Incineration or Landfill High End: 6.2E+0 kg/site
- day over 7 days/yr from 10 sites or 4.4E+1 kg/site
- yr from 10 sites or 4.4E+2 kg/yr
- all sites to: Uncertain (per GS) 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 estimate releases during processing. CEB assesses 3% residual to water, incineration, or landfill, per the Jan 2010 GS on Formulation of Radiation Curable Coatings. Submitter will ens ure (MSDS, labels, etc.) to inform the customers and users that the empty containers should be disposed properly.
Incineration or Landfill Conservative: 1.5E+0 kg/site
- day over 10 days/yr from 10 sites or 1.5E+1 kg/site
- yr from 10 sites or 1.5E+2 kg/yr
- all sites to: Incineration or Landfill (per GS). from: Equipment Cleaning Losses of Liquids from Multiple Vessels basis: EPA/OPPT Single Vessel Residual Model, CEB standard 1% residual. CEB assesses 1% residual to incineration or landfill per the Jan 2010 GS on Formulation of Radiation Curable Coatings. Note that migration to groundwater is slow
- moderate. Incineration or Landfill Output 2: 1.5E+0 kg/site
- day over 10 days/yr from 10 sites or 1.5E+1 kg/site
- yr from 10 sites or 1.5E+2 kg/yr
- all sites to: Incineration or Landfill (per GS). from: Filter Media Changeout basis: User
- Defined Loss Rate Model.Per the Jan 2010 GS on Formulation of Radiation Curable Coatings, assume 1% loss from filter waste (unpigmented coatings) to incineration or landfill. N ote that migration to groundwater is slow
- moderate. RELEASE TOTAL 7.4E+2 kg/yr
- all sites OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 390 Basis:Inhalation: negligible (VP < 0.001 torr)

Dermal : Exposure to Liquid at 100.00% concentration High End: > Potential Dose Rate: 2.2E+3 mg/day over 10 days/yr > Lifetime Average Daily Dose: 5.0E
- 1 mg/day over 10 days/yr > Average Daily Dose: 8.8E
- 1 mg/day over 10 days/yr > Acute Potential Dose: 3.2E+1 mg/ day over 10 days/yr Number of workers (all sites) with dermal exposure: 390 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2
- Hand Dermal Contact with Liquids Model.Air Typical: 2.1E
- 1 kg/site
- day over 250 days/yr from 10 sites or 5.2E+1 kg/site
- yr from 10 sites or 5.2E+2 kg/yr
- all sites Worst Case: 4.8E
- 1 kg/site
- day over 250 days/yr from 10 sites or 1.2E+2 kg/site
- yr from 10 sites or 1.2E+3 kg/yr
- all sites to: Air (10%) and Landfill (90%) (per GS) from: Coating Using Hand
- Held Spray Gun basis: EPA/ OPPT Automobile Refinish Coating Overspray Loss Model (non
- volatiles). The GS uses this model as the default and assumes for unknown uses that 90% of the emissions are captured by a dry filter and the waste is landfilled, while 10% is released to air.
Inci neration or Landfill High End: 1.9E+0 kg/site
- day over 24 days/yr from 10 sites or 4.5E+1 kg/site
- yr from 10 sites or 4.5E+2 kg/yr
- all sites to: Uncertain (per GS). 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 estimate use releases. The GS on Application of Radiation Curable Coatings, Inks, and Adhesives estimates container residue release to water, incineration, or landfill. Migration to gro undwater is slow
- moderate. Submitter will ensure (MSDS, labels, etc.) to inform the customers and users that the empty containers should be disposed properly. Incineration or Landfill Conservative: 1.2E
- 1 kg/site
- day over 250 days/yr from 10 sites or 3.0E+1 kg/site
- yr from 10 sites or 3.0E+2 kg/yr
- all sites to: Incineration or Landfill (per GS). from: Equipment Cleaning Losses of Liquids from Multiple Vessels basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual. The GS on Application of Radiation Curable Coatings, Inks, and Adhesives estimates equipment cleaning residual release to incineration or landfill. Note that migration to groundwater is slow
- moderate. Landfill Typical: 1.9E+0 kg/site
- day over 250 days/yr f rom 10 sites or 4.7E+2 kg/site
- yr from 10 sites or 4.7E+3 kg/yr
- all sites Worst Case: 4.3E+0 kg/site
- day over 250 days/yr from 10 sites or 1.1E+3 kg/site
- yr from 10 sites or 1.1E+4 kg/yr
- all sites to: Air (10%) and Landfill (90%) (per GS) from: Coating Using Hand
- Held Spray Gunbasis: EPA/OPPT Automobile Refinish Coating Overspray Loss Model (non
- volatiles). The GS uses this model as the default and assumes for unknown uses that 90% of the emissions are captured by a dry filter and the wa ste is landfilled, while 10% is released to air.

RELEASE TOTAL 1.3E+4 kg/yr
- all sites OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 170 Basis:Inhalation: Exposure to Mist (non
- volatile) (Class I) Upper Bound: > Potential Dose Rate: 4.5E+1 mg/day over 250 days/yr > Lifetime Average Daily Dose: 2.5E
- 1 mg/kg
- day over 250 days/yr > Average Daily Dose: 4.4E
- 1 mg/day over 250 days/yr > Acute Potential Dose: 6.4E
- 1 mg/day over 250 days/yr Number of workers (all sites ) with inhalation exposure: 170 Basis: Coating Using Hand
- Held Spray Gun; OSHA PNOR PEL
- Limiting Model. 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? 1
- 2 No => Inhalation Monitoring Data Desired? **No** Dermal: Exposure to Liquid at 30.00% concentration High End: > Potential Dose Rate: 6.7E+2 mg/day over 250 days/yr > Lifetime Average Daily Dose: 3.8E+0 mg/day over 250 days/yr > Average Daily Dose: 6.6E+0 mg/day over 250 days/yr > Acute Potential Dose: 9.6E+0 mg/ day over 250 days/yr Number of workers (all sites) with dermal exposure: 170 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2
- Hand Dermal Contact with Liquids Model. Exposure to Liquid at 30.00% concentration High End: > Potential Dose Rate: 3.3 E+3 mg/day over 250 days/yr > Lifetime Average Daily Dose: 1.8E+1 mg/day over 250 days/yr > Average Daily Dose: 3.2E+1 mg/day over 250 days/yr > Acute Potential Dose: 4.7E+1 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 170 Basis: Coating Using Hand
- Held Spray Gun; EPA/OPPT 2
- Hand Dermal Immersion in Liquid Model.CALL BY: Emerson Earl CALL TO: Jay Jon Organization: EPA Date: 04/30/2015 Time:

PMN: 15
- 0120 Organization: Miwon North America Inc.

Phone: Concerning what TSCA CBI? CBI: Yes MEMORANDUM of CBI TELEPHONE CONVERSATION

Q1: How are the empty containers be handled.| A1: We will do what we can (including MSDS, labeling, etc.) do ensure that our customers as well as the down stream users will properly disposed the empty containers so that there will not be releases to water. Our chemical will be sold to a few selected customers for specific application. The chemical will likely to go into UV curable coating for ele ctronics and also be used for reflective coatings.