: 1.6E+1 mg / day over 203 days / yr > Acute Potential Dose: 2.9E+1 mg / day over 203 days / yr Number of workers (all sites) with dermal exposure: 7 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.