IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources to the same medium. The release estimates were based on a combination of submitter provided data and data available in various literature sources. A description of the data is provided in the release notes for each source. The submitter stated "Due to the large number of customer and potential sites where the notification substances may be used, specific use information for each site could not be obtained. Rather, these worker exposures and environmental release scenarios are average scenarios for each particular use." Due to the uncertainty at multiple downstream use sites, the most conservative data were chosen when evaluating releases for downstream operations.

2012 EPA Assessment
Water or Incineration or Landfill
High End: 6.2E+0 kg/site-day over 11 day/yr from 110 sites
to: uncertain
2016 Expanded EPA Assessment (Oil-based fluids)
Water or Incineration or Landfill
Monthly: 5.9E+0 kg/site-day over 12 day/yr from 55 sites
Quarterly: 1.8E+1 kg/site-day over 4 day/yr from 55 site
to: Uncertain
2016 EPA Expanded Assessment (water based, on-site pretreatment with 50% efficiency)
Water or Incineration or Landfill
Monthly: 3.0E+0 kg/site-day over 12 day/yr from 55 sites
Quarterly: 8.9E+0 kg/site-day over 4 day/yr from 55 site
to: Pretreatment (50% removal efficiency) then to POTW, incineration or landfill
2016 EPA Expanded Assessment (water based, on-site pretreatment with 70% efficiency)
Water or Incineration or Landfill
Monthly: 1.8E+0 kg/site-day over 12 day/yr from 55 sites
Quarterly: 5.3E+0 kg/site-day over 4 day/yr from 55 site
to: Pretreatment (70% removal efficiency) then to POTW, incineration or landfill
2016 EPA Expanded Assessment (water based, on-site pretreatment with 99% efficiency)
Water or Incineration or Landfill
Monthly: 5.9E-2 kg/site-day over 12 day/yr from 55 sites
Quarterly: 1.8E-1 kg/site-day over 4 day/yr from 55 site
to: Pretreatment (99% removal efficiency) then to POTW, incineration or landfill
from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material
basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. The submission estimates 25.8 kg/day of PMN (25.8/859 = 3%) release to incineration or landfill from drum cleaning. This is consistent with the EPA/OPPT Drum Residual Model.  Due to the uncertainty at multiple downstream sites, RAD assesses release to uncertain media
2016 EPA Expanded Assessment (oil based fluids): Assumes quarterly or monthly container cleaning, per industry information indicating containers are not picked up daily by a waste handler.
2016 EPA Expanded Assessment (water based, on-site pretreatment with 50%, 70% and 99% efficiency): Assumes quarterly or monthly container cleaning, per industry information indicating containers are not picked up daily by a waste handler. Industry information indicates facilities must meet O&G limits.  Discharge to POTW would first be pretreated  -  50 - 99% efficiency.  This presents release to POTW (with pretreatment 50%, 70% and 99% removal efficiency).

2012 EPA Assessment
Water or Incineration or Landfill
High End: 4.2E+0 kg/site-day over 4 day/yr from 110 sites
to: uncertain
2016 Expanded EPA Assessment (Oil-based fluids)
Water or Incineration or Landfill
Monthly: 1.3E+0 kg/site-day over 12 day/yr from 55 sites
Quarterly: 4.0E+0 kg/site-day over 4 day/yr from 55 site
to: Uncertain
2016 EPA Expanded Assessment (water based, on-site pretreatment with 50% efficiency)
Water or Incineration or Landfill
Monthly: 6.6E-1 kg/site-day over 12 day/yr from 55 sites
Quarterly: 2.0E+0 kg/site-day over 4 day/yr from 55 site
to: Pretreatment (50% removal efficiency) then to POTW, incineration or landfill
2016 EPA Expanded Assessment (water based, on-site pretreatment with 70% efficiency)
Water or Incineration or Landfill
Monthly: 3.9E-1 kg/site-day over 12 day/yr from 55 sites
Quarterly: 1.2E+0 kg/site-day over 4 day/yr from 55 site
to: Pretreatment (70% removal efficiency) then to POTW, incineration or landfill
2016 EPA Expanded Assessment (water based, on-site pretreatment with 99% efficiency)
Water or Incineration or Landfill
Monthly: 1.3E-2 kg/site-day over 12 day/yr from 55 sites
Quarterly: 4.0E-2 kg/site-day over 4 day/yr from 55 site
to: Pretreatment (99% removal efficiency) then to POTW, incineration or landfill
from: Cleaning Liquid Residuals from Totes, Tank Trucks, and Rail Cars Used to Transport the Raw Material
basis: EPA/OPPT Bulk Transport Residual Model, CEB standard 0.2% residual. The submission estimates 1.7 kg/day of PMN (1.7/859 = 0.2%) release to incineration or landfill from tote, tank truck, and rail car cleaning. This is consistent with the EPA/OPPT Bulk Transport Residual Model.  Due to the uncertainty at multiple downstream sites, RAD assesses release to uncertain media
2016 EPA Expanded Assessment (oil based fluids): Assumes quarterly or monthly container cleaning, per industry information indicating containers are not picked up daily by a waste handler.
2016 EPA Expanded Assessment (water based, on-site pretreatment with 50%, 70% and 99% efficiency): Assumes quarterly or monthly container cleaning, per industry information indicating containers are not picked up daily by a waste handler. Industry information indicates facilities must meet O&G limits.  Discharge to POTW would first be pretreated  -  50 - 99% efficiency.  This presents release to POTW (with pretreatment 50%, 70% and 99% removal efficiency).

2014 EPA Assessment
Water or Incineration or Landfill
Conservative: 1.7E+1 kg/site-day over 12 day/yr from 110 sites
to: Uncertain
2016 Expanded EPA Assessment (Oil-based fluids)
Incineration or Landfill
Conservative: 8.6E+0 kg/site-day over 12 day/yr from 55 sites
to: Incineration or Landfill (industry comments)
2016 Expanded EPA Assessment (water-based, on-site pretreatment with 50% efficiency)
Water or Incineration or Landfill
Conservative: 4.3E+0 kg/site-day over 12 day/yr from 55 sites or
to: Pretreatment (50% efficiency) then to POTW, incineration or landfill
2016 Expanded EPA Assessment (water-based, on-site pretreatment with 70% efficiency)
Water or Incineration or Landfill
Conservative: 2.6E+0 kg/site-day over 12 day/yr from 55 sites
to: Pretreatment (70% efficiency) then to POTW, incineration or landfill
2016 Expanded EPA Assessment (water-based, on-site pretreatment with 99% efficiency)
Water or Incineration or Landfill
Conservative: 8.6E-2 kg/site-day over 12 day/yr from 55 sites
to: Pretreatment (99% efficiency) then to POTW, incineration or landfill
from: Equipment Cleaning Losses of Liquids from a Mixing Tank
basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual. The submission estimates 17.1 kg/day of PMN (17.1/859 = 2%) release to incineration or landfill from equipment cleaning with cleaning occurring once per year. This is consistent with the EPA/OPPT Multiple Process Vessel Residual Model.  Due to the uncertainty at multiple downstream sites, RAD assesses release to uncertain media assuming cleaning once per day.
2016 EPA Expanded Assessment (Oil-Based Fluids):  Industry information indicates cleaning of equipment that is in contact with MCCPs would not use water.  Therefore, wastes are assumed to incineration or landfill.
2016 EPA Expanded Assessment (water based, on-site pretreatment with 50%, 70% and 99% efficiency):  Industry information indicates facilities must meet O&G limits.  Discharge to POTW would first be pretreated  -  50 - 99% efficiency.  This presents release to POTW (with pretreatment 50%, 70% and 99% removal efficiency).

Air
Output 2: 4.3E-1 kg/site-day over 12 day/yr from 110 sites
to: fugitive air (2002 EU RA, 2010 Japan RA)
from: Fugitive Air Emissions
basis: User-Defined Loss Rate Model. Data from a 2002 EU RA for MCCP estimates 16 kg/yr of MCCP may be released to air from fugitive air emissions generated by preheating and blending at a typical MWF formulation site (16/32,0145 = 0.05% for the current operations). 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 the high-end estimate.

Incineration or Landfill
Output 2: 1.7E+1 kg/site-day over 12 day/yr from 110 sites
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

2012 EPA Assessment: 2.9E+3 kg/yr - all sites
2016 EPA Expanded Assessment (Oil-Based Fluids): 2.6E+4 kg/yr - all sites
2016 EPA Expanded Assessment (water-based, on-site pretreatment with 50% efficiency): 1.9E+4 kg/yr - all sites
2016 EPA Expanded Assessment (water-based, on-site pretreatment with 70% efficiency): 1.6E+4 kg/yr - all sites
2016 EPA Expanded Assessment (water-based, on-site pretreatment with 99% efficiency): 1.2E+4 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 440
Basis: The submission estimates range of 4 to 8 workers/site. As conservative, CEB assesses all 4 workers to PMN at 100% (unloading) and 10% (loading).

Inhalation:
Negligible due to low vapor pressure (VP < 0.001 torr) and physical state as handled (liquid).

Dermal:

Exposure to Liquid
High End: 2.2E+3 mg/day over 38 days/yr
Number of workers (all sites) with Dermal exposure: 440
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: 2.2E+2 mg/day over 38 days/yr
Number of workers (all sites) with Dermal exposure: 440
Basis: Loading Liquid Product into Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

PROC4: Formulation of Engine Lubricant (2% of PV)

Number of Sites/Location: 15 sites
 multiple sites  -  See Attachment 008 for a full list of customers across all downstream operations.

Basis: Per submission, 15 formulation sites, 12 exposure days/yr, PMN used as a liquid at 91.5-100% and formulated down to 4%. The 2000 GS for Lube Oil Additives estimates 300 days/yr of operation. CEB assumes submission estimate of 34 days/yr to maximize kg/site-day releases, 100% PMN in raw material and 4% PMN in product. CS calculates a use rate of 419.92 kg/site-day.
Process Description: PMN (liquid, 91.5-100%) is unloaded from tank trucks (69% of PV), drums (23% of PV), totes (4% of PV), and rail cars (4% of PV) ---> feed into blending tank ---> packaging of lubricant containing PMN (liquid, 4%) into small containers (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. The release estimates were based on a combination of submitter provided data and data available in various literature sources. A description of the data is provided in the release notes for each source. The submitter stated "Due to the large number of customer and potential sites where the notification substances may be used, specific use information for each site could not be obtained. Rather, these worker exposures and environmental release scenarios are average scenarios for each particular use." Due to the uncertainty at multiple downstream use sites, the most conservative data were chosen when evaluating releases for downstream operations.

2012 EPA Assessment
Water
High End: 2.8E+0 kg/site-day over 12 day/yr from 15 sites
to: water (GS)
from: Spillage During Raw Material Handling
basis: User-Defined Loss Rate Model. The 2000 GS for Lube Oil Additives estimates 0.7 kg/site-day of PMN released based on 1% concentration in the lube oil. For 4%, the equivalent release would be 2.8 kg/site-day. Due to the uncertainty at multiple downstream sites, RAD includes this release in the assessment.
EPA 2016 Expanded Assessment: This release source was removed.

Water or Incineration or Landfill
High End: 6.2E+0 kg/site-day over 6 day/yr from 15 sites
to: Water or Incineration or Landfill (submission, GS)
from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material
basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. The submission estimates 12.6 kg/day of PMN (12.6/420 = 3%) release to incineration or landfill from drum cleaning. This is consistent with the EPA/OPPT Drum Residual Model. The 2001 GS for Lube Oil Additives assesses all wastes to water. Due to the uncertainty at multiple downstream sites, RAD assesses release to water or incineration or landfill.

2012 EPA Assessment
Water or Incineration or Landfill
High End: 4.2E+0 kg/site-day over 2 day/yr from 15 sites
to: Water or Incineration or Landfill (submission, GS)
from: Cleaning Liquid Residuals from Totes, Tank Trucks, and Rail Cars Used to Transport the Raw Material
basis: EPA/OPPT Bulk Transport Residual Model, CEB standard 0.2% residual. The submission estimates 0.8 kg/day of PMN (0.8/420 = 0.2%) release to incineration or landfill from tote, tank truck, and rail car cleaning. This is consistent with the EPA/OPPT Bulk Transport Residual Model.  The 2000 GS for Lube Oil Additives assesses all wastes to water. Due to the uncertainty at multiple downstream sites, RAD assesses release to water or incineration or landfill using EPA/OPPT standard model loss fraction of 0.2%.

2012 EPA Assessment
Water or Incineration or Landfill
Conservative: 9.2E+0 kg/site-day over 12 day/yr from 15 sites
to: Water or Incineration or Landfill (submission, GS)
EPA 2016 Expanded Assessment
Incineration or Landfill
Conservative: 9.2E+0 kg/site-day over 12 day/yr from 15 sites
to: Incineration or Landfill (submission, GS)
from: Equipment Cleaning Losses of Liquids from a Mixing Tank
basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual. The submission estimates 8.3 kg/day of PMN (8.3/460.8=1.8%) release to incineration or landfill from equipment cleaning. The 2000 GS for Lube Oil Additives assesses all wastes to water.  Due to the uncertainty at multiple downstream sites, RAD assesses release to uncertain media assuming cleaning once per day.
EPA 2016 Expanded Assessment: Assesses release to incineration or landfill.

RELEASE TOTAL

2012 EPA Assessment: 2.9E+3 kg/yr - all sites
EPA 2016 Expanded Assessment: 3.5E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 225
Basis: The submission estimates up to 8 workers/site. The 2000 GS for Lube Oil Additives estimates 15 workers/site exposed during formulation. As conservative, CEB assesses 15 workers/site.

Inhalation:
Negligible due to low vapor pressure (VP < 0.001 torr) and physical state as handled (liquid).

Dermal:

Exposure to Liquid
High End: 2.2E+3 mg/day over 34 days/yr
Number of workers (all sites) with Dermal exposure: 225
Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

Dermal:

Exposure to Liquid
High End: 9.0E+1 mg/day over 34 days/yr
Number of workers (all sites) with Dermal exposure: 225
Basis: Loading Liquid Product into Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

PROC5: Formulation of Paints, Adhesives and Sealants (0.5% of PV)

Number of Sites/Location: 33 sites
 multiple sites  -  See Attachment 008 for a full list of customers across all downstream operations.
Days/yr: 2
Basis: Per submission, 33 formulation sites, 200-600 kg/bt, 2 bt/yr, PMN used as a liquid at 91.5-100% and formulated down to 5-15% (median 10%). CEB assumes 100% PMN in raw material and 15% PMN in product to conservatively assess exposures. CS calculates a use rate of 286.31 kg/site-bt.
Process Description: PMN (liquid, 91.5-100%) is unloaded from tank trucks (69% of PV), drums (23% of PV), totes (4% of PV), and rail cars (4% of PV) ---> feed into mixing tank with other components ---> filtration ---> packaging of paints, adhesives, and sealants containing PMN (liquid, 5-15%) into small containers (submission, 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 release estimates were based on a combination of submitter provided data and data available in various literature sources. A description of the data is provided in the release notes for each source. The submitter stated "Due to the large number of customer and potential sites where the notification substances may be used, specific use information for each site could not be obtained. Rather, these worker exposures and environmental release scenarios are average scenarios for each particular use." Due to the uncertainty at multiple downstream use sites, the most conservative data were chosen when evaluating releases for downstream operations.

2012 EPA Assessment
Water
High End: 2.9E-2 kg/site-day over 2 day/yr from 33 sites
to: water, incineration or landfill (RM-2)
from: Spillage During Raw Material Handling
basis: User-Defined Loss Rate Model. A 1992 RM-2 assessment for SCCPs estimated these releases to be 0.1% of the PV with 90% of releases going to incineration or landfill and 10% going to water. As conservative, CEB assesses these releases due to uncertainty at multiple downstream sites.
EPA 2016 Expanded Assessment: This release source was removed.

Water or Incineration or Landfill
High End: 6.2E+0 kg/site-day over 1 day/yr from 33 sites
to: Water or 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 estimates 8.5 kg/day of PMN (8.5/286 = 3%) release to landfill from drum cleaning. This is consistent with the EPA/OPPT Drum Residual Model. The 2010 ESD for Formulation of Radiation Curable Coatings, Inks, and Adhesives and the 2011 GS for the Formulation of Waterborne Coatings use the EPA/OPPT Model and assesses releases to water, incineration or landfill.  As conservative, CEB assesses these releases to water, incineration or landfill.

Water or Incineration or Landfill
High End: 1.2E+0 kg/site-day over 1 day/yr from 33 sites
to: Water or Incineration or Landfill (ESD)
from: Cleaning Liquid Residuals from Totes, Tank Trucks, and Rail Cars Used to Transport the Raw Material
basis: EPA/OPPT Bulk Transport Residual Model, CEB standard 0.2% residual. The submission estimates 0.71 kg/day of PMN (0.71/356 = 0.2%) release to landfill from tote, tank truck, and rail car cleaning. This is consistent with the EPA/OPPT Bulk Transport Residual Model.  The 2009 GS for Adhesives Formulation assesses container residuals to uncertain media.

Water or Incineration or Landfill
Conservative: 7.2E+0 kg/site-day over 2 day/yr from 33 sites
to: Water or Incineration or Landfill (submission, GS)
from: Equipment Cleaning Losses of Liquids from a Mixing Tank
basis: User-Defined Loss Rate Model. The submission estimates 7.1 kg/site-day of PMN (7.1/286 = 2.5%) release to incineration from equipment cleaning. The 2010 ESD for Formulation of Radiation Curable Coatings, Inks, and Adhesives uses the EPA/OPPT Single Vessel Residual Model an assesses release to incineration or landfill. The 2011 GS for the Formulation of Waterborne Coatings uses a 2% loss rate with releases to water, incineration or landfill.  As conservative, CEB assesses these releases to water, incineration or landfill using a 2.5% loss rate.

2012 EPA Assessment
Incineration or Landfill
High End: 2.6E-1 kg/site-day over 2 day/yr from 33 sites
to: water, incineration or landfill (RM-2)
from: Spillage During Raw Material Handling
basis: User-Defined Loss Rate Model. A 1992 RM-2 assessment for SCCPs estimated these releases to be 0.1% of the PV with 90% of releases going to incineration or landfill and 10% going to water. As conservative, CEB assesses these releases due to uncertainty at multiple downstream sites.
EPA 2016 Expanded Assessment: This release source was removed.

Incineration or Landfill
High End: 2.9E+0 kg/site-day over 2 day/yr from 33 sites
to: incineration or landfill (RM-2, ESD)
from: Filter Media Disposal
basis: User-Defined Loss Rate Model. The submission does not address spent filter waste. Both the 2010 ESD for Formulation of Radiation Curable Coatings, Inks, and Adhesives and the 1992 RM-2 assessment for SCCPs estimates 1% loss from spent filter disposal with releases to incineration or landfill.  The 2011 GS for the Formulation of Waterborne Coatings uses a loss rate of 0.02% with releases to incineration. As conservative, the RM-2 and ESD estimate of 1% with releases to incineration or landfill is used.

2012 EPA Assessment
Incineration or Landfill
2002 EU RA Estimate: 1.4E+1 kg/site-day over 2 day/yr from 33 sites
to: incineration or landfill (RM-2, 2002 EU RA)
EPA 2016 Expanded Assessment
Incineration or Landfill
Output 2: 2.9E+2 kg/site-day over 1 day/yr from 33 sites
to: incineration or landfill (RM-2, 2002 EU RA, industry comments)
from: Spoiled Batches
basis: User-Defined Loss Rate Model. A 1992 RM-2 assessment for SCCPs estimates a loss rate of 0.2% from spoiled batches with releases to incineration or landfill. A 2002 EU RA for MCCPs estimates a loss rate of 5% from scrap material and equipment cleaning with release to incineration or landfill.  The 2011 GS for the Formulation of Waterborne Coatings uses a loss rate of 1.2% for off-spec material with release to incineration. As conservative, CEB estimates up to 5% loss from scrap material with releases to incineration or landfill.
EPA 2016 Expanded Assessment: The 2009 ESD for Adhesives Formulation estimates release from off-spec batches with 1% off batches being off-spec and released to water, incineration or landfill. This is equal to (2 bt/site-yr x 0.01) = 0.02 bt/yr (rounded to 1). At 236.31 kg/site-t and 1 off-spec bt/yr, it is assumed that 236.31 kg/site-day will be released over 1 day/yr. Industry comments indicate that off-spec product is handled as hazardous waste. Therefore, EPA assumes wastes are sent to landfill or incineration.

RELEASE TOTAL

2012 EPA Assessment: 1.8E+3 kg/yr - all sites
EPA 2016 Expanded Assessment: 1.3E+4 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 1,287
Basis: The submission estimates up to 4 workers/site. The 2010 ESD for Formulation of Radiation Curable Coatings, Inks, and Adhesives estimates 39 workers/site. As conservative, CEB assesses 39 workers/site.

Inhalation:
Negligible due to low vapor pressure (VP < 0.001 torr) and physical state as handled (liquid).

Dermal:

Exposure to Liquid
High End: 2.2E+3 mg/day over 5 days/yr
Number of workers (all sites) with Dermal exposure: 1,287
Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

Dermal:

Exposure to Liquid
High End: 3.4E+2 mg/day over 34 days/yr
Number of workers (all sites) with Dermal exposure: 1,287
Basis: Loading Liquid Product into Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

USE1: Plastics Converting (43% of PV)

Number of Sites/Location: 32 unknown site(s)
Basis: Submission does not provide information on plastics converting. Per submission, the upstream compounding process yields plastic pellets containing 12  -  30% (median 21%) PMN. RAD assumes 30% as conservative for exposures. The 2004 GS on Plastics Converting is referenced to estimate general facility estimates. The GS assumes 250 day/yr of operation. Based on literature data, PVC is the most common plastic in which CPs are used as flame retardants and plasticizers. Using annual production volume of PVC from the GS, the use rate is calculated as: 6,680,000,000 kg plastic/yr / 12,191 total sites / 250 days/yr x 0.12 = 18,265 kg/site-day. Based on this use rate, CS calculates 1 end use site. Since the calculated number of end use sites, number of upstream processing sites, RAD assumes 1 customer per compounding site, or 32 converting sites. CS calculates an adjusted use rate of 203.14 kg/site-day.

Process Description: Plastic pellets or other solid form containing PMN (solid, 12-30%) are unloaded ---> forming (heating) ---> molding and shaping using various processes (injection molding, extrusion, casting, calendaring, etc.) ---> trimming ---> finishing ---> finished plastic article (GS)

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 address the potential for plastics converting operations after compounding into plastics pellets. The technical contact indicate that these operations were considered but estimates were not provided due to lack of information on downstream processes after compounding. The release estimates are based on data available in various literature sources. A description of the data is provided in the release notes for each source. Due to the uncertainty at multiple downstream use sites, the most conservative data were chosen when evaluating releases for downstream operations

Water
Output 2: 1.5E-1 kg/site-day over 250 day/yr from 32 sites
to: Water (50%) or Air (50%) (ESD, 2010 EU CSR)
from: Fugitive Air Emission During Forming and Molding
basis: User-Defined Loss Rate Model. The submission does not address plastic converting operations. Data from various literature sources suggests that fugitive air emissions generated during forming and molding can range between 0.002 to 0.15% with engineering controls depending on the type of conversion process (e.g. extrusion, injection molding, calendaring). The Plastics Converting GS (2004) estimates that 50% of air emissions will settle and ultimately released to water while the other 50% remains in air. As conservative, RAD assesses fugitive air emissions at a loss rate of 0.15% with 50% to water and 50% to air.

EPA 2012 Assessment
Water or Incineration or Landfill
Output 2: 2.0E-2 kg/site-day over 250 day/yr from 32 sites
to: water, incineration or landfill (RM-2)
EPA 2016 Expanded Assessment:
Water or Incineration or Landfill
High-End: 2.0E-2 kg/site-day over 250 day/yr from 32 sites
Low-End: 1.0E-3 kg/site-day over 250 day/yr from 32 sites
to: water, incineration or landfill (RM-2)
from: Raw Material Spillage
basis: User-Defined Loss Rate Model. The submission does not address plastic converting operations. A 1992 RM-2 assessment for SCCPs estimated release from spills to be 0.1% of the PV with 90% of releases going to incineration or landfill and 10% going to water. 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.
EPA 2016 Expanded Assessment: Industry information indicates use of industrial traps in drains would capture 95% of spillage lost to drains before going to water. Both 95% and 0% removal efficiencies have been presented.

Water or Incineration or Landfill
Output 2: 2.0E+0 kg/site-day over 250 day/yr from 32 sites
to: water, incineration or landfill (GS)
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. The submission does not address plastic converting operations. The 2004 GS for Plastics Converting estimates releases from container cleaning using the EPA/OPPT model for solid residuals with releases to water, incineration or landfill.

EPA 2012 Assessment
Water or Incineration or Landfill
Conservative: 4.1E+0 kg/site-day over 250 day/yr from 32 sites
to: water, incineration or landfill (GS)
EPA 2016 Expanded Assessment
Incineration or Landfill
Conservative: 4.1E+0 kg/site-day over 250 day/yr from 32 sites
to: water, incineration or landfill (GS)
from: Equipment Cleaning Losses of Liquids from Multiple Vessels
basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual. The submission does not address plastic converting operations. The 2004 GS for Plastics Converting estimates releases from equipment cleaning using the EPA/OPPT model loss rate of 2% with releases to water, incineration or landfill.
EPA 2016 Expanded Assessment: Converted plastics material considered mostly likely to be handled as solid waste and disposed by landfill or incineration.

EPA 2012 Assessment
Water or Landfill
Output 2: 5.1E+0 kg/site-day over 250 day/yr from 32 sites
to: water or landfill (GS)
EPA 2016 Expanded Assessment
Incineration or Landfill
Output 2: 5.1E+0 kg/site-day over 250 day/yr from 32 sites
to: incineration or landfill
from: Scrap Material
basis: User-Defined Loss Rate Model. The submission does not address plastic converting operations. A 1992 RM-2 assessment for SCCPs estimated scrap from trimming to be 1% of the PV with 90% of releases going to landfill. The 2004 GS for Plastics Converting estimated these releases to be 2.5% of PV with releases to water or landfill. This is based on the assumption that large pieces of scrap material will be disposed to landfill via solid waste and dust generated during trimming will settle to the floor and be washed away to wastewater during cleaning. Due to multiple unknown downstream sites, RAD conservatively assesses a 2.5% loss rate with release to water or landfill based on the GS.
2016 Expanded EPA Assessment:  Scrap material expected to be handled as solid waste and disposed by landfill or incineration.

Air
Output 2: 1.5E-1 kg/site-day over 250 day/yr from 32 sites
to: Water (50%) or Air (50%) (ESD, 2010 EU CSR)
from: Fugitive Air Emission During Forming and Molding
basis: User-Defined Loss Rate Model. The submission does not address plastic converting operations. Data from various literature sources suggests that fugitive air emissions generated during forming and molding can range between 0.002 to 0.15% with engineering controls depending on the type of conversion process (e.g. extrusion, injection molding, calendaring). The Plastics Converting GS (2004) estimates that 50% of air emissions will settle and ultimately released to water while the other 50% remains in air. As conservative, RAD assesses fugitive air emissions at a loss rate of 0.15% with 50% to water and 50% to air.

EPA 2012 Assessment
Air
Output 2: 4.6E-1 kg/site-day over 250 day/yr from 32 sites
to: air or landfill w/ 99% dust collection efficiency (RM-2)
EPA 2016 Expanded Assessment
Water or Landfill
Output 2: 2.0E-2 kg/site-day over 250 day/yr from 32 sites
to: water or landfill
from: Dust Generation from Converting
basis: User-Defined Loss Rate Model. The submission does not address plastic converting operations. A 1992 RM-2 assessment for SCCPs estimated a loss rate of 75g/kg of plastic produced with 1% of release to air and 99% to landfill based on a 99% dust collection efficiency. Based on a MCCP concentration of 30%, the loss rate for PMN during plastic converting is 75g/kg of plstic x 0.3 = 22.5 g/kg of plastic or 2.5%.
EPA 2016 Expanded Assessment: Dust initially to air but expected to settle to ground and be cleaned from equipment and floor with water or disposed directly to landfill.

EPA 2012 Assessment
Landfill
Output 2: 4.5E+0 kg/site-day over 250 day/yr from 32 sites
to: air or landfill w/ 99% dust collection efficiency (RM-2)
EPA 2016 Expanded Assessment
Water or Landfill
Output 2: 2.0E-2 kg/site-day over 250 day/yr from 32 sites
to: water or landfill
from: Dust Generation from Converting
basis: User-Defined Loss Rate Model. The submission does not address plastic converting operations. A 1992 RM-2 assessment for SCCPs estimated a loss rate of 75g/kg of plastic produced with 1% of release to air and 99% to landfill based on a 99% dust collection efficiency. Based on a MCCP concentration of 30%, the loss rate for PMN during plastic converting is 75g/kg of plstic x 0.3 = 22.5 g/kg of plastic or 2.5%.
EPA 2016 Expanded Assessment: Dust initially to air but expected to settle to ground and be cleaned from equipment and floor with water or disposed directly to landfill.

RELEASE TOTAL
EPA 2012 Assessment: 1.3E+5 kg/yr - all sites
EPA 2016 Expanded Assessment: 9.4E+4 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY
Tot. # of workers exposed via assessed routes: 1,536
Basis: Per 2004 GS for Plastics Converting, 48 workers/site.

Inhalation:
Exposure to Particulate
High End of Range: 4.5E+1 mg/day over 250 days/yr
Low End of Range: 1.2E+1 mg/day over 250 days/yr
Number of workers (all sites) with Inhalation exposure: 1,536
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 PVC converting operations in the EU. The monitoring data suggest MCCP air concentrations ranging from <0.01 to 1.2 mg/m[3] depending on the type of converting process. These data are based on over 28 samples taken from 4 sites. It is unknown whether these data represent area or personal monitoring data. The 2004 GS for Plastics Converting estimates exposures during converting using the OSHA PEL Limiting Model. Based on uncertainty in multiple downstream use sites and the fact that these data are only based on 4 sites, RAD assesses exposures based on the high end of the EU data range (1.2 mg/m[3]) and the OSHA PEL (15 mg/m[3] x 0.3 = 4.5 mg/m[3]).

INHALATION MONITORING DATA REVIEW
 Uncertainty (estimate based on model, regulatory limit, or data not specific to industry): Yes
 (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:
The PMN will be encapsulated in plastic pellets during handling of plastic raw material.  While some surface contact may occur, dermal exposure to solids in this form are non-quantifiable.

USE2: Rubber Converting (24% of PV)

Number of Sites/Location: 33 unknown site(s)
Basis: Submission does not provide information on rubber converting. Per submission, the upstream compounding process yields rubber sheets containing 1-10% (median 5.5%) PMN. RAD assumes 10% as conservative for exposures and 250 days/yr based on the 2004 GS on Plastics Converting. Calculation using the 2004 GS yields the number of end use sites < number of upstream processing sites. Therefore, RAD assumes 1 customer per compounding site, or 33 converting sites. CS calculates an adjusted use rate of 109.94 kg/site-day.

Process Description: Rubber sheets or other solid form containing PMN (solid, 1-10%) are unloaded ---> forming (heating) ---> molding and shaping using various processes (injection molding, extrusion, casting, calendaring, etc.) ---> trimming ---> finishing ---> finished rubber article (GS)

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 address the potential for rubber converting operations after compounding into rubber sheets. The technical contact indicate that these operations were considered but estimates were not provided due to lack of information on downstream processes after compounding. The release estimates are based on data available in various literature sources. A description of the data is provided in the release notes for each source. Due to the uncertainty at multiple downstream use sites, the most conservative data were chosen when evaluating releases for downstream operations

 2016 Expanded EPA Assessment Approach:  Industry comments indicate cutting/trimming of rubber is the only activity considered "converting" with minimal waste sent to solid waste.  Activities such as in plastics converting would not occur for rubber "converting" therefore no wastes would be generated from empty containers or volatile releases during converting.  For the 2016 Expanded EPA Assessment, releases from scrap material were kept in the assessment.  Releases from all other sources were removed.

EPA 2012 Assessment
Water
Output 2: 2.7E-1 kg/site-day over 250 day/yr from 33 sites
to: Water (50%) or Air (50%) (ESD, 2010 EU CSR)
from: Fugitive Air Emission During Forming and Molding
basis: User-Defined Loss Rate Model. The submission does not address rubber converting operations. Data from various literature sources suggests that fugitive air emissions generated during forming and molding can range between 0.002 to 0.05% with engineering controls depending on the type of conversion process (e.g. extrusion, injection molding, calendaring). The Plastics Converting GS (2004) estimates that 50% of air emissions will settle and ultimately released to water while the other 50% remains in air. As conservative, RAD assesses fugitive air emissions at a loss rate of 0.05% with 50% to water and 50% to air.
EPA 2016 Expanded Assessment: This release source was removed.

EPA 2012 Assessment
Water or Incineration or Landfill
Suggested Estimate: 1.1E-2 kg/site-day over 250 day/yr from 33 sites
to: water, incineration or landfill (RM-2)
from: Raw Material Spillage
basis: User-Defined Loss Rate Model. The submission does not address rubber converting operations. A 1992 RM-2 assessment for SCCPs estimated release from spills to be 0.1% of the PV with 90% of releases going to incineration or landfill and 10% going to water. 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.
EPA 2016 Expanded Assessment: This release source was removed.

EPA 2012 Assessment
Water or Incineration or Landfill
Output 2: 1.1E+0 kg/site-day over 250 day/yr from 33 sites
to: water, incineration or landfill (GS)
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. The submission does not address rubber converting operations. The 2004 GS for Plastics Converting estimates releases from container cleaning using the EPA/OPPT model for solid residuals with releases to water, incineration or landfill.
EPA 2016 Expanded Assessment: This release source was removed.

EPA 2012 Assessment
Water or Incineration or Landfill
Conservative: 2.2E+0 kg/site-day over 250 day/yr from 33 sites
to: water, incineration or landfill (GS)
from: Equipment Cleaning Losses of Liquids from Multiple Vessels
basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual. The submission does not address rubber converting operations. The 2004 GS for Plastics Converting estimates releases from equipment cleaning using the EPA/OPPT model loss rate of 2% with releases to water, incineration or landfill.
EPA 2016 Expanded Assessment: This release source was removed.

EPA 2012 Assessment
Water or Landfill
Output 2: 2.7E+0 kg/site-day over 250 day/yr from 33 sites
to: water or landfill (GS)
EPA 2016 Expanded Assessment
Output 2: 2.7E+0 kg/site-day over 250 day/yr from 33 sites
to: incineration or landfill (industry comments)
from: Scrap Material
basis: User-Defined Loss Rate Model. The submission does not address rubber converting operations. A 1992 RM-2 assessment for SCCPs estimated scrap from trimming to be 1% of the PV with 90% of releases going to landfill. The 2004 GS for Plastics Converting estimated these releases to be 2.5% of PV with releases to water or landfill. This is based on the assumption that large pieces of scrap material will be disposed to landfill via solid waste and dust generated during trimming will settle to the floor and be washed away to wastewater during cleaning. Due to multiple unknown downstream sites, RAD conservatively assesses a 2.5% loss rate with release to water or landfill based on the GS.
2016 Expanded EPA Assessment:  Industry comments indicate cutting/trimming of rubber is the only activity considered "converting" with minimal waste sent to solid waste (incineration or landfill).

EPA 2012 Assessment
Air
Output 2: 2.7E-1 kg/site-day over 250 day/yr from 33 sites
to: Water (50%) or Air (50%) (ESD, 2010 EU CSR)
from: Fugitive Air Emission During Forming and Molding
basis: User-Defined Loss Rate Model. The submission does not address rubber converting operations. Data from various literature sources suggests that fugitive air emissions generated during forming and molding can rande between 0.002 to 0.05% with engineering controls depending on the type of conversion process (e.g. extrusion, injection molding, calendaring). The Plastics Converting GS (2004) estimates that 50% of air emissions will settle and ultimately released to water while the other 50% remains in air. As conservative, RAD assesses fugitive air emissions at a loss rate of 0.05% with 50% to water and 50% to air.
 EPA 2016 Expanded Assessment:  This release source was removed.

EPA 2012 Assessment
Air
Output 2: 1.2E-3 kg/site-day over 250 day/yr from 33 sites
to: air or landfill w/ 99% dust collection efficiency (RM-2)
from: Dust Generation from Converting
basis: User-Defined Loss Rate Model. The submission does not address rubber converting operations. A 1992 RM-2 assessment for SCCPs estimated a loss rate of 11g/kg of rubber produced with 1% of release to air and 99% to landfill based on a 99% dust collection efficiency. Based on a MCCP concentration of 10%, the loss rate for PMN during rubber converting is 11g/kg of plstic x 0.1 = 1.1 g/kg of plastic or 0.11%.
EPA 2016 Expanded Assessment: This release source was removed.

EPA 2012 Assessment
Landfill
Output 2: 1.2E-1 kg/site-day over 250 day/yr from 33 sites
to: air or landfill w/ 99% dust collection efficiency (RM-2)
from: Dust Generation from Converting
basis: User-Defined Loss Rate Model. The submission does not address rubber converting operations. A 1992 RM-2 assessment for SCCPs estimated a loss rate of 11g/kg of rubber produced with 1% of release to air and 99% to landfill based on a 99% dust collection efficiency. Based on a MCCP concentration of 10%, the loss rate for PMN during rubber converting is 11g/kg of plstic x 0.1 = 1.1 g/kg of plastic or 0.11%.
EPA 2016 Expanded Assessment: This release source was removed.

RELEASE TOTAL

2012 EPA Assessment: 5.6E+4 kg/yr - all sites
EPA 2016 Expanded Assessment: 2.3E+4 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 1,584
Basis: Per 2004 GS for Plastics Converting, 48 workers/site.

Inhalation:

2012 EPA Assessment
Exposure to Vapor
2008 EU RA Data: 7.0E-1 mg/day over 250 days/yr
OSHA PEL: 1.5E+1 mg/day over 250 days/yr
Number of workers (all sites) with Inhalation exposure: 1,584
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/m[3] 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 based on 1 site, RAD assesses exposures based on the high end of the EU data range (0.07 mg/m[3]) and the OSHA PEL (15 mg/m[3] x 0.1 = 1.5 mg/m[3]).
EPA 2016 Expanded Assessment: Inhalation exposure not assessed; the PMNis entrained in sheet product. Therefore, inhalation exposure is not expected from solid sheet handling.

INHALATION MONITORING DATA REVIEW

 Uncertainty (estimate based on model, regulatory limit, or data not specific to industry): Yes
 (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:

	The PMN will be encapsulated in rubber sheets during handling of plastic raw material.  While some surface contact may occur, dermal exposure to solids in this form are non-quantifiable.

USE3: Use of Metalworking Fluids (30% of PV)

Number of Sites/Location: 250 sites .
multiple sites  -  See Attachment 008 for a full list of customers across all downstream operations.

Days/yr: 247

Basis: Per submission, 9,070 MWF use sites, 300 exposure days/yr, PMN used as a liquid at 5-10% (median 7.5%) and diluted to 1.25-2.5% (median 1.875%) during use. The 2011 ESD for MWF Operations estimates 247 days/yr of operation. The ESD estimates the number of sites as: (1,133,784 kg/yr) / (12,000 gal/site-yr x 1 kg/L x 3.785 L/gal x 0.1) = 250 sites. As conservative, RAD assumes 247 days/yr of operation and the ESD estimate of 250 sites to maximize kg/site-day release. RAD also assume 10% PMN in the raw material, and 2.5% PMN during metalworking operations. CS calculates a use rate of 18.3609 kg/site-day.
Process Description: Bulk MWF containing PMN (liquid, 5 - 10%, median 7.5%) 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 release estimates were based on a combination of submitter provided data and data available in various literature sources. A description of the data is provided in the release notes for each source. The submitter stated "Due to the large number of customer and potential sites where the notification substances may be used, specific use information for each site could not be obtained. Rather, these worker exposures and environmental release scenarios are average scenarios for each particular use." Due to the uncertainty at multiple downstream use sites, the most conservative data were chosen when evaluating releases for downstream operations.

2012 EPA Assessment
Water or Incineration or Landfill
High End: 6.2E-1 kg/site-day over 218 day/yr from 250 sites
to: water, incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Oil-Based Fluids)
Incineration or Landfill
High End: 6.2E-1 kg/site-day over 77 day/yr from 125 sites
to: incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 50% on-site pretreatment)
Water, Incineration or Landfill
High End: 3.1E-1 kg/site-day over 77 day/yr from 125 sites
to: Pretreatment (50% efficiency) then to POTW, incineration or landfill
2016 Expanded EPA Assessment (Water-Based Fluids, 70% on-site pretreatment)
Water, Incineration or Landfill
High End: 1.9E-1 kg/site-day over 77 day/yr from 125 sites
to: Pretreatment (70% efficiency) then to POTW, incineration or landfill
2016 Expanded EPA Assessment (Water-Based Fluids, 99% on-site pretreatment)
Water, Incineration or Landfill
High End: 6.2E-3 kg/site-day over 77 day/yr from 125 sites
to: Pretreatment (99% efficiency) then to POTW, incineration or landfill
from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material
basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. The submission estimates 0.15 kg/site-day of PMN (~3% based on the use rate derived from the submission estimate of 9,070 sites) released to landfill from container residuals. The 2011 ESD for MWF Operations estimates releases using the EPA/OPPT Drum Residual Model (3% loss rate) with releses to water incineration or landfill. Due to uncertainty at multiple downstream sites, these releases are assessed to uncertain media using a 3% loss rate per the ESD.
2016 Expanded EPA Assessment (Oil-Based Fluids): 2011 OECD ESD for Use of Metalworking Fluids assesses spend metalworking fluids for oil-based fluids to incineration or landfill:
2016 Expanded EPA Assessment (Water-Based Fluids with on-site pretreatment with 50%, 70% and 99% efficiency). Industry information indicates facilities must meet O&G limits.  Discharge to POTW would first be pretreated  -  50 - 99% efficiency.  This presents release to POTW (with pretreatment 50%, 70% and 99% removal efficiency).

2012 EPA Assessment
Water
Output 2: 2.0E+0 kg/site-day over 247 day/yr from 250 sites
to: on-site WWTP or POTW (ESD)
2016 Expanded EPA Assessment (Oil-Based Fluids)
Water or Incineration or Landfill
Output 2: 7.0E-1 kg/site-day over 247 day/yr from 125 sites
to: water, incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 50% on-site pretreatment)
Water, Incineration or Landfill
High End: 3.5E-1 kg/site-day over 247 day/yr from 125 sites
to: on-site WWTP or POTW (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 70% on-site pretreatment)
Water, Incineration or Landfill
High End: 2.1E-1 kg/site-day over 247 day/yr from 125 sites
to: on-site WWTP or POTW (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 99% on-site pretreatment)
Water, Incineration or Landfill
High End: 7.0E-3 kg/site-day over 247 day/yr from 125 sites
to: on-site WWTP or POTW (ESD)
from: Dragout Losses
basis: User-Defined Loss Rate Model. The submission estimates an aggregated loss of 1% from misting/evaporation and dragout with release to POTW. 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. These data provide the best representation of U.S. operations and are more conservative than the submitter estimates. 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.
2016 Expanded EPA Assessment¨ 2011 OECD ESD for Use of Metalworking Fluids assesses dragout losses of metalworking fluids for oil-based fluids to water, incineration or landfill.
2016 Expanded EPA Assessment (Water-Based Fluids with on-site pretreatment with 50%, 70% and 99% efficiency).  Industry information indicates facilities must meet O&G limits.  Discharge to POTW would first be pretreated  -  50 - 99% efficiency.  This presents release to POTW (with pretreatment 50%, 70% and 99% removal efficiency).

2012 EPA Assessment
Water or Incineration or Landfill
Output 2: 6.4E+0 kg/site-day over 247 day/yr from 250 sites
to: water, incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Oil-Based Fluids)
Incineration or Landfill
Output 2: 2.3E+0 kg/site-day over 247 day/yr from 125 sites
to: incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 50% on-site pretreatment)
Water, Incineration or Landfill
High End: 1.1E+0 kg/site-day over 247 day/yr from 125 sites
to: Pretreatment (50% efficiency) then to POTW, incineration or landfill
2016 Expanded EPA Assessment (Water-Based Fluids, 70% on-site pretreatment)
Water, Incineration or Landfill
High End: 6.8E-1 kg/site-day over 247 day/yr from 125 sites
to: Pretreatment (70% efficiency) then to POTW, incineration or landfill
2016 Expanded EPA Assessment (Water-Based Fluids, 99% on-site pretreatment)
Water, Incineration or Landfill
High End: 2.3E-2 kg/site-day over 247 day/yr from 125 sites
to: Pretreatment (99% efficiency) then to POTW, incineration or landfill
from: Filter Media and Other Recycling Waste
basis: User-Defined Loss Rate Model. The submitter does not address releases from recycling or filter media losses. 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 uncertainty at multiple downstream use sites.
2016 Expanded EPA Assessment (Oil-Based Fluids) 2011 OECD ESD for Use of Metalworking Fluids assesses disposal of filter media and other recycling waste to incineration or landfill for oil-based fluids.
2016 Expanded EPA Assessment (Water-Based Fluids with on-site pretreatment with 50%, 70% and 99% efficiency). Industry information indicates facilities must meet O&G limits.  Discharge to POTW would first be pretreated  -  50 - 99% efficiency.  This presents release to POTW (with pretreatment 50%, 70% and 99% removal efficiency).

2012 EPA Assessment
Water or Incineration or Landfill
Output 2: 8.2E+0 kg/site-day over 247 day/yr from 250 sites
to: water, incineration, or landfill (ESD)
2016 Expanded EPA Assessment Oil-Based Fluids)
Incineration or Landfill
Output 2: 3.4E+0 kg/site-day over 247 day/yr from 125 sites
to: incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 50% on-site pretreatment)
Water, Incineration or Landfill
High End: 1.7E+0 kg/site-day over 247 day/yr from 125 sites
to: Pretreatment (50% efficiency) then to POTW, incineration or landfill
2016 Expanded EPA Assessment (Water-Based Fluids, 70% on-site pretreatment)
Water, Incineration or Landfill
High End: 1.0E+0 kg/site-day over 247 day/yr from 125 sites
to: Pretreatment (70% efficiency) then to POTW, incineration or landfill
2016 Expanded EPA Assessment (Water-Based Fluids, 99% on-site pretreatment)
Water, Incineration or Landfill
High End: 3.4E-2 kg/site-day over 247 day/yr from 125 sites
to: Pretreatment (99% efficiency) then to POTW, incineration or landfill
from: Spent Metalworking Fluid
basis: User-Defined Loss Rate Model. The submission assesses the remaining fluid to POTW from spent MWF disposal with bath changeouts occurring 5 times/yr. 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 occurring 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.
2016 Expanded EPA Assessment (Oil-Based Fluids) 2011 OECD ESD for Use of Metalworking Fluids assesses disposal of spent metalworking fluid to incineration or landfill for oil-based fluids.
2016 Expanded EPA Assessment (Water-Based Fluids with on-site pretreatment with 50%, 70% and 99% efficiency). Industry information indicates facilities must meet O&G limits.  Discharge to POTW would first be pretreated  -  50 - 99% efficiency.  This presents release to POTW (with pretreatment 50%, 70% and 99% removal efficiency).

2012 EPA Assessment
Air
Output 2: 8.9E-1 kg/site-day over 247 day/yr from 250 sites
to: air (2002 EU RA)
from: Misting/Evaporation
basis: User-Defined Loss Rate Model. The submission estimates an aggregate los rate of 1% from misting/evaporation and dragout. 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
EPA 2016 Expanded Assessment: This release source was removed.

RELEASE TOTAL
2012 EPA Assessment: 1.1E+6 kg/yr - all sites
2016 Expanded EPA Assessment (Oil-Based Fluids): 5.7E+5 kg/yr - all sites
2016 Expanded EPA Assessment (Water-Based Fluids, 50% on-site pretreatment): 2.8E+5 kg/yr - all sites
2016 Expanded EPA Assessment (Water-Based Fluids, 70% on-site pretreatment): 1.7E+5 kg/yr - all sites
2016 Expanded EPA Assessment (Water-Based Fluids, 99% on-site pretreatment): 5.7E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY
Tot. # of workers exposed via assessed routes: 24,000
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.

Inhalation:
Exposure to Mist
High End of Range: 3.6E+0 mg/day over 247 days/yr
Typical: 9.8E-1 mg/day over 247 days/yr
Number of workers (all sites) with Inhalation exposure: 24,000
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/m[3] 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 25% of the mist. (GS assumes that water conc. is 60% and the PMN is then estimated to be 10/40 = 25% of the mist.

INHALATION MONITORING DATA REVIEW
 Uncertainty (estimate based on model, regulatory limit, or data not specific to industry): Yes
 (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+2 mg/day over 247 days/yr
Number of workers (all sites) with Dermal exposure: 24,000
Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

Dermal:
Exposure to Mist
Output 1: 4.9E+2 mg/day over 247 days/yr
Number of workers (all sites) with Dermal exposure: 24,000
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 operations.

USE4: Use of Engine Lubricant (1.6% of PV)

Number of Sites/Location: 16 sites
unknown sites

Basis: Per submission, 16 commercial automotive sites, 250 days/yr, PMN in lube oil at 4%. CS calculates a use rate of 15.1171 kg/site-day.
Process Description: Lube oil containing PMN (liquid, 4%) is unloaded from small containers ---> lube oil added to engine ---> after service life, spent oil removed from engine and disposed of (submission, GS)

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 release estimates were based on a combination of submitter provided data and data available in various literature sources. A description of the data is provided in the release notes for each source. The submitter stated "Due to the large number of customer and potential sites where the notification substances may be used, specific use information for each site could not be obtained. Rather, these worker exposures and environmental release scenarios are average scenarios for each particular use." Due to the uncertainty at multiple downstream use sites, the most conservative data were chosen when evaluating releases for downstream operations.

Incineration
Output 1: 1.3E+1 kg/site-day over 250 day/yr from 16 sites
to: incineration or landfill (submission, GS)
from: Spent Oil Disposal
basis: User-Defined Loss Rate Model. The submission estimates 10.9 kg/site-day of PMN (10.9/15.12 = 72%) released to incineration and 1.09 kg/site-day of PMN (1.09/15.12 = 7%) released to landfill from spent oil disposal. The 2000 GS for Lube Oil Additives estimates 83.2% to incineration and 7.7% to landfill. As conservative, CEB uses the GS loss rate estimates.

Incineration or Landfill
High End: 9.1E-2 kg/site-day over 250 day/yr from 16 sites
to: Incineration or Landfill (submission, GS)
from: Cleaning Liquid Residuals from Small Containers Used to Transport the Raw Material
basis: EPA/OPPT Small Container Residual Model, CEB standard 0.6% residual. The submission estimates 0.08 kg/site-day of PMN (0.08/15.1 = 0.53%) release landfill from container cleaning. The 2000 GS for Lube Oil Additives assesses releases to incineration or landfill. Due to the uncertainty at multiple downstream sites, CEB assesses these releases to incineration or landfill using the EPA/OPPT Small Container loss rate of 0.6%.

Landfill
Output 1: 1.2E+0 kg/site-day over 250 day/yr from 16 sites
to: incineration or landfill (submission, GS)
from: Spent Oil Disposal
basis: User-Defined Loss Rate Model. The submission estimates 10.9 kg/site-day of PMN (10.9/15.12 = 72%) released to incineration and 1.09 kg/site-day of PMN (1.09/15.12 = 7%) released to landfill from spent oil disposal. The 2000 GS for Lube Oil Additives estimates 83.2% to incineration and 7.7% to landfill. As conservative, CEB uses the GS loss rate estimates.

RELEASE TOTAL

5.5E+4 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 80

Inhalation:
Negligible due to low vapor pressure (VP < 0.001 torr) and physical state as handled (liquid).

Dermal:

Exposure to Liquid
High End: 7.1E+1 mg/day over 250 days/yr
Number of workers (all sites) with Dermal exposure: 80
Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

USE5: Application of Paints, Adhesives and Sealants (0.5% of PV)

Number of Sites/Location: 38 sites
 unknown sites
Days/yr: 249
Basis: Per submission, 38 painting crews, 249 days/yr, and PMN used as at 5-15% (median 10%). CEB assumes 15% PMN to conservatively assess exposures. CS calculates a use rate of 1.9971 kg/site-day.
Process Description: Paint or coating containing PMN (liquid, 5-15%; median 10%) unloaded from containers ---> painting and coating surfaces ---> curing ---> PMN entrained in solid coating (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. The release estimates were based on a combination of submitter provided data and data available in various literature sources. A description of the data is provided in the release notes for each source. The submitter stated "Due to the large number of customer and potential sites where the notification substances may be used, specific use information for each site could not be obtained. Rather, these worker exposures and environmental release scenarios are average scenarios for each particular use." Due to the uncertainty at multiple downstream use sites, the most conservative data were chosen when evaluating releases for downstream operations.

Water or Incineration or Landfill
High End: 1.7E-2 kg/site-day over 175 day/yr from 38 sites
to: Water, Incineration or Landfill (submission, ESD)
from: Cleaning Liquid Residuals from Small Containers Used to Transport the Raw Material
basis: EPA/OPPT Small Container Residual Model, CEB standard 0.6% residual. The submission estimates 0.012 kg/site-day of PMN (0.012/1.997 = 0.6%) release landfill from container cleaning. This is consistent with the EPA/OPPT Small Container Residual model. The 2011 ESD for Application of Radiation Curable Coatings, Inks, and Adhesives assesses these releases to water, incineration or landfill using the EPA/OPPT models. Due to the uncertainty at multiple downstream sites, CEB assesses these releases to water, incineration or landfill.

Water or Incineration or Landfill
Conservative: 4.0E-2 kg/site-day over 249 day/yr from 38 sites
to: Water or Incineration or Landfill (submission, ESD)
from: Equipment Cleaning Losses of Liquids from Painting Equipment
basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual. The submission estimates 0.012 kg/site-day of PMN (0.012/1.997 = 0.6%) release to landfill or POTW from equipment cleaning. The 2011 ESD for Application of Radiation Curable Coatings, Inks, and Adhesives assess releases to incineration or landfill using the EPA/OPPT Multiple Process Vessel Residual Model. Due to the uncertainty at multiple downstream sites, CEB assesses these releases to water, incineration or landfill using he EPA/OPPT model loss rate of 2%.

Air
High End: 1.5E-1 kg/site-day over 249 day/yr from 38 sites
to: air or landfill (spray model)
from: Coating Using Hand-Held Spray Gun
basis: EPA/OPPT Automobile Refinish Coating Overspray Loss Model (non-volatiles). The submission does not estimate releases from coating application and does not provide information on the type of coating method. The submission does indicate that the coatings may be used in road marking applications. As conservative, spray coating is assumed. The EPA/OPPT model estimates a filter capture efficiency of 90% during spray coating resulting in 10% releases to air and 90% to landfill.

Landfill
High End: 1.3E+0 kg/site-day over 249 day/yr from 38 sites
to: air or landfill (spray model)
from: Coating Using Hand-Held Spray gun
basis: EPA/OPPT Automobile Refinish Coating Overspray Loss Model (non-volatiles). The submission does not estimate releases from coating application and does not provide information on the type of coating method. The submission does indicate that the coatings may be used in road marking applications. As conservative, spray coating is assumed. The EPA/OPPT model estimates a filter capture efficiency of 90% during spray coating resulting in 10% releases to air and 90% to landfill.

RELEASE TOTAL

1.5E+4 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 114

Inhalation:

Exposure to Mist
What-If: 9.0E+1 mg/day over 250 days/yr
Number of workers (all sites) with Inhalation exposure: 114
Basis: Coating Using Hand-Held Spray Gun; EPA/OPPT Automobile Refinish Spray Coating Inhalation Model (non-volatile non-polyisocyanates). A 2002 EU RA on MCCPs and a 2010 EU CSR on MCCPs presents air monitoring data from paint spray application with values ranging from 0.002 to 0.19 mg/m3 with a media of 0.04 mg.m3 and a 90[th] percentile of 0.085 mg/m3. The EPA/OPPT Auto Refinishing Spray Coating model calculates n exposure of 9 mg/m3. The EPA/OPPT model is used to provide a conservative estimate due to uncertainty in downstream use sites.

INHALATION MONITORING DATA REVIEW

 Uncertainty (estimate based on model, regulatory limit, or data not specific to industry): Yes
 (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: 2.6E+2 mg/day over 250 days/yr
Number of workers (all sites) with Dermal exposure: 114
Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

USE6: Waterproofer/Flame Retardant in Textiles (0.5% of PV)

Number of Sites/Location: 11 sites
multiple sites  -  See Attachment 008 for a full list of customers across all downstream operations.
Days/yr: 95
Basis: Per submission, 11 finishing sites, 95 days/yr, and PMN used as at 91.5-100% and formulated to 5% in finishing bath. CEB assumes 100% PMNin the raw material. CS calculates a use rate of 18.0827 kg/site-day.
Process Description: PMN (liquid, 91.5-100%) unloaded from tank trucks (69% of PV), drums (23% of PV), totes (4% of PV), and rail cars (4% of PV) ---> feed into finishing solution tank with other components (PMN, liquid, 5%) ---> fabric is moved through the bath ---> transfer heated rollers ---> PMN entrained in coating on fabric (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. The release estimates were based on a combination of submitter provided data and data available in various literature sources. A description of the data is provided in the release notes for each source. The submitter stated "Due to the large number of customer and potential sites where the notification substances may be used, specific use information for each site could not be obtained. Rather, these worker exposures and environmental release scenarios are average scenarios for each particular use." Due to the uncertainty at multiple downstream use sites, the most conservative data were chosen when evaluating releases for downstream operations.

Water
High End: 3.6E+0 kg/site-day over 95 day/yr from 11 sites
to: POTW (submission, GS)
from: Dumping of Finishing Bath
basis: User-Defined Loss Rate Model. The submission estimates 3.6 kg/site-day of PMN (3.6/18.1 = 20%) released to POTW from dumping of finishing bath. The 1994 GS for Fabric Finishing estimates a fabric pick up between 60 and 100% with bath dumping to water. The submission estimates are in general agreement with the GS estimates.

Water or Incineration or Landfill
High End: 6.2E+0 kg/site-day over 2 day/yr from 11 sites
to: uncertain
from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material
basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. The submission estimates 0.54 kg/day of PMN (0.54/18.1 = 3%) release to landfill from drum cleaning. This is consistent with the EPA/OPPT Drum Residual Model. As conservative, CEB assesses these releases to uncertain media due to uncertainty in downstream operations.

Water or Incineration or Landfill
High End: 4.6E+0 kg/site-day over 1 day/yr from 11 sites
to: uncertain
from: Cleaning Liquid Residuals from Totes, Tank Trucks, and Rail Cars Used to Transport the Raw Material
basis: EPA/OPPT Bulk Transport Residual Model, CEB standard 0.2% residual. The submission estimates 0.04 kg/day of PMN (0.04/18.1 = 0.2%) release to landfill from bulk container cleaning. This is consistent with the EPA/OPPT Bulk Transport Residual Model. As conservative, CEB assesses these releases to uncertain media due to uncertainty in downstream operations.

RELEASE TOTAL

4.0E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 33
Basis: The submission estimates 2 workers/site. CEB assesses a default minimum of 3 workers/site.

Inhalation:
Negligible due to low vapor pressure (VP < 0.001 torr) and physical state as handled (liquid).

Dermal:

Exposure to Liquid
High End: 4.3E+2 mg/day over 250 days/yr
Number of workers (all sites) with Dermal exposure: 33
Basis: Exposure During Finishing; EPA/OPPT 2-Hand Dermal Immersion in Liquid Model.

Exposure to Liquid
High End: 1.8E+3 mg/day over 250 days/yr
Number of workers (all sites) with Dermal exposure: 33
Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

P-12-0284
Post Focus Review Draft 10/20/2016

This section provides details on EPA's original engineering assessment of occupational exposure and environmental releases from 2012 as well as the Expanded EPA assessment from 2016.

ENGINEER: Macek/Choudhary
PV (kg/yr): 45,500

Revision Notes/Assessment Overview: 07/26/2016 Update: This IRER was revised to utilize the methodologies from 2 CP assessments in 2015. Industry comments were also used in this assessment. Changes include: providing several release scenarios for all uses (using WWT removal efficiencies of 50, 70 and 99% as well as assuming monthly and quarterly release of container residuals per industry practices). Occupational assessments remained the same as in the previous version of this IRER. However dermal assessments increase as a result of a larger hand surface are used as default in dermal exposure calculations. Note: This is the CEB Review version of the Standard Review Draft. On February 7, 2012, the U.S. Environmental Protection Agency (EPA_ and the U.S. Department of Justice announced a settlement agreement with Dover Chemical Corporation resulting from an unauthorized manufacture of chemical substances at facilities in Dover, Ohio and Hammond, Indiana. As a result of the settlement, EPA has received several premanufacture notices (PMN) from Dover Chemical Corporation for various existing medium-chain and long-chain chlorinated paraffins (MCCP and LCCP) products. The review of these PMNs is complimented by EPA's current initiatives to conduct a review of the environmental and health impacts of MCCPs and LCCPs as part of EPA's Work Plan Chemicals Initiative. /// For each substance, Dover Chemical has provided detailed information for the manufacturing and downstream processing and use as part of the PMN submissions. Prior to receiving the submissions, EPA conducted a literature review on release and exposure data for the manufacture and downstream processing and use of chlorinated paraffins as a means to supplement information provided by Dover Chemical and/or fill any data gaps that may exist. Literature sources that have been reviewed include: 1) previous EPA asessments on chlorinated paraffins; 2) foreign risk assessments on MCCPs and LCCPs (e.g., EU risk assessments); 3) EPA/OPPT Generic Scenarios; 4) OECD Emission Scenario Documents; and 5) Toxics Release inventory data. Data provided by Dover Chemical, data identified in the literature review, and EPA/OPPT standard models were reviewed and the best available data were used to assess environmental releases and occupational exposures.

SUBMITTER: Dover Chemical

USE: 100% of the notification substance is used as a lubricant in metal working fluids (MWFs). The notification substance is blended into the MWFs.
OTHER USES: Generic uses MCCP: 1) Forty-three percent of the notification substances are used as a flame retardant/plasticizer in polymers. Typical concentration in the plastic is 12-30%. 2) Thirty percent of the notification substance is used as a lubricant in metal working fluids (MWFs). The notification substance is blended into the MWFs at 5-10%. 3) Two percent of the notification substances is used as lubricants in automotive. The notification substances is blended into the lubricant at 4%. [20% consumer uses]. 4) Twenty-four percent of the notification substance is used as a flame retardant/plasticizer in rubber. Typical total concentration of flame retardant/plasticizer in the rubber is 1-10%, with a media value of 5.5%. 5) One-half of one percent of the notification substances are used as plasticizer in 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, and swimming pools. The notification substance is blended into the paints at 5-15%. [0.1% consumer uses as sealants in windows] and 6) One-half of one percent of the notification substances are applied as a flame retardant/waterproofers to textiles. The notification substance products are added at 5% of the textile coating finishing solution.

MSDS:  									Yes	LABEL: Yes

Gen Eqpt: Eng Controls: Ventilation should effectively remove and prevent buildup of any vapor/mist/fume/dust generated from the handling of this product. // Eye/Face: Safety glasses with side-shields. If splashes are likely to occur, wear a face shield. // Skin: Normal work clothing (long sleeved shirts and long pants) is recommended.
Respirator: No personal respiratory protective equipment normally required. If mist is generated (heating, spraying) and engineering controls are not sufficient, wear approved organic vapor respirator suitable for oil mist.
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:
Chemical Name: Octodecane, chloro
S-H2O: 0.000005 g/L @
VP: 1.0E-6 torr @
MW: 358 %<500 %<1000
Physical State and Misc CRSS Info: Neat: liquid	Mfg: liquid
Proc/Form: liquid	End Use: 100% in final product. The chlorinated products would range from C18H35Cl3 (at ~30% chlorination) to C18H20Cl18 (at ~ 70% chlorination).

Consumer Use: No

SAT (concerns):

Related Cases and Misc SAT Info:
SAT data not yet available
Migration to groundwater:
PBT rating: PBT SAT data not yet available
Health:
Eco:

OCCUPATIONAL EXPOSURE RATING: 2D

NOTES & KEY ASSUMPTIONS:
Generated by the 06/07/2005 version of ChemSTEER. PMN is a MCCP product that is manufacture domestically and used as a lubricant in metal working fluids (MWFs). // Note: the SAT information is not yet available for this PMN. // For MFG: Submitter estimates were used for assessing release and dermal exposure was assessed using standard models. // 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 those previously reviewed by EPA  as well as Generic Scenarios and Emission Scenario Documents. The submitter has stated that "Due to the large number of customer and potential sites where the notification substances may be used, specific use scenarios are average scenarios for each particular use." Due to the uncertainty at multiple downstream use sites, the most conservative data were chosen when evaluating releases for downstream operations. // Note, all exposure-based criteria were met.

POLLUTION PREVENTION CONSIDERATIONS:

EXPOSURE-BASED REVIEW: Yes	(3 criteria met)

 # of workers exposed: 0 >1000? Yes
 >100 workers with >10 mg/day inhalation exposure: Yes
 (a) >100 workers w/1-10 mg/day inh. exp. & >100 days/yr: Yes
 (b) Routine Dermal Cont: >250 workers & >100 days/yr: Yes

MFG: Batch Manufacturing of PMN

Number of Sites/Location: 1 submitter sites
Dover Chemical Corporation, Dover, OH 44622

Days/yr:  3

Basis: Per submission, 1 submitter site, 3 bt/yr, 22 hr/bt, 20,412 kg/bt, PMN produced as a liquid at 91.5 to 100%. CEB assumes PMN is produced as liquid at 100% to conservatively assess exposures. CS calculates 15,166.67 kg/bt.

Process Description: 1-Octadecene charged to reactor at approximately 176 deg C ---> chlorine gas in fed to reactor ---> QC sampling to check reaction completion (PMN liquid, 91.5  -  100%) ---> off-gas is fed through scrubber system ---> when reaction is finished, turn off chlorine ---> nitrogen purge ---> residual hydrochloric acid is removed from the product by nitrogen blow, then air blow ---> mix with stabilizer, antifoaming agent, and amine phosphate ester salt ---> charge to storage tank (optional) ---> PMN (liquid, 91.5  -  100%) is charged to tank trucks (69% of PV), drums (23% of PV), totes (4% of PV), and rail cars (4% 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.

Incineration or Landfill
Conservative: 4.1E+2 kg/site-day over 1 day/yr from 1 site
to: Incineration or Landfill (submission)
from: Equipment Cleaning Losses of Liquids from Multiple Vessels
basis: User-Defined Loss Rate Model. The submission estimates 408.24 kg/bt of PMN are released to incineration or landfill from equipment cleaning residuals with cleaning occurring once per year. This is equivalent to a loss rate of 2.7% which is more conservative than the standard model loss fraction.  OPPT/RAD assesses equipment cleaning residual releases to incineration or landfill using a loss fraction of 2.7%.

Landfill
Output 2: 2.2E+0 kg/site-day over 3 day/yr from 1 site
to: non-hazardous waste landfill (submission)
from: Filter Waste Disposal
basis: User-Defined Loss Rate Model. The submission estimates 2.25 kg/bt of PMN is released to landfill from filter waste disposal.

RELEASE TOTAL

4.2E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 4
Basis: The submission estimates up to 4 workers/site exposed to PMN at during various activities. As conservative,
RAD assesses dermal exposure for all workers to liquid PMN at 100% during sampling (1-hand) and loading (2-hand) activities.

Inhalation:

Inhalation exposure is expected to be negligible due to low vapor pressure (VP<0.001 torr) and physical state as handled.

Dermal:
Exposure to Liquid
High End: 8.8E+2 mg/day over 3 days/yr
Number of workers (all sites) with Dermal exposure: 4
Basis: Sampling Liquid Product; EPA/OPPT 1-Hand Dermal Contact with Liquids Model.

Dermal:

Exposure to Liquid
High End: 1.8E+3 mg/day over 3 days/yr
Number of workers (all sites) with Dermal exposure: 4
Basis: Loading Liquid Product into Transport Containers; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

PROC3: Formulation of Metalworking Fluids
Number of Sites/Location: 24 sites
 multiple sites  -  See Attachment 008 for a full list of customers across all downstream operations.

Basis: Per submission, 24 MWF formulation sites, 3 bt/yr, PMN used as a liquid at 91.5-100% and formulated down to 5-10% (median 7.5%). CEB assumes 100% PMN in raw material and 10% PMN in MWF to conservatively assess exposures. CS calculates a use rate of 631.94 kg/site-bt.
Process Description: PMN (liquid, 91.5-100%) is unloaded from tank trucks (69% of PV), drums (23% of PV), totes (4% of PV), and rail cars (4% of PV) ---> feed into blending tank ---> packaging of metal working fluids containing PMN (5-10%, median 7.5%) (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. The release estimates were based on a combination of submitter provided data and data available in various literature sources. A description of the data is provided in the release notes for each source. The submitter stated "Due to the large number of customer and potential sites where the notification substances may be used, specific use information for each site could not be obtained. Rather, these worker exposures and environmental release scenarios are average scenarios for each particular use." Due to the uncertainty at multiple downstream use sites, the most conservative data were chosen when evaluating releases for downstream operations.

2012 EPA Assessment
Water or Incineration or Landfill
High End: 6.2E+0 kg/site-day over 2 day/yr from 24 sites
to: uncertain
2016 Expanded EPA Assessment (Oil-based fluids)
Water or Incineration or Landfill
Monthly: 1.1E+0 kg/site-day over 12 day/yr from 12 sites
Quarterly: 3.3E+0 kg/site-day over 4 day/yr from 12 site
to: Uncertain
2016 EPA Expanded Assessment (water based, on-site pretreatment with 50% efficiency)
Water or Incineration or Landfill
Monthly: 5.5E-1 kg/site-day over 12 day/yr from 12 sites
Quarterly: 1.6E+0 kg/site-day over 4 day/yr from 12 site
to: Pretreatment (50% removal efficiency) then to POTW, incineration or landfill
2016 EPA Expanded Assessment (water based, on-site pretreatment with 70% efficiency)
Water or Incineration or Landfill
Monthly: 3.3E-1 kg/site-day over 12 day/yr from 12 sites
Quarterly: 9.8E-1 kg/site-day over 4 day/yr from 12 site
to: Pretreatment (70% removal efficiency) then to POTW, incineration or landfill
2016 EPA Expanded Assessment (water based, on-site pretreatment with 99% efficiency)
Water or Incineration or Landfill
Monthly: 1.1E-2 kg/site-day over 12 day/yr from 12 sites
Quarterly: 3.3E-2 kg/site-day over 4 day/yr from 12 site
to: Pretreatment (99% removal efficiency) then to POTW, incineration or landfill
from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material
basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. The submission estimates 19 kg/day of PMN (19/632 = 3%) release to incineration or landfill from drum cleaning. This is consistent with the EPA/OPPT Drum Residual Model.  Due to the uncertainty at multiple downstream sites, RAD assesses release to uncertain media
2016 EPA Expanded Assessment (oil based fluids): Assumes quarterly or monthly container cleaning, per industry information indicating containers are not picked up daily by a waste handler.
2016 EPA Expanded Assessment (water based, on-site pretreatment with 50%, 70% and 99% efficiency): Assumes quarterly or monthly container cleaning, per industry information indicating containers are not picked up daily by a waste handler. Industry information indicates facilities must meet O&G limits.  Discharge to POTW would first be pretreated  -  50 - 99% efficiency.  This presents release to POTW (with pretreatment 50%, 70% and 99% removal efficiency).

2012 EPA Assessment
Water or Incineration or Landfill
High End: 4.2E+0 kg/site-day over 1 day/yr from 24 sites
to: uncertain
2016 Expanded EPA Assessment (Oil-based fluids)
Water or Incineration or Landfill
High End: 4.2E-1 kg/site-day over 7 day/yr from 12 sites
to: Uncertain
2016 EPA Expanded Assessment (water based, on-site pretreatment with 50% efficiency)
Water or Incineration or Landfill
High End: 2.1E-1 kg/site-day over 7 day/yr from 12 sites
to: Pretreatment (50% removal efficiency) then to POTW, incineration or landfill
2016 EPA Expanded Assessment (water based, on-site pretreatment with 70% efficiency)
Water or Incineration or Landfill
High End: 1.3E-1 kg/site-day over 7 day/yr from 12 sites
to: Pretreatment (70% removal efficiency) then to POTW, incineration or landfill
2016 EPA Expanded Assessment (water based, on-site pretreatment with 99% efficiency)
Water or Incineration or Landfill
High End: 4.0E-3 kg/site-day over 7 day/yr from 12 sites
to: Pretreatment (99% removal efficiency) then to POTW, incineration or landfill
from: Cleaning Liquid Residuals from Totes, Tank Trucks, and Rail Cars Used to Transport the Raw Material
basis: EPA/OPPT Bulk Transport Residual Model, CEB standard 0.2% residual. The submission estimates 1.26 kg/day of PMN (1.26/632 = 0.2%) release to incineration or landfill from tote, tank truck, and rail car cleaning. This is consistent with the EPA/OPPT Bulk Transport Residual Model.  Due to the uncertainty at multiple downstream sites, RAD assesses release to uncertain media
2016 EPA Expanded Assessment (oil based fluids): Assumes quarterly or monthly container cleaning, per industry information indicating containers are not picked up daily by a waste handler.
2016 EPA Expanded Assessment (water based, on-site pretreatment with 50%, 70% and 99% efficiency): Industry information indicates facilities must meet O&G limits.  Discharge to POTW would first be pretreated  -  50 - 99% efficiency.  This presents release to POTW (with pretreatment 50%, 70% and 99% removal efficiency).

2014 EPA Assessment
Water or Incineration or Landfill
Conservative: 1.3E+1 kg/site-day over 3 day/yr from 24 sites
to: Uncertain
2016 Expanded EPA Assessment (Oil-based fluids)
Incineration or Landfill
Conservative: 1.9E+0 kg/site-day over 10 day/yr from 12 sites
to: Incineration or Landfill (industry comments)
2016 Expanded EPA Assessment (water-based, on-site pretreatment with 50% efficiency)
Water or Incineration or Landfill
Conservative: 9.4E-1 kg/site-day over 10 day/yr from 12 sites or
to: Pretreatment (50% efficiency) then to POTW, incineration or landfill
2016 Expanded EPA Assessment (water-based, on-site pretreatment with 70% efficiency)
Water or Incineration or Landfill
Conservative: 5.7E-1 kg/site-day over 10 day/yr from 12 sites
to: Pretreatment (70% efficiency) then to POTW, incineration or landfill
2016 Expanded EPA Assessment (water-based, on-site pretreatment with 99% efficiency)
Water or Incineration or Landfill
Conservative: 1.9E-2 kg/site-day over 12 day/yr from 12 sites
to: Pretreatment (99% efficiency) then to POTW, incineration or landfill
from: Equipment Cleaning Losses of Liquids from a Mixing Tank
basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual. The submission estimates 12.64 kg/day of PMN (12.64/632 = 2%) release to incineration or landfill from equipment cleaning with cleaning occurring once per year. This is consistent with the EPA/OPPT Multiple Process Vessel Residual Model.  Due to the uncertainty at multiple downstream sites, RAD assesses release to uncertain media assuming cleaning once per day.
2016 EPA Expanded Assessment (Oil-Based Fluids):  Industry information indicates cleaning of equipment that is in contact with MCCPs would not use water.  Therefore, wastes are assumed to incineration or landfill.
2016 EPA Expanded Assessment (water based, on-site pretreatment with 50%, 70% and 99% efficiency):  Industry information indicates facilities must meet O&G limits.  Discharge to POTW would first be pretreated  -  50 - 99% efficiency.  This presents release to POTW (with pretreatment 50%, 70% and 99% removal efficiency).

Air
Output 2: 3.2E-1 kg/site-day over 3 day/yr from 24 sites
to: fugitive air (2002 EU RA, 2010 Japan RA)
from: Fugitive Air Emissions
basis: User-Defined Loss Rate Model. Data from a 2002 EU RA for MCCP estimates 16 kg/yr of MCCP may be released to air from fugitive air emissions generated by preheating and blending at a typical MWF formulation site (16/32,0145 = 0.05% for the current operations). 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 the high-end estimate.

Incineration or Landfill
Output 2: 1.3E+1 kg/site-day over 3 day/yr from 24 sites
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

2012 EPA Assessment: 2.2E+3 kg/yr - all sites
2016 EPA Expanded Assessment (Oil-Based Fluids): 8.7E+2 kg/yr - all sites
2016 EPA Expanded Assessment (water-based, on-site pretreatment with 50% efficiency): 6.6E+2 kg/yr - all sites
2016 EPA Expanded Assessment (water-based, on-site pretreatment with 70% efficiency): 5.8E+2 kg/yr - all sites
2016 EPA Expanded Assessment (water-based, on-site pretreatment with 99% efficiency): 4.6E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 192
Basis: The submission estimates up to 8 workers/site. As conservative, CEB assesses all 8 workers to PMN at 100% (unloading) and 10% (loading).

Inhalation:
Negligible due to low vapor pressure (VP < 0.001 torr) and physical state as handled (liquid).

Dermal:

Exposure to Liquid
High End: 2.2E+3 mg/day over 3 days/yr
Number of workers (all sites) with Dermal exposure: 192
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: 2.2E+2 mg/day over 3 days/yr
Number of workers (all sites) with Dermal exposure: 192
Basis: Loading Liquid Product into Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

USE3: Use of Metalworking Fluids (30% of PV)

Number of Sites/Location: 10 sites
multiple sites  -  See Attachment 008 for a full list of customers across all downstream operations.

Days/yr: 247

Basis: Per submission, 364 MWF use sites, 300 exposure days/yr, PMN used as a liquid at 5-10% (median 7.5%) and diluted to 1.25-2.5% (median 1.875%) during use. The 2011 ESD for MWF Operations estimates 247 days/yr of operation. The ESD estimates the number of sites as: (45,500 kg/yr) / (12,000 gal/site-yr x 1 kg/L x 3.785 L/gal x 0.1) = 10 sites. As conservative, RAD assumes 247 days/yr of operation and the ESD estimate of 10 sites to maximize kg/site-day release. RAD also assume 10% PMN in the raw material, and 2.5% PMN during metalworking operations. CS calculates a use rate of 18.4211 kg/site-day.
Process Description: Bulk MWF containing PMN (liquid, 5 - 10%, median 7.5%) 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 release estimates were based on a combination of submitter provided data and data available in various literature sources. A description of the data is provided in the release notes for each source. The submitter stated "Due to the large number of customer and potential sites where the notification substances may be used, specific use information for each site could not be obtained. Rather, these worker exposures and environmental release scenarios are average scenarios for each particular use." Due to the uncertainty at multiple downstream use sites, the most conservative data were chosen when evaluating releases for downstream operations.

2012 EPA Assessment
Water or Incineration or Landfill
High End: 6.2E-1 kg/site-day over 219 day/yr from 10 sites
to: water, incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Oil-Based Fluids)
Incineration or Landfill
High End: 6.2E-1 kg/site-day over 78 day/yr from 14 sites
to: incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 50% on-site pretreatment)
Water, Incineration or Landfill
High End: 3.1E-1 kg/site-day over 78 day/yr from 14 sites
to: Pretreatment (50% efficiency) then to POTW, incineration or landfill
2016 Expanded EPA Assessment (Water-Based Fluids, 70% on-site pretreatment)
Water, Incineration or Landfill
High End: 1.9E-1 kg/site-day over 78 day/yr from 14 sites
to: Pretreatment (70% efficiency) then to POTW, incineration or landfill
2016 Expanded EPA Assessment (Water-Based Fluids, 99% on-site pretreatment)
Water, Incineration or Landfill
High End: 6.2E-3 kg/site-day over 78 day/yr from 14 sites
to: Pretreatment (99% efficiency) then to POTW, incineration or landfill
from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material
basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. The submission estimates 0.15 kg/site-day of PMN (~3% based on the use rate derived from the submission estimate of 9,070 sites) released to landfill from container residuals. The 2011 ESD for MWF Operations estimates releases using the EPA/OPPT Drum Residual Model (3% loss rate) with releses to water incineration or landfill. Due to uncertainty at multiple downstream sites, these releases are assessed to uncertain media using a 3% loss rate per the ESD.
2016 Expanded EPA Assessment (Oil-Based Fluids): 2011 OECD ESD for Use of Metalworking Fluids assesses spend metalworking fluids for oil-based fluids to incineration or landfill:
2016 Expanded EPA Assessment (Water-Based Fluids with on-site pretreatment with 50%, 70% and 99% efficiency). Industry information indicates facilities must meet O&G limits.  Discharge to POTW would first be pretreated  -  50 - 99% efficiency.  This presents release to POTW (with pretreatment 50%, 70% and 99% removal efficiency).

2012 EPA Assessment
Water
Output 2: 2.0E+0 kg/site-day over 247 day/yr from 10 sites
to: on-site WWTP or POTW (ESD)
2016 Expanded EPA Assessment (Oil-Based Fluids)
Water or Incineration or Landfill
Output 2: 7.0E-1 kg/site-day over 247 day/yr from 14 sites
to: water, incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 50% on-site pretreatment)
Water, Incineration or Landfill
High End: 3.5E-1 kg/site-day over 247 day/yr from 14 sites
to: on-site WWTP or POTW (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 70% on-site pretreatment)
Water, Incineration or Landfill
High End: 2.1E-1 kg/site-day over 247 day/yr from 14 sites
to: on-site WWTP or POTW (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 99% on-site pretreatment)
Water, Incineration or Landfill
High End: 7.0E-3 kg/site-day over 247 day/yr from 14 sites
to: on-site WWTP or POTW (ESD)
from: Dragout Losses
basis: User-Defined Loss Rate Model. The submission estimates an aggregated loss of 1% from misting/evaporation and dragout with release to POTW. 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. These data provide the best representation of U.S. operations and are more conservative than the submitter estimates. 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.
2016 Expanded EPA Assessment¨ 2011 OECD ESD for Use of Metalworking Fluids assesses dragout losses of metalworking fluids for oil-based fluids to water, incineration or landfill.
2016 Expanded EPA Assessment (Water-Based Fluids with on-site pretreatment with 50%, 70% and 99% efficiency).  Industry information indicates facilities must meet O&G limits.  Discharge to POTW would first be pretreated  -  50 - 99% efficiency.  This presents release to POTW (with pretreatment 50%, 70% and 99% removal efficiency).

2012 EPA Assessment
Water or Incineration or Landfill
Output 2: 6.4E+0 kg/site-day over 247 day/yr from 10 sites
to: water, incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Oil-Based Fluids)
Incineration or Landfill
Output 2: 2.3E+0 kg/site-day over 247 day/yr from 14 sites
to: incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 50% on-site pretreatment)
Water, Incineration or Landfill
High End: 1.1E+0 kg/site-day over 247 day/yr from 14 sites
to: Pretreatment (50% efficiency) then to POTW, incineration or landfill
2016 Expanded EPA Assessment (Water-Based Fluids, 70% on-site pretreatment)
Water, Incineration or Landfill
High End: 6.9E-1 kg/site-day over 247 day/yr from 14 sites
to: Pretreatment (70% efficiency) then to POTW, incineration or landfill
2016 Expanded EPA Assessment (Water-Based Fluids, 99% on-site pretreatment)
Water, Incineration or Landfill
High End: 2.3E-2 kg/site-day over 247 day/yr from 14 sites
to: Pretreatment (99% efficiency) then to POTW, incineration or landfill
from: Filter Media and Other Recycling Waste
basis: User-Defined Loss Rate Model. The submitter does not address releases from recycling or filter media losses. 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 uncertainty at multiple downstream use sites.
2016 Expanded EPA Assessment (Oil-Based Fluids) 2011 OECD ESD for Use of Metalworking Fluids assesses disposal of filter media and other recycling waste to incineration or landfill for oil-based fluids.
2016 Expanded EPA Assessment (Water-Based Fluids with on-site pretreatment with 50%, 70% and 99% efficiency). Industry information indicates facilities must meet O&G limits.  Discharge to POTW would first be pretreated  -  50 - 99% efficiency.  This presents release to POTW (with pretreatment 50%, 70% and 99% removal efficiency).

2012 EPA Assessment
Water or Incineration or Landfill
Output 2: 8.2E+0 kg/site-day over 247 day/yr from 10 sites
to: water, incineration, or landfill (ESD)
2016 Expanded EPA Assessment Oil-Based Fluids)
Incineration or Landfill
Output 2: 3.4E+0 kg/site-day over 247 day/yr from 14 sites
to: incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 50% on-site pretreatment)
Water, Incineration or Landfill
High End: 1.7E+0 kg/site-day over 247 day/yr from 125 sites
to: Pretreatment (50% efficiency) then to POTW, incineration or landfill
2016 Expanded EPA Assessment (Water-Based Fluids, 70% on-site pretreatment)
Water, Incineration or Landfill
High End: 1.0E+0 kg/site-day over 247 day/yr from 14 sites
to: Pretreatment (70% efficiency) then to POTW, incineration or landfill
2016 Expanded EPA Assessment (Water-Based Fluids, 99% on-site pretreatment)
Water, Incineration or Landfill
High End: 3.4E-2 kg/site-day over 247 day/yr from 14 sites
to: Pretreatment (99% efficiency) then to POTW, incineration or landfill
from: Spent Metalworking Fluid
basis: User-Defined Loss Rate Model. The submission assesses the remaining fluid to POTW from spent MWF disposal with bath changeouts occurring 5 times/yr. 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 occurring 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.
2016 Expanded EPA Assessment (Oil-Based Fluids) 2011 OECD ESD for Use of Metalworking Fluids assesses disposal of spent metalworking fluid to incineration or landfill for oil-based fluids.
2016 Expanded EPA Assessment (Water-Based Fluids with on-site pretreatment with 50%, 70% and 99% efficiency). Industry information indicates facilities must meet O&G limits.  Discharge to POTW would first be pretreated  -  50 - 99% efficiency.  This presents release to POTW (with pretreatment 50%, 70% and 99% removal efficiency).

2012 EPA Assessment
Air
Output 2: 8.9E-1 kg/site-day over 247 day/yr from 10 sites
to: air (2002 EU RA)
from: Misting/Evaporation
basis: User-Defined Loss Rate Model. The submission estimates an aggregate los rate of 1% from misting/evaporation and dragout. 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
EPA 2016 Expanded Assessment: This release source was removed.

RELEASE TOTAL

2012 EPA Assessment: 4.5E+4 kg/yr - all sites
2016 Expanded EPA Assessment (Oil-Based Fluids): 2.3E+4 kg/yr - all sites
2016 Expanded EPA Assessment (Water-Based Fluids, 50% on-site pretreatment): 1.1E+4 kg/yr - all sites
2016 Expanded EPA Assessment (Water-Based Fluids, 70% on-site pretreatment): 6.8E+3 kg/yr - all sites
2016 Expanded EPA Assessment (Water-Based Fluids, 99% on-site pretreatment): 2.3E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 480
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.

Inhalation:

Exposure to Mist
High End of Range: 3.6E+0 mg/day over 247 days/yr
Typical: 9.8E-1 mg/day over 247 days/yr
Number of workers (all sites) with Inhalation exposure: 480
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/m[3] 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 25% of the mist. (GS assumes that water conc. is 60% and the PMN is then estimated to be 10/40 = 25% of the mist.

INHALATION MONITORING DATA REVIEW

 Uncertainty (estimate based on model, regulatory limit, or data not specific to industry): Yes
 (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+2 mg/day over 247 days/yr
Number of workers (all sites) with Dermal exposure: 480
Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

Dermal:

Exposure to Mist
Output 1: 4.9E+2 mg/day over 247 days/yr
Number of workers (all sites) with Dermal exposure: 480
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 operations.

EXPOSURE SCENARIO ESTIMATES
(E-FAST Model Run. SEE APPENDIX G FOR REFERENCE TO FULL REPORTS UNDER SEPARATE COVER )

                          POST-FOCUS EXPOSURE REPORT

This updated assessment is based on the Post-Focus Draft Revision 2 dated 10/20/2016.

	Chemical ID:   P-12-0282                                                Reviewer: Tobias/EN
   Results Table: Dose, Concentration, and Days Exceeded Results Summary
Exposure Scenario[1]
                                     Water
                                   Landfill
                                   Stack Air
                                 Fugitive Air
Release activity(ies)[2]; exposure calculation(s)[3]
                                Drinking Water
                                Fish Ingestion
                                    7Q10[4]
                                    CC = 1
                               PDM Days Exceeded
                                     LADD
                                      ADR
                                 (24-hr conc.)
                              LADD (Annual conc.
                                      ADR
                                 (24-hr conc.)
                              LADD (Annual conc.

                                      ADR
                                     LADD
                                      ADR
                                     LADD

                                   mg/kg/day
                                   mg/kg/day
                                   mg/kg/day
                                   mg/kg/day
                                     μg/l
                                    # Days
                                   mg/kg/day
                                   mg/kg/day
                                  (ug/m[3])
                                   mg/kg/day
                                  (ug/m[3])
                                   mg/kg/day
                                  (ug/m[3])
                                   mg/kg/day
                                  (ug/m[3])
MFG: Max ADR
                                      ---
                                      ---
                                      ---
                                      ---
                                      ---
                                      ---
                                      ---
                                   5.10E-01
                                  (2.76E+03)
                                      ---
                                      ---
                                      ---
MFG: Max LADD
                                      ---
                                      ---
                                      ---
                                      ---
                                      ---
                                      ---
                                   1.53E-04
                                      ---
                                   1.17E-04
                                  (1.51E+00)
                                      ---
                                      ---
PROC1: Max ADR: max acute eco
                                   1.91E-02
                                      ---
                                   1.69E+00
                                      ---
                                   8.63E+02
                                      ---
                                      ---
                                   1.10E-01
                                  (6.20E+02)
                                      ---
                                   1.05E-03
                                  (5.74E+00)
                                      ---
PROC1: Max LADD
                                      ---
                                   1.02E-05
                                      ---
                                   2.10E-04
                                      ---
                                      ---
                                   1.81E-04
                                      ---
                                   3.52E-04
                                  (4.55E+00)
                                      ---
                                   3.70E-06
                                  (4.78E-02)
PROC2: Max ADR: max acute eco
                                   1.09E-02
                                      ---
                                   9.70E-01
                                      ---
                                   4.95E+02
                                      ---
                                      ---
                                   6.04E-02
                                  (3.30E+02)
                                      ---
                                   1.05E-03
                                  (5.74E+00)
                                      ---
PROC2: PDM1
                                      ---
                                      ---
                                      ---
                                      ---
                                   5.41E+01
                                      38
                                      ---
                                      ---
                                      ---
                                      ---
                                      ---
PROC2: Max LADD
                                      ---
                                   1.13E-05
                                      ---
                                   2.32E-04
                                      ---
                                      ---
                                   1.35E-04
                                      ---
                                   2.62E-04
                                  (3.39E+00)
                                      ---
                                   3.70E-06
                                  (4.78E-02)
PROC3: Max ADR: max acute eco
                                   6.61E-03
                                      ---
                                   5.80E-01
                                      ---
                                   2.99E+02
                                      ---
                                      ---
                                   4.94E-02
                                  (2.70E+02)
                                      ---
                                   1.05E-03
                                  (5.74E+00)
                                      ---
PROC3: PDM1
                                      ---
                                      ---
                                      ---
                                      ---
                                   3.22E+01
                                      37
                                      ---
                                      ---
                                      ---
                                      ---
                                      ---
PROC3: Max LADD
                                      ---
                                   6.77E-06
                                      ---
                                   1.39E-04
                                      ---
                                      ---
                                   1.21E-04
                                      ---
                                   2.35E-04
                                  (3.04E+00)
                                      ---
                                   3.70E-06
                                  (4.78E-02)
PROC4: Max ADR: max acute eco
                                   2.15E-04
                                      ---
                                   1.90E-02
                                      ---
                                   9.72E+00
                                      ---
                                      ---
                                   2.20E-02
                                  (1.20E+02)
                                      ---
                                   1.05E-03
                                  (5.74E+00)
                                      ---
PROC4: PDM1
                                      ---
                                      ---
                                      ---
                                      ---
                                   1.08E+00
                                       6
                                      ---
                                      ---
                                      ---
                                      ---
                                      ---
PROC4: Max LADD
                                      ---
                                   2.23E-07
                                      ---
                                   4.60E-06
                                      ---
                                      ---
                                   9.57E-05
                                      ---
                                   1.86E-04
                                  (2.40E+00)
                                      ---
                                   3.70E-06
                                  (4.78E-02)
PROC5: Max ADR: max acute eco
                                   9.44E-02
                                      ---
                                   8.33E+00
                                      ---
                                      ---
                                      ---
                                      ---
                                   4.30E-01
                                  (2.34E+03)
                                      ---
                                   3.50E-03
                                  (1.91E+01)
                                      ---
PROC5: PDM1
                                      ---
                                      ---
                                      ---
                                      ---
                                   2.51E+00
                                      115
                                      ---
                                      ---
                                      ---
                                      ---
                                      ---
PROC5: Max LADD
                                      ---
                                   5.25E-05
                                      ---
                                   1.08E-03
                                      ---
                                      ---
                                   1.99E-04
                                      ---
                                   3.88E-04
                                  (5.01E+00)
                                      ---
                                   9.37E-05
                                  (1.21E+00)
PROC6: Max ADR: max acute eco
                                   4.56E-02
                                      ---
                                   4.02E+00
                                      ---
                                   2.06E+03
                                      ---
                                      ---
                                   2.20E-01
                                  (1.20E+03)
                                      ---
                                   2.23E-04
                                  (1.22E+00)
                                      ---
PROC6: PDM1
                                      ---
                                      ---
                                      ---
                                      ---
                                   1.26E+00
                                      19
                                      ---
                                      ---
                                      ---
                                      ---
                                      ---
PROC6: Max LADD
                                      ---
                                   2.47E-05
                                      ---
                                   5.08E-04
                                      ---
                                      ---
                                   3.49E-04
                                      ---
                                   6.79E-04
                                  (8.77E+00)
                                      ---
                                   1.98E-06
                                  (2.56E-02)
PROC7: Max ADR: max acute eco
                                   2.82E-03
                                      ---
                                   2.50E-01
                                      ---
                                   1.28E+02
                                      ---
                                      ---
                                   1.79E-02
                                  (9.77E+01)
                                      ---
                                      ---
                                      ---
PROC7: Max LADD
                                      ---
                                   1.51E-06
                                      ---
                                   3.10E-05
                                      ---
                                      ---
                                   2.88E-05
                                      ---
                                   5.60E-05
                                  (7.20E-01)
                                      ---
                                      ---
PROC8: Max ADR: max acute eco
                                   1.20E-03
                                      ---
                                   1.10E-01
                                      ---
                                   5.41E+01
                                      ---
                                      ---
                                   4.50E-01
                                  (2.48E+03)
                                      ---
                                      ---
                                      ---
PROC8: Max LADD
                                      ---
                                   4.00E-07
                                      ---
                                   8.23E-06
                                      ---
                                      ---
                                   5.71E-05
                                      ---
                                   1.11E-04
                                  (1.43E+00)
                                      ---
                                      ---
USE1: Max ADR: max acute eco
                                   5.65E-04
                                      ---
                                   2.94E-02
                                      ---
                                   2.65E+01
                                      ---
                                      ---
                                   8.66E-03
                                  (4.73E+01)
                                      ---
                                      ---
                                      ---
USE1: PDM1
                                      ---
                                      ---
                                      ---
                                      ---
                                   2.65E+01
                                      174
                                      ---
                                      ---
                                      ---
                                      ---
                                      ---
USE1: Max LADD
                                      ---
                                   1.10E-05
                                      ---
                                   2.26E-04
                                      ---
                                      ---
                                   2.39E-04
                                      ---
                                   4.65E-04
                                  (6.01E+00)
                                      ---
                                      ---
USE2: Max ADR: max acute eco
                                   2.79E-03
                                      ---
                                   1.50E-01
                                      ---
                                   1.31E+02
                                      ---
                                      ---
                                   3.82E-03
                                  (2.09E+01)
                                      ---
                                      ---
                                      ---
USE2: PDM1
                                      ---
                                      ---
                                      ---
                                      ---
                                   1.31E+02
                                      74
                                      ---
                                      ---
                                      ---
                                      ---
                                      ---
USE2: PDM2
                                      ---
                                      ---
                                      ---
                                      ---
                                   1.19E+02
                                      235
                                      ---
                                      ---
                                      ---
                                      ---
                                      ---
USE2: Max LADD
                                      ---
                                   5.09E-05
                                      ---
                                   1.05E-03
                                      ---
                                      ---
                                   1.05E-04
                                      ---
                                   2.04E-04
                                  (2.64E+00)
                                      ---
                                      ---
USE3: Max ADR
                                   1.68E-03
                                      ---
                                   8.73E-02
                                      ---
                                   7.88E+01
                                      ---
                                      ---
                                   2.31E-03
                                  (1.26E+01)
                                      ---
                                      ---
                                      ---
USE3: PDM1
                                      ---
                                      ---
                                      ---
                                      ---
                                   7.88E+01
                                      70
                                      ---
                                      ---
                                      ---
                                      ---
                                      ---
USE3: PDM2
                                      ---
                                      ---
                                      ---
                                      ---
                                   7.16E+01
                                      222
                                      ---
                                      ---
                                      ---
                                      ---
                                      ---
USE3: Max LADD
                                      ---
                                   3.06E-05
                                      ---
                                   6.29E-04
                                      ---
                                      ---
                                   6.31E-05
                                      ---
                                   1.23E-04
                                  (1.59E+00)
                                      ---
                                      ---
USE4: Max ADR
                                   5.67E-05
                                      ---
                                   2.95E-03
                                      ---
                                   2.66E+00
                                      ---
                                      ---
                                   7.80E-05
                                  (4.30E-01)
                                      ---
                                      ---
                                      ---
USE4: PDM1
                                      ---
                                      ---
                                      ---
                                      ---
                                   2.66E+00
                                      13
                                      ---
                                      ---
                                      ---
                                      ---
                                      ---
USE4: PDM2
                                      ---
                                      ---
                                      ---
                                      ---
                                   2.42E+00
                                      39
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USE4: Max LADD