p130192.en1

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.

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 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

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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

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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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