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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:

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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.

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