INITIAL REVIEW ENGINEERING REPORT

P-14-0684 C

P-14-0683, P-14-0684

CEB Staff Draft 8/26/2014 11:00:00 PM

ENGINEER:

PV (kg/yr): 15000000 

Revision Notes/Assessment Overview:

SUBMITTER: Qualice, LLC (submitter)

USE: The uses are equally split between flame retardant/plasticizer in the rubber (50%) and lubricant in metal 

working fluids (MWFs) (50%). These uses are consistent with all the lit and previous cases submitted . Other 

potential uses are listed elsewhere. Lubricants can have more variety of chlorine content based on application 

needs, while rubber formulations have chlorine content more steady around the 52% levels. Related Cases 

Submitted Together: P-14-0683, P-14-0684.

OTHER USES: Generic uses MCCP: 1) Substances are used as a flame retardant/plasticizer in polymers; 2) used 

as lubricants in automotives 3) as components of solvent based paints, adhesives and sealants. The paints are 

specialty paints for applications where weather resistant coatings are needed, such as steel construction, industrial 

flooring, road marking, window sealants and pools; and 4) flame retardants / waterproofers to textiles.

MSDS: Yes LABEL: Yes

Gen Eqpt: Eng Controls: Under normal conditions of use, natural ventilation should effectively remove and 

prevent buildup of any vapor/mist/fume/dust generated from the handling of this product. // Eye/Face: If splashes 

are likely to occur, wear safety glasses with side-shields or a face shield with safety glasses. // Skin: Normal work

clothing (long sleeved shirts and long pants) is recommended. If splashes are likely to occur, use apron or 

impervious suit, such as a Tyvek coverall. If liquid contact is likely to occur, manufacturer recommends nitrile 

gloves (ex: N-DEX Nitrile).

Respirator: No personal respiratory protective equipment normally required. If mist is generated (heating, 

spraying) and engineering controls are not sufficient, wear NIOSH certified organic vapor respirator with 

particulate filter.

Health Effects: Eye: Contact with eyes may cause irritation // Skin: Prolonged and/or repeated skin contact may 

result in mild irritation or redness // Inhalation: Avoid breathing vapors or mists of this product. May cause irritation 

of respiratory tract. // Ingestion: Small amounts (a tablespoonful) swallowed during normal handling operations are 

not likely to cause injury; swallowing amounts larger than that may cause injury.

TLV/PEL: - none established

CRSS: (7/17/2014 1:00:00 AM):

Chemical Name: Tetradecane, chloro derivs.

S-H2O: 0.000005 g/L @ 

VP: 2.0E-6 torr @ 

MW: 440 0.0%<500 0.0%<1000

Physical State and Misc CRSS Info:

Neat: liquid Mfg: liquid

Proc/Form: liquid End Use: 10 - 15 % in final product. The stoicheometer of the process diagram would 

produce PMN products that are average molecular formula containing 6 - 8 chlorine atoms. The starting olefin is 

98% C14 and 93% alpha oleffin. The typical MW is near 440 daltons for a Cl7 congener based on total PV of > 40 

to < 70 wt % chlorine content.

Consumer Use: No

SAT (concerns): (7/17/2014 11:00:00 PM):

Related Cases and Misc SAT Info:

Same as P-12-0283. Analogs: P-12-0282, P-12-0357, P-12-0453 all MCCPs

Migration to groundwater: Slow
PBT rating: P2 B3 T2

Health: 1, No exposures needed

Eco: 3, Water (All releases to water with a CC = 1 ppb), XB Testing (Testing desired)

OCCUPATIONAL EXPOSURE RATING: 2-3D

NOTES & KEY ASSUMPTIONS:

Generated by the 06/07/2005 version of ChemSTEER. This is a consolidated set: P14-0683 & 0684. The two 

PMNs have identical volume, use rate, concentration and uses. PB ratings are P2B3; therefore, a full assessment is 

performed. This is an exposure-based case; all exposure criteria met; XB testing desired for Eco. //// Note 

P14-0684 was previously submitted as P12-0357 by Trinity, but the case was later withdrawn. //// The PMN is a 

MCCP product that is manufactured domestically and used in the following applications: 1) 50% as a flame 

retardant in rubber products; and 2) 50% as a lubricant in metal working fluids (MWFs). // The technical contact 

was called, see contact report for details. // Note, this IRER is consistent with past assessment of P12-0357 (same 

chemical as P14-0684, same uses), except that this IRER assesses a separate converting operation based on latest 

information provided by technical contact. Further, this IRER was prepared using the same methdology as the 

following past MCCP cases: P12-0277 through P12-0284, and P12-0453. //// For MFG: Submitter estimates were 

used for assessing submitter specified waste streams and standard models were used to assess equipment cleaning. 

Dermal exposure was assessed using standard models and inhalation exposure is expected to be negl. // For 

downstream processing and use operations: The release and exposure estimates were based on a combination of 

submitter provided data and data available in various literature sources. The literature sources include 1) previous 

EPA assessments on chlorinated paraffins; 2) foreign risk assessments on MCCPs and LCCPs (e.g. EU risk 

assessments); 3) EPA/OPPT Generic Scenarios; and 4) OECD Emission Scenario Documents. Due to the 

uncertainty at multiple downstream use sites, the most conservative data were chosen when evaluating releases for 

downstream operations.

POLLUTION PREVENTION CONSIDERATIONS:

P2 claims were made for the MCCP being an alternative to the SCCP. P2 claims were also made for MCCP as an 

alternative for phthalates. While true neither merits recognition.

P2 REC: P2 claims were made for the MCCP being an alternative to the SCCP. P2 claims were also made for 

MCCP as an alternative for phthalates. While true neither merits recognition.

EXPOSURE-BASED REVIEW: Yes (3 criteria met)

1) # of workers exposed: 149,846 >1000? Yes 

2) >100 workers with > 10 mg/day inhalation exposure: Yes 

3) (a) >100 workers w/1-10 mg/day inh. exp. & >100 days/yr: Yes 

 (b) Routine Dermal Cont: > 250 workers & > 100 days/yr: Yes
P-14-0684 C

P-14-0683, P-14-0684

MFG: Batch Manufacturing of PMN

Number of Sites/Location: 1 submitter site(s) 

Qualice, LLC Hamlet NC 28345

Basis: Per submission, 1 submitter site, 375 bt/yr, 12 hr/bt, 20,000 kg/bt, PMN produced as a liquid at 100%. CS calculates 750 

bt/yr based on submitted PV of 15,000,000 kg/yr. Assumed 3 processing lines per site.

Process Description: Feedstock charged to a reactor ---> chlorine gas in fed to reactor ---> byproduct gas is recovered and 

treated and produces waste PMN stream, bleach and HCl product ---> reaction forms PMN (liquid, 100%) --> QC sampling ---> 

stabilizer added ---> transfer to storage ---> loading PMN product (liquid, 100%) into tank trucks (90% of PV) or totes (10% of

PV) (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 Incineration or Landfill

Conservative: 4.0E+2 kg/site-day over 1 day/yr from 1 sites or 4.0E+2 kg/yr

to: uncertain

from: Equipment Cleaning Losses of Liquids from Multiple Vessels

basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual. The submission states that 

equipment cleaning is not performed between batches (not needed). As conservative, CEB assesses cleaning of 

equipment for 1 day/yr to address the possibility of equipment cleaning due to unforseen circumstances with 

releases to uncertain media.

Incineration

Output 2: 2.2E+1 kg/site-day over 250 day/yr from 1 sites or 5.4E+3 kg/yr

to: off-site incineration (submission)

from: Waste from Byproduct Gas Recovery

basis: User-Defined Loss Rate Model. The submission estimates 7.2 kg/bt of PMN is released to off-site 

incineration from waste PMN produced during byproduct gas recovery. CS calculates 3 bt/day resulting in a release 

of (7.2 x 3) = 21.6 kg/site-day.

Landfill

Output 2: 9.0E+0 kg/site-day over 250 day/yr from 1 sites or 2.2E+3 kg/yr

to: RCRA Subtitle D landfill (submission)

from: Carbon Waste from HCl Carbon Treatment

basis: User-Defined Loss Rate Model. The submission estimates 3 kg/bt of PMN is released to a RCRA subtitle D 

landfill from waste carbon produced HCl carbon treatment. CS calculates 3 bt/day resulting in a release of (3 x 3) = 

9 kg/site-day.

RELEASE TOTAL

8.0E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 6

Basis: The submission estimates up to 3 workers/site exposed to PMN at during various activities. As conservative, 

CEB assesses dermal exposure for all workers to liquid PMN at 100% during sampling (1-hand) and loading 

(2-hand) activities.

Dermal:
Exposure to Liquid 

High End: 1.1E+3 mg/day over 250 days/yr

Number of workers (all sites) with Dermal exposure: 3

Basis: Sampling Liquid Product; EPA/OPPT 1-Hand Dermal Contact with Liquids Model.

Dermal:

Exposure to Liquid 

High End: 2.2E+3 mg/day over 250 days/yr

Number of workers (all sites) with Dermal exposure: 3

Basis: Loading Liquid Product into Transport Containers; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.
P-14-0684 C

P-14-0683, P-14-0684

PROC2: Compounding of Rubber Products (50% of PV)

Number of Sites/Location: 6 submitter site(s) 

unknown site Mebane NC 

unknown site Youngsville NC 

unknown site Marysville OH 

unknown site Hannibal MO 

unknown site Calhoun GA 

unknown site St. Mary's OH 

Basis: Per submission, the PMN is used at 100% in rubber compounding at 6 customer sites. The technical contacts indicates 

the PMN may be present in rubber products from 10-15%. CEB assumes 15% to conservatively assesses exposures and 250 

days/yr based on 2004 ESD for Plastic Converting. CS calculates a use rate of 5,000 kg/site-day.

Process Description: PMN (liquid, 100%) unloaded from tank trucks ---> piped into mixer, mix with raw rubber and other 

additives at high temperature ---> molten rubber extruded into sheets, blocks and/or molds (PMN, 10-15% entrained in solid ) 

and shipped to downstream sites (submission, CRSS, technical contact for P14-0683/684 and P12-0282)

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. The submission does not provide information on releases during the manufacture of rubber 

products. The methology used to assesses the standard reviews for P12-0277 through P12-0284 (LCCP and MCCP 

products) was used to assesses releases during this operation. The only exception being container cleaning releases 

which are estimated using information from the submitter and technical contact.

Air

High End: 1.2E+0 kg/site-day over 250 day/yr from 6 sites or 1.9E+3 kg/yr

to: water or air (ESD, 2010 EU CSR)

from: Fugitive Air Emission from Extrusion

basis: User-Defined Loss Rate Model. Per ESD, fugitive air emissions generated during rubber converting can be 

0.05% with engineering controls depending on the type of coversion process (e.g. extrusion, injection molding, 

calendaring). The 2004 GS for Plastics Compounding estimates that 50% of air emissions will settle and be 

ultimately released to water while the other 50% remains in air. As conservative, CEB assesses fugitive air 

emissions at a loss rate of 0.05% with 50% to water and 50% to air.

Water

High End: 1.2E+0 kg/site-day over 250 day/yr from 6 sites or 1.9E+3 kg/yr

to: water or air (ESD, 2010 EU CSR)

from: Fugitive Air Emission from Extrusion

basis: User-Defined Loss Rate Model. Per ESD, fugitive air emissions generated during rubber converting can be 

0.05% with engineering controls depending on the type of coversion process (e.g. extrusion, injection molding, 

calendaring). The 2004 GS for Plastics Compounding estimates that 50% of air emissions will settle and be 

ultimately released to water while the other 50% remains in air. As conservative, CEB assesses fugitive air 

emissions at a loss rate of 0.05% with 50% to water and 50% to air.

Water or Incineration or Landfill

High End: 5.0E-1 kg/site-day over 250 day/yr from 6 sites or 7.5E+2 kg/yr

to: water, incineration, or landfill (RM-2)

from: Spillage During Raw Material Handling

basis: User-Defined Loss Rate Model. A 2010 EU CSR assessment on MCCPs estimated these releases to be 

0.01% of PV with releases to water or solid waste. .

Water or Incineration or Landfill

Conservative: 1.0E+2 kg/site-day over 250 day/yr from 6 sites or 1.5E+5 kg/yr

to: Uncertain
from: Equipment Cleaning Losses of from Multiple Vessels

basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual. The 2004 GS for Plastics 

Compounding estimates releases from equipment cleaning using the EPA/OPPT model loss rate of 2%. Due to 

multiple unknow sites, release to uncertain media (water, incineration or landfill) is assumed.

Water or Incineration or Landfill

High End: 3.8E+1 kg/site-day over 1 day/yr from 6 sites or 2.3E+2 kg/yr

to: water, incineration or land (ESD)

from: Cleaning Liquid Residuals from Tank Trucks Used to Transport the Raw Material

basis: EPA/OPPT Bulk Transport Residual Model, CEB standard 0.2% residual. The submission states that tank 

trucks are reused and are not cleaned between uses. For P12-0357, technical contact stated that in a scenario where 

the they will need to be taken out of service, tank trucks will be sent to a third party truck washing facility. To 

account for the possibility of containers being removed from service, CEB assesses releases from container cleaning 

for 1 day/yr with releases to uncertain media.

RELEASE TOTAL

1.5E+5 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 144

Basis: The submission estimates 1 worker/site. The 2004 ESD for Plastic Compounding estimates up to 24 

workers/site. CEB uses the ESD estimate as conservative.

Inhalation:

Exposure to Vapor 

High End of Range: 4.4E+0 mg/day over 250 days/yr

Low End of Range: 3.0E-2 mg/day over 250 days/yr

Number of workers (all sites) with Inhalation exposure: 144

Basis: Fugitive Air Emission from Extrusion; User-defined Inhalation Model. The 2004 GS for Plastics Compounding 

suggests that inhalation exposure is negligible for non-volatile substances during compounding. A 2010 EU Risk Assessment on 

MCCP contains monitoring| data from plastic compounding operations is the EU. The monitoring data is based on 32 air samples 

from 4 sites. Results showed MCCP air concentrations ranging from <0. 003 to 0.44 mg/m3 with a median of 0.03 mg/m3 and a 

90th percentile of 0.15 mg/m3. It is unknown whether these data represent area or personal monitoring data. As conservative, 

exposures estimates are presented based on the low and high of the range for these data and assuming up to 8 hr exposure 

duration. .

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

 (b) Hazard Rating for health of 2 or greater? No

Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal:

Exposure to Liquid 

High End: 2.2E+3 mg/day over 250 days/yr

Number of workers (all sites) with Dermal exposure: 144

Basis: Unloading Liquid Raw Material from Tank Trucks; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.
P-14-0684 C

P-14-0683, P-14-0684

PROC1: Formulation of Metalworking Fluids (50% of PV)

Number of Sites/Location: 10 submitter site(s) 

unknown site Goshen NY 

unknown site Harvey IL 

unknown sites Cleveland OH 

unknown sites Detroit MI 

unknown sites Philadelphia PA 

unknown site Mantua NJ 

unknown site Milwaukee WI 

unknown site Cincinnati OH 

unknown site Crystal Lake IL 

unknown site Linden NJ 

Basis: Per submission, 20 MWF formulation sites, 150 kg PMN/bt, 240 exposure days/yr, PMN used as a liquid at 100%. For 

past case P12-0357, technical contact estimates the PMN will be in products at 10-15%. CEB assumes 100% PMN in raw 

material and 15% PMN in plastic product to conservatively assess exposures. CS calculates a use rate of 1,562.5 kg/site-day 

based on 240 day/yr operation.

Process Description: PMN (liquid, 100%) is unloaded from tanks trucks (90% of PV) and totes (10% of PV) ---> transfer to 

storage ---> feed into blending tank, mixed with base oils and other additives ---> packaging of metal working fluids containing 

PMN (10 - 15%) (submission, technical contact from P12-0357)

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. The submission states there are no releases during formulation of MWFs. The methology used 

to assesses the standard reviews for P12-0277 through P12-0284 and P12-0357 (LCCP and MCCP products) was 

used to assesses releases during this operation. The only exception being container cleaning releases which are 

estimated using information from the submitter and technical contact.

Water or Incineration or Landfill

High End: 3.8E+1 kg/site-day over 1 day/yr from 20 sites or 7.6E+2 kg/yr

to: uncertain

from: Cleaning Liquid Residuals from Totes and Tank Trucks Used to Transport the Raw Material

basis: EPA/OPPT Bulk Transport Residual Model, CEB standard 0.2% residual. The submission states that totes 

and tank trucks are reused and are not cleaned between uses. From contact report for P12-0357, the technical 

contact stated that in a scenario where the they will need to be taken out of service, totes would be sent to a third 

party handler for cleaning and disposal and tank trucks will be sent to a third party truck washing facility. To 

account for the possibility of containers being removed from service, CEB assesses releases from container cleaning 

for 1 day/yr with releases to uncertain media.

Water or Incineration or Landfill

Conservative: 1.6E+1 kg/site-day over 240 day/yr from 20 sites or 7.5E+4 kg/yr

to: Uncertain

from: Equipment Cleaning Losses of Liquids from a Mixing Tank

basis: EPA/OPPT Single Vessel Residual Model, CEB standard 1% residual. The submission does not address 

equipment cleaning at downstream formulation sites. Due to uncertainty at multiple downstream sites, CEB 

assesses releases to uncertain media using the standard model loss fraction assuming cleaning once per day.

Air

Output 2: 7.8E-2 kg/site-day over 240 day/yr from 20 sites or 3.8E+2 kg/yr

to: fugitive air (2002 EU RA, 2010 Japan RA)

from: Fugitive Air Emissions

basis: User-Defined Loss Rate Model. A 2010 Japanese RA for SCCPs suggests 0.005% release to air during 

MWF formulation. Due to uncertainty at multiple downstream use sites, CEB includes this release source using this 

estimate.
Incineration or Landfill

Output 2: 3.1E+1 kg/site-day over 240 day/yr from 20 sites or 1.5E+5 kg/yr

to: incineration or landfill (2002 EU RA)

from: Off-Spec Material

basis: User-Defined Loss Rate Model. Data from a 2002 EU RA estimates a 1-2% loss rate from disposal of 

off-spec batches released to solid waste. Due to uncertainty at multiple downstream use sites, CEB includes this 

release source using the high end estimate with releases to incineration or landfill.

RELEASE TOTAL

2.3E+5 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 80

Basis: The submission estimates 80 workers for all sites (avg 4 workers/site). As conservative, CEB assesses all 

workers are exposed to PMN at 100% (unloading) and 15% (loading).

Dermal:

Exposure to Liquid 

High End: 2.2E+3 mg/day over 240 days/yr

Number of workers (all sites) with Dermal exposure: 80

Basis: Unloading Liquid Raw Material from Totes and Tank Trucks; EPA/OPPT 2-Hand Dermal Contact with Liquids 

Model.

Dermal:

Exposure to Liquid 

High End: 3.4E+2 mg/day over 240 days/yr

Number of workers (all sites) with Dermal exposure: 80

Basis: Loading Liquid Product into Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.
P-14-0684 C

P-14-0683, P-14-0684

USE1: Use of Metalworking Fluids (50% of PV)

Number of Sites/Location: 1 submitter site(s) 

unknown sites 

Basis: The submission does not address the use of formulated MWFs containing the PMN. The lubricant products contain 

10-15% PMN per contact report for P12-0357. CEB assumes 15% to conservatively assess exposures. The 2011 ESD for MWF 

Operations estimates 247 days/yr of operation. The ESD estimates the number of sites as: (7,500,000 kg/yr) / (4,260 gal/site-yr x 

1 kg/L x 3.785 L/gal x 0.15) = 3,101 sites. Environmental releases are of concern for this PMN. As conservative, CEB assumes 

247 days/yr of operation and the ESD estimate of 3,101 sites to maximize kg/site-day release. CEB also assumes 15% PMN in 

raw material and assumes no dilution as conservative. CS calcualtes a use rate of 9.7918 kg/site-day.

Process Description: Bulk MWF containing PMN (liquid, 10 - 15%,) is unloaded from transport containers ---> transfer to 

mixing vessel ---> possible dilution of if water-based MWF ---> transfer to metal shaping trough ---> metal shaping operation 

---> shaped metal part is rinsed and dried ---> spent MWF is drained and discarded (ESD)

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. The submission does not provide information on releases during the use of MWFs. The ESD 

was used to assesses releases during this operation.

Water or Incineration or Landfill

High End: 9.4E-1 kg/site-day over 18 day/yr from 3101 sites or 5.2E+4 kg/yr

to: water, incineration, or landfill (ESD)

from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material

basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. The submission does not address end use. 

Due to uncertainty at multiple downstream sites, these releases are assessed to uncertain media using a 3% loss rate 

per the ESD.

Water

Output 2: 1.0E+0 kg/site-day over 247 day/yr from 3101 sites or 8.0E+5 kg/yr

to: on-site WWTP or POTW (ESD)

from: Dragout Losses

basis: User-Defined Loss Rate Model. The 2011 ESD for MWF Operations estimates a loss rate of 11% from 

dragout with releases to on-site WWTP or POTW. These data are based on U.S. industry data collected during the 

development of effluent guidelines for the metalworking industry. Due to uncertainty at multiple downstream sites, 

CEB assesses dragout releases using the ESD estimate of 11% and accounting for upstream losses from container 

cleaning: (1-0.03) x 0.11 = 0.1067. Releases are assessed to water via on-site WWTP or POTW per submission and 

ESD.

Water or Incineration or Landfill

Output 2: 3.4E+0 kg/site-day over 247 day/yr from 3101 sites or 2.6E+6 kg/yr

to: water, incineration, or landfill (ESD)

from: Filter Media and Other Recycling Waste

basis: User-Defined Loss Rate Model. The 2011 ESD for MWF Operations estimates these releases to account for a 

36% loss rate with releases to water, incineration, or landfill (water-based fluids) or incineration or landfill 

(straight-oil). Accounting for upstream container cleaning losses: (1-0.03) x 0.36 = 0.3492. CEB assesses these 

releases to water, incineration, or landfill based on uncertainy at multiple downstream use sites.

Water or Incineration or Landfill

Output 2: 4.4E+0 kg/site-day over 247 day/yr from 3101 sites or 3.3E+6 kg/yr

to: water, incineration, or landfill (ESD)

from: Spent Metalworking Fluid

basis: User-Defined Loss Rate Model. The 2011 ESD for MWF Operations also assesses 100% release with the 

spent MWF disposed to water (water-based fluids) or incineration or landfill (straight oil fluids) with at least one 
bath changeout occuring per day at a facility with multiple baths in use. Based on uncertainty at multiple 

downstream use sites, CEB assesses the spent MWF to water, incineration, or landfill. Account for upstream losses, 

the loss rate is calculated as: (1-0.03) x (1-0.05-0.11-0.38) = 0.4462.

Air

Output 2: 4.7E-1 kg/site-day over 247 day/yr from 3101 sites or 3.6E+5 kg/yr

to: air (2002 EU RA)

from: Misting/Evaporation

basis: User-Defined Loss Rate Model. A 2002 EU RA for MCCP estimates misting/evaporation losses to range 

from 2 to 5% depending on the type of MWF begin used. Based on uncertainty at multiple downstream sites, CEB 

uses the most conservative estimate of 5% loss to air from misting/evaporation. Account for upstream losses from 

container cleaning: (1-0.03) x 0.05 = 0.0485

RELEASE TOTAL

7.2E+6 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 148848

Basis: The 2011 ESD for MWF Use estimates 48 workers/site. CEB assesses 48 workers/site as conservative, due 

to uncertainty at downstream use sites.

Dermal:

Exposure to Liquid 

High End: 2.6E+2 mg/day over 247 days/yr

Number of workers (all sites) with Dermal exposure: 148848

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

Dermal:

Exposure to Mist 

: mg/day over days/yr

: 3.7E+2 mg/day over 247 days/yr

Number of workers (all sites) with Dermal exposure: 148848

Basis: Exposure During Metalworking Operation; User-defined Dermal Model. The 2011 ESD for MWF Operations 

estimates an average dermal surface loading rate for MWFs of 2.9 mg/cm2-hr during metalworking operations. These data are 

more conservative than the EPA/OPPT 2-Hand Dermal Contact Model and are used to provide a conservative estimate of dermal 

exposure during MWF use due to uncertainty at downstream opeations. Per ESD, exposure is to fluid that has undergone a 

10-fold dilution so PMN concentration is 15% x 10% = 1.5%.

Inhalation:

Exposure to Mist 

High End of Range: 5.3E+0 mg/day over 247 days/yr

Typical: 1.5E+0 mg/day over 247 days/yr

Number of workers (all sites) with Inhalation exposure: 148848

Basis: Exposure During Metalworking Operation; User-defined Inhalation Model. The 2011 ESD for MWF Operations 

estimates typical mist concentrations ranging from 0.19 to 0.39 mg/m3 and high end concentrations ranging from 0.87 to 1.42 

mg/m3 depending on the type of MWF used. These estimates are based on the geometric mean (typical) and 90th percentile data 

(high end) of data collected by NIOSH from 942 machinists at 79 shops across the U.S. A range of inhalation exposure estimates 

are based the high end for the range of geometric means and 90th percentiles. CEB assumes the PMN is 37.5% of the mist. (GS 

assumes that water conc. is 60% and the PMN is then estimated to be 15/40 = 37.5% of the mist. 0.39 mg/m3 x 37.5% = 0.146 

mg/m3. 1.42 mg/m3 x 37.5% = 0.532 mg/m3.
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

 (b) Hazard Rating for health of 2 or greater? No

Inhalation Monitoring Data Desired? Yes (both criteria met)
P-14-0684 C

P-14-0683, P-14-0684

USE2: Converting of Rubber Products (50% of PV)

Number of Sites/Location: 1 submitter site(s) 

unknown site(s) 

Basis: Submission does not provide the number of rubber converting sites. Per 2004 ESD on Plastics Converting, 250 day/yr 

operation and a default plastic use rate of (38,738 MM kg/yr) / (12,191 sites) / (250 day/yr) = 12,710.36 kg/site-day (general 

plastics). CS calculates 16 sites.

Process Description: Rubber blocks, sheets or molds containing PMN (solid, 10 - 15%) are unloaded ---> forming (heating) 

---> molding and shaping using various processes (injection molding, extrusion, casting, calendaring, etc.) ---> trimming ---> 

finishing ---> finishied rubber article

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. The 2004 Plastics Converting ESD is referenced for this operation.

Incineration or Landfill

Output 2: 4.8E+1 kg/site-day over 250 day/yr from 16 sites or 1.9E+5 kg/yr

to: landfill or incineration

from: Scrap Material

basis: User-Defined Loss Rate Model. The 2004 GS for Plastics Converting estimated these releases to be 2.5% of 

PV. Expected to be handled as solid waste with disposal to landfill or incineration considered most likely.

Incineration or Landfill

Output 2: 1.9E+1 kg/site-day over 250 day/yr from 16 sites or 7.5E+4 kg/yr

to: incineration or landfill

from: Cleaning Solid/ Powder Residuals from Containers Used to Transport the Raw Material

basis: EPA/OPPT Solid Residuals in Transport Containers Model, CEB standard 1% residual. Solid compounded 

plastic residuals considered most likely to be handled as solid waste with disposal to landfill or incineration.

Incineration or Landfill

Conservative: 3.8E+1 kg/site-day over 250 day/yr from 16 sites or 1.5E+5 kg/yr

to: incineration or landfill

from: Equipment Cleaning Losses of Liquids from Multiple Vessels

basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual. Converted plastic residual 

material in equipment is considered most likely to be handled as solid waste and disposed by landfill or incineration.

Water or Incineration or Landfill

Output 2: 1.9E-1 kg/site-day over 250 day/yr from 16 sites or 7.6E+2 kg/yr

to: water, incineration or landfill

from: Dust Generation from Converting

basis: User-Defined Loss Rate Model. Per ESD, 0.01% loss of daily use rate. Particles are originally released to 

air but are expected to eventually settle to the ground. Dust particles are expected to be cleaned from equipment and 

floor with water or disposed directly to landfill.

Air

Output 2: 2.4E+0 kg/site-day over 250 day/yr from 16 sites or 9.5E+3 kg/yr

to: Water (50%) or Air (50%) (ESD)

from: Fugitive Air Emission from Converting

basis: User-Defined Loss Rate Model. Based on Plastics Converting GS (2004), Most plastic additives are 

non-volatile; however, converting operations may be performed at elevated temperatures; thus slight volatilization 

may occur. A release of 0.25% of the daily use rate is estimated. Particles are originally released to air but 

subsequent condensation may result in losses to water. As a conservative estimate, 50% is assumed to be released to 

water and 50% is assumed to be released to the atmosphere. NOTE: The CSR estimates 0.05% loss for this 
activity.

Water

Output 2: 2.4E+0 kg/site-day over 250 day/yr from 16 sites or 9.5E+3 kg/yr

to: Water (50%) or Air (50%) (ESD)

from: Fugitive Air Emission from Converting

basis: User-Defined Loss Rate Model. Based on Plastics Converting GS (2004), Most plastic additives are 

non-volatile; however, converting operations may be performed at elevated temperatures; thus slight volatilization 

may occur. A release of 0.25% of the daily use rate is estimated. Particles are originally released to air but 

subsequent condensation may result in losses to water. As a conservative estimate, 50% is assumed to be released to 

water and 50% is assumed to be released to the atmosphere. NOTE: The CSR estimates 0.05% loss for this 

activity.

Water or Incineration or Landfill

Output 2: 1.9E-1 kg/site-day over 250 day/yr from 16 sites or 7.6E+2 kg/yr

to: water, incineration or landfill (RM-2_

from: Raw Material Spillage

basis: User-Defined Loss Rate Model. A 2010 EU CSR assessment on MCCPs estimated these releases to be 

0.01% of PV with releases to water or solid waste. The 2010 EU CSR estimate is used as a basis to estimate releases 

from spillage.

RELEASE TOTAL

4.4E+5 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 768

Basis: Per 2004 ESD for Plastics Converting, 48 workers/site.

Inhalation:

Exposure to Mist 

High End of Range: 1.5E+1 mg/day over 250 days/yr

Low End of Range: 7.0E-1 mg/day over 250 days/yr

Number of workers (all sites) with Inhalation exposure: 768

Basis: Inhalation Exposure during Converting; User-defined Inhalation Model. A 2008 EU RA on MCCPs and a 2010 EU 

CSR on MCCPs contains monitoring data from rubber manufacturing operations in the EU. The monitoring data suggest MCCP 

air concentrations ranging from 0.01 to 0.07 mg/m3 based on monitoring conducted at 1 site. It is unknown whether these data 

represent area or personal monitoring data. Based on uncertainty in multiple downstream use sites and the fact that these data are 

only basd on 1 site, CEB assesses exposures based on the high end of the EU data range (0.07 mg/m3) and the OSHA PEL (15 

mg/m3 x 0.1 = 1.5 mg/m3).

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

 (b) Hazard Rating for health of 2 or greater? No

Inhalation Monitoring Data Desired? Yes (both criteria met)