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INITIAL REVIEW ENGINEERING REPORT PMN: 13-0192 Post-Focus Draft Revision 1 3/8/2013

ENGINEER: Jackson / Austin \ AH PV (kg/yr): 200,000 Import Only YX

SUBMITTER: Zeon Chemicals LP

USE: Rubber compounds used in automotive tires. Estimated to be an adhesive that is blended with rubber, carbon, vulcanizing agents, accelerators and other additives, which are then molded and vulcanized to be formed as tires for motor cars.

OTHER USES: No other uses were found.

MSDS: Yes Label: No

Gen Eqpt: Local exhaust ventilation, follow facility guidelines on eye/face protection, use of proper chemical hygiene practices is recommended. Respirator: Respiratory protection is not typically required during normal use and handling operations where general dilution or local exhaust ventilation is adequate to control exposures. NIOSH approved respiratory protection may be needed if vapor or dust is generated during processing or if the product is ground into a fine powder. Wear a positive pressure air-supplied respirator in situations where there may be potential for elevated airborne exposure such as during equipment malfunction, or product hangup or stagnation during processing that may result in decomposition. Health Effects: Processing and use of this product may cause static charge which may ignite flammable materials. No information on toxicity available. TLV/PEL: None established for the PMN

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Consumer Use: No

SAT (concerns) (01/11/2013): Migration to groundwater: Negligible PBT rating: P3B3T1 Health: 1 Not Required Eco: 3 Water (All releases to water with a CC = 1 ppb), XB Testing (Testing desired)

OCCUPATIONAL EXPOSURE RATING: 2-3B

NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER.

dermal exposure to solid (consistent with this IRER).

POLLUTION PREVENTION CONSIDERATIONS:

None.

EXPOSURE-BASED REVIEW: Yes (0 criteria met)

1) # of workers exposed: 34 >1000? No 2) >100 workers with >10 mg/day inhalation exposure: No 3) (a) >100 workers w/1-10 mg/day inh. exp. & >100 days/yr: No (b) Routine Dermal Cont: >250 workers & >100 days/yr:

No

INITIAL REVIEW ENGINEERING REPORT PMN: 13-0192

Processing: Sampling and Repackaging

Number of Sites/ Location: 2 Zeon Chemicals LP Louisville KY 40211 Zeon Chemicals Warehouse Louisville KY 40258 Days/yr: 5 Basis: Submitter estimates 2 sites, 600 kg/bt, 5 hr/bt, and 10 bt/yr (or 5 bt/site-yr), which translates to a PV of 6,000 kg/yr of PMN that could potentially be sampled or repackaged. Note this operation is 3% of the total PV. Page 2p130192.en1 The majority of the PMN will be shipped directly to customers without further processing.

Process Description: PMN imported to submitter sites (solid, 100%) --> small quantity may be used for quality or R&D lab analysis; additionally, PMN may be delivered to warehouse for sampling/repackaging --> PMN (solid, 100%) shipped in packaging containers to customers (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.

Water or Air or Incineration or Landfill Output 2: 0.0E+0 kg/site-day over 5 days/yr from 2 sites or 0.0E+0 kg/yr to: Air, water, incineration or land (Dust Model) from: Unloading Solid Raw Material from Transport Containers basis: User-Defined Loss Rate Model. The PMN is a solid. The 2006 Dust Model estimates 0.5% loss associated with solid transferring activities (e.g. repackaging). Per discussion with submitter, the PMN solid is not airborne. PS> 250 microns. no dusting.

Landfill Output 2: 5.0E+1 kg/site-day over 5 days/yr from 2 sites or 5.0E+2 kg/yr to: Landfill (submission) from: Sampling and other repackaging activities basis: User-Defined Loss Rate Model. Submission estimates 50 kg/bt PMN may be landfilled. CEB assumes this amount includes potential container residue and sampling losses (8.3% loss).

RELEASE TOTAL 5.0E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 6 Basis: Submission estimates 3 workers for lab analysis and 3 workers for repackaging (6 workers for both sites).

Inhalation:

Exposure to Particulate (Class I) Upper Bound: 1.5E+2 mg/day over 5 days/yr Number of workers (all sites) with inhalation exposure: 6 Basis: Unloading Solid Raw Material from Transport Containers; 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 No Inhalation Monitoring Data Desired? Yes (both criteria Page 3p130192.en1 met)

Dermal:

Exposure to Solid at 100.00% concentration High End: 3.1E+3 mg/day over 5 days/yr Number of workers (all sites) with dermal exposure: 6 Basis: Unloading Solid Raw Material from Transport Containers; EPA/OPPT Direct 2-Hand Dermal Contact with Solids Model.

INITIAL REVIEW ENGINEERING REPORT PMN: 13-0192

Use: Rubber Compounds

Number of Sites/ Location: 1 unknown site Graniteville SC 29029 Days/yr: 180 Basis: Submission states 1 customer site and 180 exposure day/yr. CEB assumes 1800 day/yr operation and calculates a PMN use rate of 1,111 kg/site-day.

Process Description: PMN (solid, 100%) --> blended with rubber, carbon, vulcanizing agents, accelerators and other additives (solid, 5%) --> mixture molded /extruded and vulcanized to form tires --> curing by heat and pressure, PMN destroyed per CRSS (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.

Water or Air or Incineration or Landfill Output 2: 0.0E+0 kg/site-day over 180 days/yr from 1 site or 0.0E+0 kg/yr to: Air, water, incineration or land (Dust Model) from: Unloading Solid Raw Material from Transport Containers basis: User-Defined Loss Rate Model. Submission estimates 7 kg/day spill from dumping of material into process equipment (0.6% loss) which is disposed of in municipal trash. Note submitter estimate is more conservative than the Dust Model. Per submitter conversation and amendment, the 7 kg release statement was inaccuarate. the material is greater than 250 microns and will not be airborne.

Air Output 2: 8.3E-2 kg/site-day over 180 days/yr from 1 site to: Air (submission) from: Fugitive Process Losses basis: User-Defined Loss Rate Model. Per submission, vapors or fine particulates may be released to the outside air from ventilation devices in compounding areas. Submission estimates 15 kg/yr release (Release 2 & 4).

Incineration or Landfill Output 2: 1.1E+1 kg/site-day over 180 days/yr from 1 site or 2.0E+3 kg/yr to: Incineration or landfill (CEB assumption) from: Cleaning Solid/ Powder Residuals from Containers Page 4p130192.en1 Used to Transport the Raw Material basis: EPA/OPPT Solid Residuals in Transport Containers Model, CEB standard 1% residual.

Incineration or Landfill Output 2: 1.1E+1 kg/site-day over 180 days/yr from 1 site or 2.0E+3 kg/yr to: Incineration or landfill (CEB assumption) from: Equipment Cleaning Losses of Solids from Process Vessels basis: EPA/OPPT Solid Residuals in Transport Containers Model, CEB standard 1% residual.

Incineration or Landfill Output 2: 6.9E+0 kg/site-day over 180 days/yr from 1 site or 1.2E+3 kg/yr to: Incineration or landfill (CEB assumption) from: Offspec Material basis: User-Defined Loss Rate Model. Submission also estimates 500 kg/yr unusable rubber compound and 750 kg/yr PMN in off-spec rubber trimming that could be disposed of in special waste or municipal trash (0.6% loss).

RELEASE TOTAL 5.3E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 28 Basis: Submission estimates 28 workers potentially exposed at the customer site.

Inhalation:

Exposure to Particulate (Class I) Upper Bound: 1.5E+2 mg/day over 180 days/yr Number of workers (all sites) with inhalation exposure: 28 Basis: Unloading Solid Raw Material from Transport Containers; 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 No Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal:

Exposure to Solid at 100.00% concentration High End: 3.1E+3 mg/day over 180 days/yr Number of workers (all sites) with dermal exposure: 28 Basis: Unloading Solid Raw Material from Transport Containers; EPA/OPPT Direct 2-Hand Dermal Contact with Solids Model.

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