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INITIAL REVIEW ENGINEERING REPORT 

PMN: 13-0127

Focus Ready Draft 12/10/2012

ENGINEER: Jon \ REC

PV (kg/yr): 30,000 Import Only

SUBMITTER: Miwon North America, Inc.

USE: Monomer for resin in industrial coatings. All

analogs are acrylate monomers in coating formulations.

155:124603 CA: High-refractive-index acrylic resin

compositions for optical materials and their cured

products. 153:62744 CA: Curable composition for imprints,

 patterning method and pattern. 140:50340 CA: Recording

material formulations for holographic media. 136:310650

CA: Low shrinkage thermosetting resin compositions and

use in low shrinkage die attach pastes.

OTHER USES: 152:336446 CA: Antistatic and

light-leakage-preventing adhesive compositions for

polarizing plates and liquid crystal displays. 138:25538

CA: Polymerizable compounds having rigid-rod like spacers

for low shrinkage thermosetting adhesive compositions.

140:129142 CA: Low shrinkage thermosetting resin

compositions and use as adhesives.

 
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SAT (concerns) (12/04/2012):

Related Cases and Related Cases and Misc SAT Info:

Ecotox:

Migration to groundwater: Slow

PBT rating: P1B1T1 .

Health: 1-2 Dermal, Drinking Water, Inhalation

Eco: 3 Water (All releases to water with a CC = 1.00 ppb)

OCCUPATIONAL EXPOSURE RATING: 1C

NOTES & KEY ASSUMPTIONS:

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

PMN is import only; Processing and Use have been assessed.

 The PMN is a resin used in industrial coatings. The

following same-submitter, same/similar-use past cases

were referenced for consistency: and

 All past cases were for resins for industrial

coatings. CEB assesses the current IRER according to the

August 2008 Generic Scenario on the Formulation of

Radiation Curable Coatings, Inks, and Adhesives and the

2010 Generic Scenario on the Application of Radiation

Curable Coatings, Inks, and Adhesives to assess

formulation and downstream use, respectively (consistent

with past cases). Current IRER assessments of releases

and exposures during formulation and use are consistent

with all 7 past cases. Current IRER assumes that the

number of USE sites is equal to the number of PROC sites

(consistent with past cases).

POLLUTION PREVENTION CONSIDERATIONS:

No Pollution Prevention information provided by the

submitter.
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EXPOSURE-BASED REVIEW: No

INITIAL REVIEW ENGINEERING REPORT 

PMN: 13-0127

Processing: Coating Formulation

Number of Sites/ Location: 10

Unknown Sites

Days/yr: 10

Basis: Submission provides PV of 10,000 kg/yr.

Submission estimates 5 to 10 sites (depending on number

of customers; although submission also estimates 1 site).

 Submission estimates 10 exposure days/year, and 400 to 2,

000 kg/bt of LVE. To be conservative for exposures, CEB

assesses 10 sites, 10 operating days/year, and ChemSTEER

calculates 300 kg/site-bt LVE (assumptions consistent

with all past cases). LVE is imported at 100%.

Process Description: Import LVE (100% LVE; liquid) -->

Charge LVE and other materials --> Heat to 40 to 50 oC

--> Mix (30% LVE) --> Packing (5-gal pails or 55-gal

drums; 30% LVE; liquid), 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. Note: submission states no release to

the environment. However, CEB assesses releases based on

multiple unknown customer sites.

Water or Incineration or Landfill

High End: 9.0E+0 kg/site-day over 10 days/yr from 10 sites

or 9.0E+2 kg/yr

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, incin, or

land, per the Aug 2008 GS on Formulation of Radiation

Curable Coatings. Note that migration to groundwater is

negl.

Incineration or Landfill

Conservative: 3.0E+0 kg/site-day over 10 days/yr from 10

sites

or 3.0E+2 kg/yr

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 incin
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or land, per the Aug 2008 GS on Formulation of Radiation

Curable Coatings. Note that migration to groundwater is

negl.

Incineration or Landfill

Output 2: 3.0E+0 kg/site-day over 10 days/yr from 10 sites

or 3.0E+2 kg/yr

to: Incineration or Landfill (per GS)

from: Filter Media Changeout

basis: User-Defined Loss Rate Model. Per the Aug 2008 GS

on Formulation of Radiation Curable Coatings, assume 1%

loss from filter waste (unpigmented coatings) to incin or

land. Note that migration to groundwater is negl.

RELEASE TOTAL

1.5E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 390

Basis: Submission states 10 workers for all sites

combined (i.e., 2 workers/site across 5 sites). The

August 2008 GS on Formulation of Radiation Curable

Coatings estimates 39 workers/site as default for

coatings. CEB assesses per the GS as conservative.

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 100.00% concentration

High End: 1.8E+3 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.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 13-0127

Use: Industrial Coating Use

Number of Sites/ Location: 10

Unknown Sites

Days/yr: 250

Basis: The submission does not provide details about the

use operation. The LVE arrives at 30% concentration. The

2010 GS on Application of Radiation Curable Coatings

estimates a use rate of 137,000 kg/site-yr (for unknown

coatings). Per the GS, the number of sites = (PV) /

(Coating use rate x Concentration of LVE in coating) = 10,

000 / (137,000 x 0.30) = 0.25 sites = ~1 site. As a
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conservative estimate, CEB assumes the number of use

sites is equal to the number of PROC sites (10 sites).

The GS estimates 250 operating days as default. ChemSTEER

calculates 12 kg LVE/batch.

Process Description: Coating is unloaded (liquid, 30%)

--> Coating is diluted and mixed (optional) --> Coating

is applied to substrate (roll, spray, curtain) -->

Coating is cured, LVE is reacted (per GS 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: 1.9E+0 kg/site-day over 48 days/yr from 10 sites

or 9.0E+2 kg/yr

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, incin, or land. Migration to gw is negl.

Air

Output 2: 9.0E-1 kg/site-day over 250 days/yr from 10

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). For an unknown coating

process, the GS on Application of Radiation Curable

Coatings, Inks, and Adhesives conservatively assesses the

spray coating with a 25% transfer efficiency. The GS

assumes 90% of the emissions are captured by a dry filter

and the waste is landfilled, while 10% is released to air.

Incineration or Landfill

Conservative: 2.4E-1 kg/site-day over 250 days/yr from 10

sites

or 6.0E+2 kg/yr

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 incin or land.

Note that migration to gw is negl.

Landfill
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Output 2: 8.1E+0 kg/site-day over 250 days/yr from 10

sites

or 2.0E+4 kg/yr

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). For an unknown coating

process, the GS on Application of Radiation Curable

Coatings, Inks, and Adhesives conservatively assesses the

spray coating with a 25% transfer efficiency. The GS

assumes 90% of the emissions are captured by a dry filter

and the waste is landfilled, while 10% is released to air.

RELEASE TOTAL

2.4E+4 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 170

Basis: Based on guidance in the 2010 GS (Application of

Radiation Curable Coatings, Inks and Adhesives), CEB

assumes 17 workers per site.

Inhalation:

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:

Basis: Coating Using Hand-Held Spray Gun; EPA/OPPT

Automobile OEM Spray Coating Inhalation Model

(non-volatile non-polyisocyanates).

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? 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: 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: 2.6E+3 mg/day over 250 days/yr

Number of workers (all sites) with dermal exposure: 170
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Basis: Coating Using Hand-Held Spray Gun; EPA/OPPT 2-Hand

Dermal Immersion in Liquid Model.