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 

ensure (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. Note 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.

Incineration 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 groundwater 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 from 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 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.

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: 3.3E+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 electronics and also be used 

for reflective coatings.