### 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: N ormal 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: N o 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: N o

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: SlowPBT rating: P 2 B 3 T 2 Health: 1, N o 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. //// N ote 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. // N ote, 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: YesP-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/y r - 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/y r 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/y r 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/y r 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/y r to: Uncertainfrom: 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/y r - 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/y r Low End of Range: 3.0E-2 mg/day over 250 days/y r 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? N o Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal:

Exposure to Liquid High End: 2.2E+3 mg/day over 250 days/y r 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 containin g 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/y r 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/y r 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/y r 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/y r - 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/y r 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/y r 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/y r 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/y r 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/y r 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 onebath 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/y r - 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/y r 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/y r

: 3.7E+2 mg/day over 247 days/y r 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/y r Typical: 1.5E+0 mg/day over 247 days/y r 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/m 3 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? N o 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/y r 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/y r 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/y r 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/y r 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. N OTE: The CSR estimates 0.05% loss for thisactivity.

Water Output 2: 2.4E+0 kg/site-day over 250 day/yr from 16 sites or 9.5E+3 kg/y r 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. N OTE: 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/y r - 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/y r Low End of Range: 7.0E-1 mg/day over 250 days/y r 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? N o Inhalation Monitoring Data Desired? Yes (both criteria met)