blend (10/18/13 contact report) unloaded from 5 gal pails or drums -> consumer product blending (10/18/13 contact report: conc 0.0005% typical, 0.001% max PMN; 99.3% non-powder products) -> packaging

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 Conservative: 2.5E-5 kg/site-day over 125 days/yr from

or 3.2E-2 kg/yr to: uncertain (GS) from: Loading Solid Product into Transport Containers basis: User-Defined Loss Rate Model. GS for dust loss from unloading estimates 0.5% loss.

Water or Incineration or Landfill High End: 2.2E-2 kg/site-day over 125 days/yr from

or 2.7E+1 kg/yr to: Water, incineration, or landfill [per GS] from: Cleaning Liquid Residuals from Containers Used to Transport the Raw Material basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual.

Water or Incineration or Landfill Conservative: 7.2E-3 kg/site-day over 125 days/yr from

or 9.0E+0 kg/yr to: Water, incineration, or landfill [per GS] from: Equipment Cleaning Losses of Liquids from a Single, Large Vessel basis: EPA/OPPT Single Vessel Residual Model, CEB standard 1% residual. Submission states 0.0002 kg/day PMN is released to unknown media during equipment cleaning . CEB standard of 1% assessed as the more conservative estimate. GS is references for media of release as it was not specified in submission.

RELEASE TOTAL 3.6E+1 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 270 Basis: Submission estimated is exposed during drum unloading; GS estimates 27 workers per site. CEB assessed exposure per GS.

Inhalation:packaging

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: 6.2E-2 kg/site-day over 48 days/yr from or 3.0E+0 kg/yr to: uncertain from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual.

Water or Incineration or Landfill Conservative: 1.6E-2 kg/site-day over 125 days/yr from

or 2.0E+0 kg/yr to: uncertain, but water likely for this operation from: Equipment Cleaning Losses of Liquids from Multiple Vessels basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual.

RELEASE TOTAL 5.0E+0 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 27 Basis: Submission estimated 1 worker per site is exposed during drum unloading; GS estimates 27 workers per site. CEB assessed exposure per GS.

Inhalation: negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 1.00% concentration High End: 1.8E+1 mg/day over 125 days/yr Number of workers (all sites) with dermal exposure: 3 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

Exposure to Liquid at 0.00% concentration High End: 1.8E-2 mg/day over 125 days/yr Number of workers (all sites) with dermal exposure: 24 Basis: Loading Liquid Product into Small Containers; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.