file:///J|/INITENG/P13%20cases/p130127.eng.txt[6/4/2013 7:44:40 AM] 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.file:///J|/INITENG/P13%20cases/p130127.eng.txt[6/4/2013 7:44:40 AM] 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.file:///J|/INITENG/P13%20cases/p130127.eng.txt[6/4/2013 7:44:40 AM] 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 incinfile:///J|/INITENG/P13%20cases/p130127.eng.txt[6/4/2013 7:44:40 AM] 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 afile:///J|/INITENG/P13%20cases/p130127.eng.txt [6/4/2013 7:44:40 AM] 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.

Landfillfile:///J|/INITENG/P13%20cases/p130127.eng.txt [6/4/2013 7:44:40 AM] 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 O verspray 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: 170file:///J|/INITENG/P13%20cases/p130127.eng.txt [6/4/2013 7:44:40 AM] Basis: Coating Using Hand-Held Spray Gun; EPA/OPPT 2-Hand Dermal Immersion in Liquid Model.