2. In some cases, the minimum values in the table are preceded by "<". This indicates that the value reported in article was reported as a non-detect. In such cases, one half of the lowest reported detection limit was compiled as the `minimum' reported monitoring data
3. All concentrations measured from impoundment lagoons and drainage ditches from the USEPA (1988) study have not been included as they are not considered as surface water concentrations
4. All concentrations measured from suspended solid matter fraction from influents from the Coelhan (2010) study have not been included as they are not considered as surface water concentrations
 Sediment
MCCP sediment concentrations from marine and non-marine environments ranged from 5.00 x 10[-3] to 1.64 x 10[1] mg/kg dw and from 2.0 x 10[-3] to 6.51 x 10[1] mg/kg dw, respectively.

For the purposes of this assessment, in the studies considered acceptable, EPA/OPPT used the lowest and highest reported marine and non-marine sediment concentrations (5.00x10[-3] to 1.64 x 10[1] mg/kg dw and 2.00 x 10[-3] to 6.51 x 10[1] mg/kg dw, respectively) to evaluate risks of potential concern to sediment organisms (Table_Apx D-1-2). Where appropriate, reported values were converted to a common unit, as presented in the table.
Table_Apx D-1-2: Sediment Concentrations of MCCPs, Sorted by Country
                                     Media
                                    Country
                                   Location
                                   Comments
                            Converted Concentration
                                 Common Units
                                  References

                            City, State or Province

                                   Sediment
                                   (Marine)
                                   Australia
                                      NR
                                      ---
                                     1.11
                                   mg/kg dw
                            Kemmlein et al. (2002)

                                      ---
                                     1.17
                                   mg/kg dw
                            Kemmlein et al. (2002)

                                      ---
                                     3.11
                                   mg/kg dw
                            Kemmlein et al. (2002)

                                      ---
                                  1.64x10[1]
                                   mg/kg dw
                            Kemmlein et al. (2002)

                                    Canada
                      Hamilton Harbour (Windemere basin)
                                      ---
                                 2.90x10[-1]
                                    mg/kg*
                              Muir et al. (2000)

                                    Germany
                            German Bight, North Sea
                                      ---
                                 5.00x10[-3]
                                   mg/kg dw
                             Hüttig et al. (2004)

                                      ---
                                 9.00x10[-3]
                                   mg/kg dw
                             Hüttig et al. (2004)

                                      ---
                                 9.00x10[-3]
                                   mg/kg dw
                             Hüttig et al. (2004)

                                      ---
                                 1.30x10[-2]
                                   mg/kg dw
                             Hüttig et al. (2004)

                                      ---
                                 2.80x10[-2]
                                   mg/kg dw
                             Hüttig et al. (2004)

                                      ---
                                 1.46x10[-1]
                                   mg/kg dw
                             Hüttig et al. (2004)

                                  Baltic Sea
                                      ---
                                 9.30x10[-2]
                                   mg/kg dw
                             Hüttig et al. (2004)

                                      ---
                                 1.15x10[-1]
                                   mg/kg dw
                             Hüttig et al. (2004)

                                      ---
                                 1.22x10[-1]
                                   mg/kg dw
                             Hüttig et al. (2004)

                                      ---
                                 2.11x10[-1]
                                   mg/kg dw
                             Hüttig et al. (2004)

                                      ---
                                 4.99x10[-1]
                                   mg/kg dw
                             Hüttig et al. (2004)

                             North and Baltic Sea
                                      ---
                                 2.20x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 2.30x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 3.30x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 3.40x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 3.70x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 3.90x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 4.30x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 4.30x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 4.80x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 5.40x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 5.80x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 6.10x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 7.20x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 7.60x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 7.70x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 8.10x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 8.50x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 8.70x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 1.49x10[-1]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 1.49x10[-1]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 1.49x10[-1]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 2.75x10[-1]
                                   mg/kg dw
                           Hüttig and Oehme (2006)

                                      ---
                                 9.10x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2005)

                                      ---
                                 4.80x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2005)

                                      ---
                                 1.98x10[-1]
                                   mg/kg dw
                           Hüttig and Oehme (2005)

                                      ---
                                 1.31x10[-1]
                                   mg/kg dw
                           Hüttig and Oehme (2005)

                                      ---
                                 1.32x10[-1]
                                   mg/kg dw
                           Hüttig and Oehme (2005)

                                      ---
                                 3.03x10[-1]
                                   mg/kg dw
                           Hüttig and Oehme (2005)

                                      ---
                                 1.53x10[-1]
                                   mg/kg dw
                           Hüttig and Oehme (2005)

                                      ---
                                 1.14x10[-1]
                                   mg/kg dw
                           Hüttig and Oehme (2005)

                                      ---
                                 4.00x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2005)

                                      ---
                                 2.70x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2005)

                                      ---
                                 1.80x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2005)

                                      ---
                                 1.90x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2005)

                                      ---
                                 3.00x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2005)

                                      ---
                                 3.20x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2005)

                                      ---
                                 1.80x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2005)

                                      ---
                                 2.40x10[-2]
                                   mg/kg dw
                           Hüttig and Oehme (2005)
                                   Sediment
                                 (Non-marine)
                                    Canada
                                   Lake Erie
                                      ---
                                 6.80x10[-2]
                                   mg/kg dw
                             Tomy and Stern (1999)

                                Lake St Francis
                                    Minimum
                                 7.50x10[-1]
                                   mg/kg dw
                                  EC (2008b)

                                    Maximum
                                      1.2
                                   mg/kg dw
                                  EC (2008b)

                                Czech Republic
                                      NR
                                    Minimum
                                 2.00x10[-3]
                                    mg/kg*
                            Pribylova et al. (2006)

                                     Labe
                                      Sum
                                 1.80x10[-2]
                                   mg/kg dw
                            Pribylova et al. (2006)

                                      Sum
                                 7.30x10[-2]
                                   mg/kg dw
                            Pribylova et al. (2006)

                                  Libis-Labe
                                      Sum
                                      1.6
                                   mg/kg dw
                            Pribylova et al. (2006)

                                    Bilina
                                      Sum
                                 3.10x10[-2]
                                   mg/kg dw
                            Pribylova et al. (2006)

                                  Mala Becva
                                      Sum
                                 1.13x10[-1]
                                   mg/kg dw
                            Pribylova et al. (2006)

                                     Becva
                                      Sum
                                 1.20x10[-1]
                                   mg/kg dw
                            Pribylova et al. (2006)

                                    Morava
                                      Sum
                                 1.93x10[-1]
                                   mg/kg dw
                            Pribylova et al. (2006)

                                     Ohre
                                      Sum
                                 3.08x10[-1]
                                   mg/kg dw
                            Pribylova et al. (2006)

                                      Sum
                                 6.00x10[-1]
                                   mg/kg dw
                            Pribylova et al. (2006)

                                      Sum
                                     5.58
                                   mg/kg dw
                            Pribylova et al. (2006)

                                    Morava
                                      Sum
                                 4.16x10[-1]
                                   mg/kg dw
                            Pribylova et al. (2006)

                                     Dyje
                                      Sum
                                 7.57x10[-1]
                                   mg/kg dw
                            Pribylova et al. (2006)

                                   Drevnice
                                      Sum
                                 8.93x10[-1]
                                   mg/kg dw
                            Pribylova et al. (2006)

                                    Germany
                               Bodensee (middle)
                                     <
                                 5.00x10[-3]
                                   mg/kg dw
                                  IPCS (1996)

                                      ---
                                 7.00x10[-2]
                                   mg/kg dw
                                  IPCS (1996)

                                  River Lech
                                     <
                                 5.00x10[-3]
                                   mg/kg dw
                                  IPCS (1996)

                                      ---
                                 3.25x10[-1]
                                   mg/kg dw
                                  IPCS (1996)

                                    Maximum
                                 7.00x10[-1]
                                    mg/kg*
                              Tomy et al. (1998)

                                  River Rhine
                                      ---
                                 6.00x10[-2]
                                   mg/kg dw
                                  IPCS (1996)

                                      ---
                                 8.50x10[-2]
                                   mg/kg dw
                                  IPCS (1996)

                                      ---
                                 1.40x10[-1]
                                   mg/kg dw
                                  IPCS (1996)

                                    Minimum
                                 1.45x10[-1]
                                   mg/kg dw
                                  IPCS (1996)

                                    Maximum
                                 2.05x10[-1]
                                   mg/kg dw
                                  IPCS (1996)

                             River Elbe at Hamburg
                                    Minimum
                                 1.30x10[-1]
                                   mg/kg dw
                                  IPCS (1996)

                                    Maximum
                                 2.30x10[-1]
                                   mg/kg dw
                                  IPCS (1996)

                                  River Main
                                    Minimum
                                 1.60x10[-1]
                                   mg/kg dw
                                  IPCS (1996)

                                    Maximum
                                 2.60x10[-1]
                                   mg/kg dw
                                  IPCS (1996)

                             Outer Alster, Hamburg
                                      ---
                                 3.70x10[-1]
                                   mg/kg dw
                                  IPCS (1996)

                                    Norway
                                      NR
                                    minimum
                                 5.00x10[-2]
                                   mg/kg dw
                            Petersen et al. (2006)

                                    maximum
                                     3.24
                                   mg/kg dw
                            Petersen et al. (2006)

                                      ---
                                      2.7
                                   mg/kg ww
                             Borgen et al. (2003)

                                      ---
                                  1.14x10[1]
                                   mg/kg ww
                             Borgen et al. (2003)

                                  South China
                               Pearl River Delta
                                    Minimum
                                 8.80x10[-1]
                                   mg/kg dw
                              Chen et al. (2011)

                                    Minimum
                                      1.1
                                   mg/kg dw
                              Chen et al. (2011)

                                    Minimum
                                      1.4
                                   mg/kg dw
                              Chen et al. (2011)

                                    Maximum
                                      1.4
                                   mg/kg dw
                              Chen et al. (2011)

                                    Maximum
                                      3.8
                                   mg/kg dw
                              Chen et al. (2011)

                                     Mean
                                      3.9
                                   mg/kg dw
                              Chen et al. (2011)

                                     Mean
                                  2.10x10[1]
                                   mg/kg dw
                              Chen et al. (2011)

                                    Maximum
                                  3.80x10[1]
                                   mg/kg dw
                              Chen et al. (2011)

                                  Switzerland
                                   Lake Thun
                                    Minimum
                                 5.00x10[-3]
                                   mg/kg dw
                              Iozza et al. (2008)

                                    Maximum
                                 2.60x10[-2]
                                   mg/kg dw
                              Iozza et al. (2008)

                                  Lake Zurich
                                    Maximum
                                 5.00x10[-3]
                                    mg/kg*
                              Tomy et al. (1998)

                                United Kingdom
                                      NR
                                     <
                                 1.00x10[-1]
                                   mg/kg dw
                            Nicholls et al. (2001)

                     South West Region: Grand Union Canal
                                      ---
                                 3.00x10[-1]
                                   mg/kg dw
                            Nicholls et al. (2001)

                                      ---
                                      2.7
                                   mg/kg dw
                            Nicholls et al. (2001)

                                      ---
                                      2.8
                                   mg/kg dw
                            Nicholls et al. (2001)

                     South West Region; Bristol Avon River
                                      ---
                                 5.00x10[-1]
                                   mg/kg dw
                            Nicholls et al. (2001)

                                      ---
                                 6.00x10[-1]
                                   mg/kg dw
                            Nicholls et al. (2001)

                                      ---
                                 8.00x10[-1]
                                   mg/kg dw
                            Nicholls et al. (2001)

                         North East Region: Hull River
                                      ---
                                      1.0
                                   mg/kg dw
                            Nicholls et al. (2001)

                                      ---
                                  1.35x10[1]
                                   mg/kg dw
                            Nicholls et al. (2001)

                                      ---
                                      1.1
                                   mg/kg dw
                            Nicholls et al. (2001)

                        South West Region: Colne River
                                      ---
                                      1.4
                                   mg/kg dw
                            Nicholls et al. (2001)

                                      ---
                                      2.0
                                   mg/kg dw
                            Nicholls et al. (2001)

                       West Midlands Region: Trent River
                                      ---
                                      3.8
                                   mg/kg dw
                            Nicholls et al. (2001)

                                      ---
                                  6.02x10[1]
                                   mg/kg dw
                            Nicholls et al. (2001)

                                      ---
                                  6.51x10[1]
                                   mg/kg dw
                            Nicholls et al. (2001)

                      North West Region: Hornsmill brook
                                      ---
                                      5.6
                                   mg/kg dw
                            Nicholls et al. (2001)

                                      ---
                                  1.25x10[1]
                                   mg/kg dw
                            Nicholls et al. (2001)

                                      ---
                                  1.83x10[1]
                                   mg/kg dw
                            Nicholls et al. (2001)

                         North East Region: Hull River
                                      ---
                                      1.0
                                   mg/kg dw
                            Nicholls et al. (2001)

                                      ---
                                      1.1
                                   mg/kg dw
                            Nicholls et al. (2001)

                                      ---
                                  1.35x10[1]
                                   mg/kg dw
                            Nicholls et al. (2001)

                       East Midlands Region: Idle River
                                      ---
                                  1.62x10[1]
                                   mg/kg dw
                            Nicholls et al. (2001)

                                      ---
                                  4.39x10[1]
                                   mg/kg dw
                            Nicholls et al. (2001)

                      Northumberland Region: Skerne River
                                      ---
                                  1.80x10[1]
                                   mg/kg dw
                            Nicholls et al. (2001)

                                      ---
                                  2.56x10[1]
                                   mg/kg dw
                            Nicholls et al. (2001)

                                      ---
                                  5.84x10[1]
                                   mg/kg dw
                            Nicholls et al. (2001)

                        East Anglia Region: Lark River
                                      ---
                                  3.22x10[1]
                                   mg/kg dw
                            Nicholls et al. (2001)

                                      ---
                                  4.50x10[1]
                                   mg/kg dw
                            Nicholls et al. (2001)

                                      ---
                                  6.04x10[1]
                                   mg/kg dw
                            Nicholls et al. (2001)

                                 United States
                                 Detroit River
                                      ---
                                 6.80x10[-2]
                                   mg/kg dw
                              Tomy et al. (1999)

                               Sugar Creek, Ohio
            Reported as trace with range of 1.5-5; used the average
                                 3.25x10[-3]
                                   mg/kg dw
                                 USEPA (1988)

            Reported as trace with range of 1.5-5; used the average
                                 3.25x10[-3]
                                   mg/kg dw
                                 USEPA (1988)

                                      ---
                                 6.80x10[-3]
                                   mg/kg dw
                                 USEPA (1988)

                                      ---
                                 8.20x10[-3]
                                   mg/kg dw
                                 USEPA (1988)

                                      ---
                                 7.60x10[-1]
                                   mg/kg dw
                                 USEPA (1988)

                                      ---
                                  2.10x10[1]
                                   mg/kg dw
                                 USEPA (1988)

                                      ---
                                  3.40x10[1]
                                   mg/kg dw
                                 USEPA (1988)

                                      ---
                                  5.00x10[1]
                                   mg/kg dw
                                 USEPA (1988)
Note:
NR: Not recorded. Location description was not provided in the study.
--: Single sample value reported above the detection limit; therefore, no data qualifier required.
1. All values provided in the table above represent total MCCP and not individual MCCP isomers
2. In some cases, the minimum values in the table are preceded by "<". This indicates that the value reported in article was reported as a non-detect. In such cases, one half of the lowest reported detection limit was compiled as the `minimum' reported monitoring data
3. dw   -   dry weight and ww   -   wet weight

 Biosolids and Soil
CPs are detected more frequently and at higher concentrations in treated sewage sludge (i.e., biosolids) than in soil. MCCP concentrations ranged from 5.00 x 10[-5] to 9.70 x 10[3] mg/kg dw in sludge and from 1.5 x 10[-2] to 8.5 x 10[-2] mg/kg dw in soil. It is unclear if the difference in MCCP concentrations in sludge and soil is related to the smaller sample sizes for these media compared to the typically larger data sets available for water and sediment. To determine the most reliable studies for its consideration, EPA/OPPT used the following criteria: designation of specific MCCP chain length and the appropriate analytical methodology. Based these criteria, EPA/OPPT determined that the data reported by Stevens et al. (2003) were the most reliable for its use in this assessment: data are summarized below.

Stevens et al. (2003) measured MCCP concentrations in sludge samples obtained from 14 WWTPs in the UK. MCCP concentrations ranged from 3.00 x 10[1] to 9.70 x 10[3] mg/kg dw. The authors concluded that these very high concentrations were likely the result of releases from numerous and ongoing diffuse sources. EPA/OPPT did not use information from other published studies reporting measured CPs in sludge and soil because they did not distinguish the CPs measured  (Nicholls et al., 2001). These studies reported total CP concentrations at much lower levels ranging from 3.00 x 10[-5] to 2.3 mg/kg dw.

Although risk to terrestrial species was not calculated, EPA/OPPT notes that the lowest and highest reported biosolid and soil concentrations (5.00 x 10[-5] to 9.70 x 10[3] mg/kg dw and 1.5 x 10[-2] to 8.5 x 10[-2] mg/kg dw, respectively) represents a very large range (up to eight orders of magnitude (Table_Apx D-1-3).

Table_Apx D-1-3: Biosolid and Soil Concentrations of MCCPs
Location
                                     Media
                                 Concentration
                                     Units
                                  References

                                    Minimum
                                    Maximum

Switzerland
                                     Soil
                                1.5 x 10[-2]
                                 8.5 x 10[-2]
                                   mg/kg dw
                                 Iozza (2010)
China
                                     Soil
                                 2.1 x 10[-6]
                                1.53 x 10[-3]
                                   mg/kg dw
                              Wang et al. (2013)
Czech Republic
                                 Sewage Sludge
                                7.36 x 10[-1]
                                     2.30
                                   mg/kg dw
                            Pribylova et al. (2006)
United Kingdom
                                 Sewage Sludge
                                 3.00 x 10[1]
                                 9.70 x 10[3]
                                   mg/kg dw
                             Stevens et al. (2003)
United States
                                 Sewage Sludge
                                5.00 x 10[-5]
                                5.00 x 10[-5]
                                   mg/kg dw
                            Pribylova et al. (2006)

 Biota
EPA/OPPT reviewed available published literature and summarized MCCP concentrations in tissues of aquatic and terrestrial biota (Table_Apx D-1-4). Measured tissue concentrations for aquatic biota ranged from ND to 2.63 mg/kg ww (i.e., beluga whales, seals, rainbow trout, carp, mackerel, arctic char, mussels, crustaceans, and plankton) and ranged from 5.00 x 10[-3] to 3.70 x 10[-1] mg/kg ww in terrestrial biota. The concentrations measured in the terrestrial studies did not designate the specific CP congeners measured.
As a result of EPA/OPPT's evaluation, MCCPs were found in organisms across many different trophic levels indicating widespread environmental contamination (Table_Apx D-1-4). The data were insufficient for EPA/OPPT to draw conclusions about trends based on region, species, time, or other factors.

While EPA/OPPT determined the concentrations of MCCPs in aquatic and terrestrial biota range from ND to 2.63 mg/kg ww from 5.00 x 10[-3] to 3.70 x 10[-1] mg/kg ww, respectively, in this assessment, EPA/OPPT did not use tissue concentrations to determine risks of potential concern for biota Table_Apx D-1-4. Rather, it used the risk quotient (RQ) method as described in Section 6.

Table_Apx D-1-4: Biota Concentrations of MCCPs
 Location
                               Media Description
                                    Minimum
                                     Units
                                 Min Reference
                                    Maximum
                                     Units
                                 Max Reference

                                 Aquatic Biota
 Australia
                                 Invertebrates
                                  2.32x10[-5]
                                    mg/kg lw
                             Kemmlein et al. (2002)
                                  3.05x10[-5]
                                    mg/kg lw
                             Kemmlein et al. (2002)
 Canada
                                    Mammals
                                  5.45x10[-7]
                                    mg/kg ww
                              Bennie et al. (2000)
                                  8.00x10[-5]
                                    mg/kg ww
                              Bennie et al. (2000)

                                      Fish
                                  2.57x10[-7]
                                    mg/kg ww
                              Bennie et al. (2000)
                                      2.63
                                    mg/kg ww
                               Muir et al. (2000)

                                 Invertebrates
                                     ND[1]
                                    mg/kg ww
                                   EC (1993)
                                     ND[1]
                                    mg/kg ww
                                   EC (1993)

                                     Total
                                     ND[1]
                                    mg/kg ww
                                   EC (1993)
                                      2.63
                                    mg/kg ww
                               Muir et al. (2000)
 Europe
                                      Fish
                                  7.00x10[-3]
                                    mg/kg ww
                               Reth et al. (2006)
                                  4.70x10[-2]
                                    mg/kg ww
                               Reth et al. (2006)
 North Sea/Baltic Sea Region[2]
                                      Fish
                                     ND[3]
                                    mg/kg ww
                                   IVL (2009)
                                  2.6x10[-1]
                                    mg/kg ww
                               Reth et al. (2005)
 United States
                                      Fish
                                  2.90x10[-3]
                                    mg/kg ww
                             Tomy and Stern (1999)
                                  9.04x10[-1]
                                    mg/kg ww
                             Tomy and Stern (1999)

                                 Invertebrates
                                  3.50x10[-3]
                                    mg/kg ww
                                  USEPA (1988)
                                  1.70x10[-1]
                                    mg/kg ww
                                  USEPA (1988)

                                     Total
                                  2.90x10[-3]
                                    mg/kg ww
                             Tomy and Stern (1999)
                                  9.04x10[-1]
                                    mg/kg ww
                             Tomy and Stern (1999)
 United States / Canada
- Great Lakes
                                      Fish
                                  1.80x10[-3]
                                    mg/kg ww
                               Muir et al. (2003)
                                  1.10x10[-1]
                                    mg/kg ww
                               Muir et al. (2003)

                                 Invertebrates
                                  2.40x10[-3]
                                    mg/kg ww
                                   EC (2008a)
                                  1.60x10[-2]
                                    mg/kg ww
                               Muir et al. (2003)

                                     Total
                                  1.80x10[-3]
                                    mg/kg ww
                               Muir et al. (2003)
                                  1.10x10[-1]
                                   mg/kg ww.
                               Muir et al. (2003)
                               Terrestrial Biota
 Europe
                                     Birds
                                  5.00x10[-3]
                                    mg/kg ww
                               Reth et al. (2006)
                                  3.70x10[-1]
                                    mg/kg ww
                               Reth et al. (2006)
 Notes:
 Summary values represent total MCCP and not individual MCCP isomers.
 [1] MCCPs were not detected in Invertebrates from Canada. Detection limit = 4.0 x 10[-7] mg/kg; (1/2) DL = 2.0 x 10[-7] (EC, 1993).
 [2] North Sea/Baltic Sea Region includes the following countries: Estonia, Latvia, Lithuania, Norway, Poland, and Sweden.
 [3] The minimum MCCP concentration value for fish from the North Sea/Baltic Sea Region was non-detect. The detection limit = 2.5 x 10[-4] mg/kg; (1/2) DL = 1.25 x 10[-4] (IVL 2009)

    LCCP MONITORING DATA
Kemmlein et al. (2002) optimized and tested the carbon skeleton reaction gas chromatography analytical method to analyze environmental samples for CPs. The optimized method was used for marine sediments, mussels and crabs taken from an area influenced by a CP manufacturer in Yarraville, Australia. LCCP (C18-20) concentrations in marine sediment ranged from 1.02 x 10[-1] to 4.31 x 10[-1] mg/kg dw (Table_Apx D-2-1), those in mussels ranged from 4 x 10[-1] to 1.9 mg/kg lw, and those in crab ranged from 3 x 10[-2] to 4.4 mg/kg lw. The results presented in this paper show that bioaccumulation is evident. The mussel samples contained approximately two times and crab tissue around six times the concentration of CPs found in the most contaminated sediment sample. No other adequate studies were found to characterize LCCP concentrations in surface water, fresh water sediment or soil.

Table_Apx D-2-1: Marine Sediment Concentrations of LCCPs
                                     Media
                                    Country
                                   Location
                                   Comments
                                 Concentration
                                     Units
                                  References

                            City, State or Province

                                   Sediment
                                   (Marine)
                                   Australia
                                      NR
                                      Sum
                                 1.02x10[-1]
                                   mg/kg dw
                            Kemmlein et al. (2002)

                                      Sum
                                 1.28x10[-1]
                                   mg/kg dw
                            Kemmlein et al. (2002)

                                      Sum
                                 3.04x10[-1]
                                   mg/kg dw
                            Kemmlein et al. (2002)

                                      Sum
                                 4.31x10[-1]
                                   mg/kg dw
                            Kemmlein et al. (2002)
Notes:
    Values provided in the table above represent total LCCP (C18-20) and not individual isomers.
    dw  -  dry weight

Table_Apx D-2-2: Biota Concentrations of LCCPs
                                     Media
                                    Country
                                   Location
                                    Minimum
                                    Maximum
                                     Units
                                  References

                            City, State or Province

                                 Aquatic Biota
                                   Australia
                                      NR
                                 2.89x10[-6]
                                 6.90x10[-6]
                                   mg/kg lw
                            Kemmlein et al. (2002)
Notes:
    Minimum and Maximum concentrations provided in the table above represent total LCCP (C18-20) and not individual isomers.
    lw  -  lipid weight

 ENGINEERING (ChemSTEER) REPORTS ON P-12-0-0433 and P-12-0453
 (Used for both identifying potential releases to the environment and for estimated occupational exposures. SEE APPENDIX G FOR REFERENCE TO FULL REPORTS UNDER SEPARATE COVER)

INITIAL REVIEW ENGINERING REPORT

P-12-0433
Post Focus Review Draft 10/13/2016

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
PV (kg/yr): 23,138 Import Only

Revision Notes/Assessment Overview: 06/29/16 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 increases as a result of a larger hand surface area used as default in dermal exposure calculations.

SUBMITTER: INEOS Chlor Americas

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: No

Gen Eqpt: If prolonged or excessive skin contact is likely: Wear suitable protective clothing and gloves. // If splashing or mist is likely to occur: Wear eye/face protection.
Respirator: No information provided in MSDS.
Health Effects: Eye: may cause slight eye irritation. // Skin: unlikely to cause skin irritation in man. // Ingestion: unlikely to be hazardous if swallowed. // Inhalation: unlikely to be hazardous by inhalation. // Chronic Effects: repeated exposure to high levels may product liver and kidney damage.
TLV/PEL: - none established

CRSS:
Chemical Name: Alkanes, C18‑20, chloro
S-H2O: 0.000006 g/L @
VP: 4.0E-6 torr @
MW: 412 %<500 %<1000
Physical State and Misc CRSS Info: Neat: liquid	Mfg: liquid
Proc/Form: liquid	End Use: 15% in final product. The chlorinated products would range from C17H31Cl5 (at ~40% chlorination) to C20H34Cl8 (at ~50% chlorination).  The parent hydrocarbon had a measured composition: C17: 17.06% (max 20) C18: 64.71% (45‑70) C19: 13.67% (15‑27) C20: 2.13% (4‑12) The chlorination content looks to range between roughly 40 ‑ 55%.

Consumer Use: No

SAT (concerns):
SAT data not yet available
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:
06/29/16 Update: This IRER was revised to utilize the methodologies from 2 CP assessments completed 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 area used as default in dermal exposure calculations.  The remaining portion of this provides information from the previous assessment. Generated by the 09/30/2013 version of ChemSTEER. ***   Generated by the 06/07/2005 version of ChemSTEER. This PMN is a liquid LCCP product that is imported and used as a lubricant in metal working fluids // Note, the SAT information is not yet available for this PMN. // Note, one of four exposure based criteria were met. // For PROC: This IRER assesses releases based on information provided in EU RAs and a CSR provided by the submitter and EPA/OPPT standard models. Dermal exposures were assessed and inhalation exposure is expected to negl. (VP < 0.001 torr). // For USE: This IRER assesses releases based on the 2011 ESD for the Use of Metalworking Fluids and EU RAs provided by the submitter. Dermal and inhalation exposures were assessed per the ESD. // No same‑submitter, same‑use past cases were identified. This IRER uses the same release and exposure assessment methodology as presented in different‑submitter, same‑use past cases P12‑0277 through P12‑0282. The submitter of this IRER provided the same references that were used in the assessment of MWF formulation and use for these past cases and, therefore, this IRER performs an assessment a similar manner.

POLLUTION PREVENTION CONSIDERATIONS:

EXPOSURE-BASED REVIEW: Yes	(1 criteria met)

 # of workers exposed: 216 >1000? No
 >100 workers with >10 mg/day inhalation exposure: No
 (a) >100 workers w/1-10 mg/day inh. exp. & >100 days/yr: Yes
 (b) Routine Dermal Cont: >250 workers & >100 days/yr: Yes

PROC1: Formulation of Metalworking Fluids
Number of Sites/Location: 3 sites
Unknown site(s)

Basis: The submission does not provide information on the number of customers and or use rate of the PMN in MWF formulation. The submission states that the PMN is formulated in MWFs at a conc of 10-20% for neat oils and 5% for emulsions with a typical conc of 15%. Based on different-submitter, same-use past case P12-0277 for a similar PMN substance (liquid LCCP), 69 formulation sites were estimated for a production volume of 616,763 kg/yr. Using this as a basis, CEB estimates the number of formulation sites for a PV of 23,138 kg/yr as (23,138/619 763) * 69 ~ 3 sites. Batch size at formulation sites is unknown.  Previous larger-scale related PMN submissions (P-12-0277 and P-12-0357) estimated batch sizes at MW Fluid formulation sites of greater than 1000 gallons.  CEB assumes a batch size of at least 500 gallons (equivalent to 283 kg of PMN chemical at 15% concentration) to estimate the kg/batch and number of batches.

Process Description: PMN (liquid, 100%) is unloaded from import containers ---> feed into blending tank ---> packaging of metal working fluids containing PMN (10-20% for neat oil and 5% for emulsions) (submission past Std Review cases for CPs)

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 data from documents provided by the submitter as well as EPA/OPPT standard models.

2012 EPA Assessment
Water or Incineration or Landfill
High End: 8.6E+0 kg/site-day over 27 day/yr from 3 sites
to: uncertain
2016 Expanded EPA Assessment (Oil-based fluids)
Water or Incineration or Landfill
Monthly: 1.4E+1 kg/site-day over 12 day/yr from 2 sites
Quarterly: 4.3E+1 kg/site-day over 4 day/yr from 2 sites
to: Uncertain
2016 EPA Expanded Assessment (water based, on-site pretreatment with 50% efficiency)
Water or Incineration or Landfill
Monthly: 7.2E+0 kg/site-day over 12 day/yr from 2 sites
Quarterly: 2.2E+1 kg/site-day over 4 day/yr from 2 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
Monthly: 4.3E+0 kg/site-day over 12 day/yr from 2 sites
Quarterly: 1.3E+1 kg/site-day over 4 day/yr from 2 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
Monthly: 1.4E-1 kg/site-day over 12 day/yr from 2 sites
Quarterly: 4.3E-1 kg/site-day over 4 day/yr from 2 sites
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 does not provide information to estimate releases from container cleaning. Due to uncertainty at multiple downstream sites, CEB assesses releases to uncertain media using the standard model loss fraction of 3%.
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
Conservative: 5.7E+0 kg/site-day over 27 day/yr from 3 sites
to: Uncertain
2016 Expanded EPA Assessment (Oil-based fluids)
Incineration or Landfill
Conservative: 2.8E+0 kg/site-day over 20 day/yr from 2 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: 4.8E-1 kg/site-day over 61 day/yr from 2 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: 2.8E-1 kg/site-day over 61 day/yr from 2 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: 9.5E-3 kg/site-day over 61 day/yr from 2 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 does not provide information to estimates releases from equipment cleaning. Due to uncertainty at multiple downstream sites, CEB assesses releases to uncertain media using the standard model loss fraction of 2%.
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: 5.7E-1 kg/site-day over 27 day/yr from 3 sites
to: fugitive air (2005 EU RA, 2009 EU RA)
from: Fugitive Air Emissions
basis: User-Defined Loss Rate Model. Data from a 2005 EU RA for MCCP provided by the submitter 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 kg/yr / 7,713 kg/site-yr =  0.2% for the current operations). A 2009 EU RA for LCCPs provided by the submitter estimates a loss of 58 g/day, or 14.5 kg/yr assuming 250 days/yr of operation (14.5/7,713  = 0.19% for current operations). Due to uncertainty at multiple downstream use sites, CEB includes this release source using the high end estimate.

Incineration or Landfill
Output 2: 5.7E+0 kg/site-day over 27 day/yr from 3 sites
to: incineration or landfill (2009 EU RA)
from: Off-Spec Material
basis: User-Defined Loss Rate Model. Data from a 2009 EU RA for LCCPs 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: 1.7E+3 kg/yr - all sites
2016 EPA Expanded Assessment (Oil-Based Fluids): 6.9E+2 kg/yr - all sites
2016 EPA Expanded Assessment (water-based, on-site pretreatment with 50% efficiency): 6.4E+2 kg/yr - all sites
2016 EPA Expanded Assessment (water-based, on-site pretreatment with 70% efficiency): 4.8E+2 kg/yr - all sites
2016 EPA Expanded Assessment (water-based, on-site pretreatment with 99% efficiency): 2.4E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 24
Basis: The submission does not provide an estimate for the number of workers/site. Previous related submissions (p-12-0277 to P-12-0284) indicated 4 to 8 workers per site.  CEB assumes 8.

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 27 days/yr
Number of workers (all sites) with Dermal exposure: 24
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: 4.5E+2 mg/day over 27 days/yr
Number of workers (all sites) with Dermal exposure: 24
Basis: Loading Liquid Product into Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

USE1: Use of Metalworking Fluids
Number of Sites/Location: 4 sites
unknown site(s)

Days/yr: 247

Basis: he submission does not provide any information for end use of MWFs. The submission estimates a typical conc of PMN in MWFs of 15%. The 2011 ESD for MWF Operations estimates 247 days/yr of operation. The ESD
estimates the number of sites as: (23,138 kg/yr) / (12,000 gal/site-yr x 1 kg/L x 3.785 L/gal x 0.15) ~ 4 sites. Environmental releases are of concern for this PMN. As conservative, CEB assumes 247 days/yr of operation and the ESD estimate of 4 sites. CEB also assumes up to 20% PMN in raw material, and 2% PMN during metalworking operations. CS calcualtes a use rate of 23.4192 kg/site-day.
Process Description: Bulk MWF containing PMN (liquid, 10-20 percent neat oil or 5% emulsion) is unloaded from transport containers ---> transfer to mixing vessel ---> dilution of MWF ---> diluted MWF containing PMN (liquid, assume 1-2% for neat oil and 0.5% for emulsion assuming a 10 fold dilution) transferred to metal shaping trough ---> metal shaping operation ---> shaped metal part is rinsed and dried ---> spent MWF is drained and discarded (submission, ESD, past std review cases for CPs)

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 releases estimates were based data provided in reports provided by the submitter as well as the 2011 ESD for the Use of Metalworking Fluids.

2012 EPA Assessment
Water or Incineration or Landfill
High End: 1.2E+0 kg/site-day over 139 day/yr from 4 sites
to: water, incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Oil-Based Fluids)
Incineration or Landfill
High End: 1.2E+0 kg/site-day over 69 day/yr from 4 sites
to: incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 50% on-site pretreatment)
Water, Incineration or Landfill
High End: 1.8E-1 kg/site-day over 247 day/yr from 4 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: 1.1E-1 kg/site-day over 247 day/yr from 4 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: 3.5E-3 kg/site-day over 247 day/yr from 4 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 does not provide estimates for releases during MWF use. 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 drums residuals 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: 2.5E+0 kg/site-day over 247 day/yr from 4 sites
to: on-site WWTP or POTW (ESD)
2016 Expanded EPA Assessment (Oil-Based Fluids)
Water or Incineration or Landfill
Output 2: 1.2E+0 kg/site-day over 247 day/yr from 4 sites
to: water, incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 50% on-site pretreatment)
Water
High End: 6.2E-1 kg/site-day over 247 day/yr from 4 sites
to: on-site WWTP or POTW (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 70% on-site pretreatment)
Water
High End: 3.7E-1 kg/site-day over 247 day/yr from 4 sites
to: on-site WWTP or POTW (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 99% on-site pretreatment)
Water
High End: 1.2E-2 kg/site-day over 247 day/yr from 4 sites
to: on-site WWTP or POTW (ESD)
from: Dragout Losses
basis: User-Defined Loss Rate Model. A 2005 EU RA for MCCPs and a 2009 EU RA for LCCPs provided by the submission estimates workpiece dragout to account for 1 to 2% with releases water or chemical waste and grinding swarf dragout is estimated to be 30 to 90% with releases to incineration or landfill. 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. The data from the 2011 ESD is most representative of U.S. industry and is therefore used as the basis for releases.
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: 8.2E+0 kg/site-day over 247 day/yr from 4 sites
to: water, incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Oil-Based Fluids)
Incineration or Landfill
Output 2: 4.1E+0 kg/site-day over 247 day/yr from 4 sites
to: incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 50% on-site pretreatment)
Water, Incineration or Landfill
High End: 2.0E+0 kg/site-day over 247 day/yr from 4 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: 1.2E+0 kg/site-day over 247 day/yr from 4 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: 4.1E-2 kg/site-day over 247 day/yr from 4 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 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: 1.0E+1 kg/site-day over 247 day/yr from 4 sites
to: water, incineration, or landfill (ESD)
2016 Expanded EPA Assessment Oil-Based Fluids)
Incineration or Landfill
Output 2: 6.0E+0 kg/site-day over 247 day/yr from 4 sites
to: incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 50% on-site pretreatment)
Water, Incineration or Landfill
High End: 3.0E+0 kg/site-day over 247 day/yr from 4 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: 1.8E+0 kg/site-day over 247 day/yr from 4 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: 6.0E-2 kg/site-day over 247 day/yr from 4 sites
to: Pretreatment (99% efficiency) then to POTW, incineration or landfill
from: Spent Metalworking Fluid
basis: User-Defined Loss Rate Model.  The 2011 ESD for MWF Operations also assesses 100% release with the spent MWF disposed to water (water-based fluids) or incineration or landfill (straight oil fluids) with at least one bath changeout 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: 1.1E+0 kg/site-day over 247 day/yr from 4 sites
to: air (2002 EU RA)
from: Misting/Evaporation
basis: User-Defined Loss Rate Model. A 2005 EU RA for MCCP and a 2009 EU RA for LCCPs provided by the submitter 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: 2.3E+4 kg/yr - all sites
2016 Expanded EPA Assessment (Oil-Based Fluids): 1.2E+4 kg/yr - all sites
2016 Expanded EPA Assessment (Water-Based Fluids, 50% on-site pretreatment): 5.8E+3 kg/yr - all sites
2016 Expanded EPA Assessment (Water-Based Fluids, 70% on-site pretreatment): 3.5E+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: 192
Basis: The 2011 ESD for MWF Use estimates 48 workers/site.
Inhalation:

Exposure to Mist
High End of Range: 7.1E+0 mg/day over 247 days/yr
Typical: 2.0E+0 mg/day over 247 days/yr
Number of workers (all sites) with Inhalation exposure: 192
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 water portion is 60% of fluid.  Based on up to 20% concentration of PMN chemical in the neat fluid, the concentration of the PMN chemical in the mist could be as high as 50% (20%/40%).  Note, a 2005 EU RA for MCCPs and a 2009 EU RA for LCCPs estimates mist concentrations from 1.6 to 3.4 mg/m3 based on the 95th percentile of data collected in the EU for oil-based and water-based fluids. The data from the 2011 ESD are more representative of U.S. operations since the data were collected in the U.S.

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: 4.5E+2 mg/day over 247 days/yr
Number of workers (all sites) with Dermal exposure: 192
Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

Dermal:

Exposure to Mist
Output 1: 3.9E+3 mg/day over 247 days/yr
Number of workers (all sites) with Dermal exposure: 1992
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. CEB conservatively assessed straight oil where Fchem_trough = Fchem_neat

P-12-0453
Post Focus Review Draft 10/19/2016

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
PV (kg/yr): 2,546,302 Import Only

Revision Notes/Assessment Overview: 06/29/16 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 inceases as a result of a larger hand surface area used as default in dermal exposure calculations.  The remaining portion of this provides information from the previous assessment. ***  The assessment of this PMN is based on data provided by the submitter as well as data that was collected during EPA previous efforts to assesses environmental releases and occupational exposures during the manufacturing, processing, and use of MCCPs and LCCPs. Additional literature sources that have been reviewed include: 1) previous EPA assessments on chlorinated paraffins; 2) foreign risk assessments on MCCPs and LCCPs (e.g. EU risk assessments); 3) EPA/OPPT Generic Scenarios; 4) OECD Emission Scenario Documents; and 5) Toxics Release Inventory data. Data provided by the submitter, data identified in the literature review, and EPA/OPPT standard models were reviewed and the best available data were used to assesses environmental releases and occupational exposures.

SUBMITTER: Ineos

USE: 1) Seventeen percent (17%) of the notification substances are used as a flame retardant/plasticizer in polymers.  Typical concentration in the plastic is 15%. 2)  Seventy-four percent (74%) of the notification substance is used as a lubricant in metal working fluids (MWFs). The notification substance is blended into the MWFs at 15%. 3)  Two percent (2%) of the notification substances is used as lubricants in sealants (formulated at 10%); and finally 4) Seven percent (7%) of PV is used as plasticizer in adhesives at about 20% formulation.

OTHER USES: Generic uses MCCP based on open lit & other PMN submissions: 1) used as lubricants in automotives. The notification substance i blended into the lubricant at 4%.  [20% consumer uses]. 2)  used as a flame retardant/plasticizer in rubber.  Typical total concentration of flame retardant/plasticizer in the rubber is 1-10%, 3) used as a plasticizer in solvent based paints, adhesives and sealants.  The paints can be specialty paints for applications where weather resistant coatings are needed, such as steel construction, industrial flooring, road marking, and swimming pools. Often blended into the paints at 5-15%.  4) One-half of one percent of the notification substances are applied as a flame retardants/waterproofers to textiles.  Can be at 5% of the textile coating finishing solution.

MSDS:  Yes										LABEL: No

Gen Eqpt: If prolonged or excessive skin contact is likely: Wear suitable protective clothing and gloves. // If splashing or mist is likely to occur: Wear eye/face protection.
Respirator: No information provided.
Health Effects: Eye: Contact with eyes may cause irritation // Skin: Unlikely to cause skin irritation // Inhalation: Unlikely to be hazardous by inhalation. // Ingestion: Unlikely to be hazardous if swallowed. // Chronic Effects: repeated exposure to high levels may produce live and kidney damage.
TLV/PEL: - none established

CRSS:
Chemical Name: Alkanes, C14-17, chloro
S-H2O: 0.00003 g/L @
VP: 2.0E-5 torr @
MW: 336 %<500 %<1000
Physical State and Misc CRSS Info: Neat: liquid	Mfg: liquid
Proc/Form: variable	End Use: 5 - 20% in final product. The average molecular formula would range from C14H26Cl4  ( LOWWT at  ~40% chlorination) to C17H26Cl10 high wt (at ~ 60% chlorination). C# : % (range)  C14: 36 (30-40); C15: 30 (25-35); C16: 24 (20-30); and C17: 10 (8-18)  ChemSpider EPI est for 1,2-dichlorotetradecane : BP  339  / VP  < 1 E-3 mm Hg / s-H2O  < 6  E-6 g/L P-Chem values reported are est / measured supplied by INEOS

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: 2-3D

NOTES & KEY ASSUMPTIONS:
06/29/16 Update: This IRER was revised to utilize the methodologies from 2 CP assessments completed 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 area used as default in dermal exposure calculations.  The remaining portion of this provides information from the previous assessment. Generated by the 09/30/2013 version of ChemSTEER. *** This PMN is a MCCP product that is imported and used in the following applications: 1) 16.8%as a plasticizer in PVC production 2) 8.3 % as a lubricant in metal working fluids (MWFs) 3) 7.4% used in adhesives and 4) 2% used in sealants // Note, the SAT information is not yet available for this PMN. // For downstream processing and use operations: The releases 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. Many of the sources reviewed by EPA were also provided by the submitter (2005 EU RA on MCCPs, 2010 CSR). Due to the uncertainty at multiple downstream use sites, the most conservative data were chosen when evaluating releases for downstream operations. This assessment approach is consistent with the approached used for previous standard reviews of chlorinated paraffin products including P12‑0277 through P12‑0284, P12‑0357, and P12‑0433. This assessment includes adhesive and sealant formulation and use which is a use that was not listed in the previous assessments. The formulation of adhesives/sealants assessment was based on information provided in sources from the submitter and the 2009 ESD for the Formulation of Adhesives. The end use of adhesives/sealants was based on the 2008 ESD for the Use of Adhesives. // Note, all exposure‑based criteria were met.

POLLUTION PREVENTION CONSIDERATIONS:

EXPOSURE-BASED REVIEW: Yes	(3 criteria met)

 # of workers exposed: 13,834 >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

PROC1: Formulation of Metalworking Fluids (73.8% of PV)
Number of Sites/Location: 59 sites
unknown site(s)

Basis: The submission does not provide information on the number of customers and or use rate of the PMN in MWF formulation. The submission states that the PMN is formulated in MWFs at a conc of 10-20% for neat oils and 5% for emulsions. Based on different-submitter, same-use past case P12-0280 for the same PMN substance, 110 formulation sites were estimated for a production volume of 3,524,972 kg/yr. Using this as a basis, CEB estimates the number of formulation sites for a PV of 1,879,171 kg/yr as (1,878,171/3,524,972) * 110 ~ 59 sites. CEB assumes at least a 500 gallon mixing vessel to estimate daily throughput of PMN chemical of 378 kg and 84 days/yr. Process Description: PMN (liquid, 100%) is unloaded from import containers ---> feed into blending tank ---> blending ---> packaging of metal working fluids containing PMN (10 - 20% for neat oils, 5% for emulsions) (submission, CRSS, previous Std Review past cases for MCCPs)

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 releases 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. 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: 1.1E+1 kg/site-day over 84 day/yr from 59 sites
to: uncertain
2016 Expanded EPA Assessment (Oil-based fluids)
Water or Incineration or Landfill
Monthly: 7.8E+1 kg/site-day over 12 day/yr from 30 sites
Quarterly: 2.2E+2 kg/site-day over 4 day/yr from 30 site
to: Uncertain
2016 EPA Expanded Assessment (water based, on-site pretreatment with 50% efficiency)
Water or Incineration or Landfill
Monthly: 3.9E+1 kg/site-day over 12 day/yr from 30 sites
Quarterly: 1.2E+2 kg/site-day over 4 day/yr from 30 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: 2.3E+1 kg/site-day over 12 day/yr from 30 sites
Quarterly: 7.0E+1 kg/site-day over 4 day/yr from 30 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: 7.8E-1 kg/site-day over 12 day/yr from 30 sites
Quarterly: 2.3E+0 kg/site-day over 4 day/yr from 30 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 does not provide an estimate for releases from drum residuals. Due to uncertainty at multiple downstream sites, CEB assesses releases to uncertain media using the EPA/OPPT Drum residual model.
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: 7.6E+0 kg/site-day over 84 day/yr from 59 sites
to: Uncertain
2016 Expanded EPA Assessment (Oil-based fluids)
Incineration or Landfill
Conservative: 1.3E+0 kg/site-day over 240 day/yr from 30 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: 6.5E-1 kg/site-day over 240 day/yr from 30 sites
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: 3.9E-1 kg/site-day over 240 day/yr from 30 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: 1.3E-2 kg/site-day over 240 day/yr from 30 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 does not provide an estimate for releases from equipment cleaning. Due to uncertainty at multiple downstream sites, CEB assesses releases to uncertain media using the EPA/OPPT Multiple Vessel Model.
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: 1.9E-1 kg/site-day over 84 day/yr from 59 sites
to: fugitive air (2005 EU RA from submission, 2010 Japan RA)
from: Fugitive Air Emissions
basis: User-Defined Loss Rate Model. Data from a 2005 EU RA for MCCP provide by the submitter 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 (16kg/yr / 31,850 kg/site-yr = 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 based on the 2005 EU RA.

Incineration or Landfill
Output 2: 7.6E+0 kg/site-day over 84 day/yr from 59 sites
to: incineration or landfill (2005 EU RA from submission)
from: Off-Spec Material
basis: User-Defined Loss Rate Model. Data from a 2005 EU RA for MCCPs provided by the submitter 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: 1.3E+5 kg/yr - all sites
2016 EPA Expanded Assessment (Oil-Based Fluids): 5.6E+4 kg/yr - all sites
2016 EPA Expanded Assessment (water-based, on-site pretreatment with 50% efficiency): 3.8E+4 kg/yr - all sites
2016 EPA Expanded Assessment (water-based, on-site pretreatment with 70% efficiency): 3.0E+4 kg/yr - all sites
2016 EPA Expanded Assessment (water-based, on-site pretreatment with 99% efficiency): 1.9E+4 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 472
Basis: The submission does not provide an estimate for the number of workers/site. Previous related submissions (P-12-0277 to P-12-0284) indicated 4 to 8 workers per site.  CEB assumes 8.

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 84 days/yr
Number of workers (all sites) with Dermal exposure: 472
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: 4.5E+2 mg/day over 84 days/yr
Number of workers (all sites) with Dermal exposure: 472
Basis: Loading Liquid Product into Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

PROC2: PVC Compounding (16.8% of PV)
Number of Sites/Location: 8
unknown site(s)

Days/yr: 126

Basis: Per submission, PMN is used at 100% and is present in compounded PVC at 15%. Estimates for a series of recent related cases (P-12-0277 to P-12-0284) estimated an average of 54,000 kg of chlorinated paraffin per site-yr for this use category.  CEB estimates 8 use sites based on this data.  These same cases also estimated an average kg/site-day for the chlorinated paraffin of 425.7 kg/site-day. Based on the PV for this use category, 8 sites and 425.7 kg/site-day, CEB estimates 126 days/site-yr.
Process Description: PMN (liquid, 100%) is unloaded from transport containers into feeder ---> feed into mechanical mixer ---> extrusion, injection molding, calendaring or other process to form compounded shapes (i.e. pellets, sheets) ----> PMN (solid, 15%) charged to bulk container (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 releases 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. Due to the uncertainty at multiple downstream use sites, the most conservative data was chosen when evaluating releases for downstream operations.

Water
High End: 4.3E-3 kg/site-day over 126 day/yr from 8 sites
to: water or air (GS)
from: Fugitive Air Emission During High Temperature Extrusion
basis: User-Defined Loss Rate Model. The 2004 GS for Plastics Compounding estimates a loss rate of 0.002% to fugitive air for low volatility substances which would include MCCP substances. 50% of the releases are expected to remain in the air while the other 50% is expected to be released to water.

2012 EPA Assessment
Water or Incineration
Output 1: 8.5E+0 kg/site-day over 126 day/yr from 8 sites
to: water or incineration (GS)
EPA 2016 Expanded Assessment
Incineration or Landfill
Conservative: 8.5E+0 kg/site-day over 126 day/yr from 8 sites
to: incineration or Landfill (industry comment)
from: Equipment Cleaning Losses of Liquids, from Compounding Equipment
basis: User-Defined Loss Rate Model. The 2004 GS for Plastics Compounding estimates a loss rate of 2% based on the EPA/OPPT Multiple Vessel Residual model with releases to water.
EPA 2016 Expanded Assessment: Assesses release to incineration or landfill, per industry information.

2012 EPA Assessment
Water or Incineration or Landfill
Output 1: 1.3E+1 kg/site-day over 126 day/yr from 8 sites
to: water, incineration or land (GS)
EPA 2016 Expanded Assessment
Water or Incineration or Landfill
Monthly: 1.3E+2 kg/site-day over 12 day/yr from 8 sites
Quarterly: 4.0E+2 kg/site-day over 4 day/yr from 8 sites
to: Water or Incineration or Landfill (GS)
from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material
basis: User-Defined Loss Rate Model. The 2004 GS for Plastics Compounding estimates a loss rate of 3% based on the EPA/OPPT Drum Residual model with releases to water, incineration, or landfill.
EPA 2016 Expanded Assessment: Assumes quarterly or monthly container cleaning, per industry information indicating containers are not picked up daily by a waste handler.

Water or Incineration or Landfill
High End: 4.3E-2 kg/site-day over 126 day/yr from 8 sites
to: water, incineration, or landfill (submission, GS)
from: Spillage During Raw Material Handling
basis: User-Defined Loss Rate Model. A 2005 EU RA for MCCPs provided by the submitter and the 2004 GS for Plastic Compounding estimates a loss rate of 0.01% from spillage during raw material handling with releases to water, incineration, or landfill.

Air
High End: 4.3E-3 kg/site-day over 126 day/yr from 8 sites
to: water or air (GS)
from: Fugitive Air Emission During High Temperature Extrusion
basis: User-Defined Loss Rate Model. The 2004 GS for Plastics Compounding estimates a loss rate of 0.002% to fugitive air for low volatility substances which would include MCCP substances. 50% of the releases are expected to remain in the air while the other 50% is expected to be released to water.

RELEASE TOTAL

2012 EPA Assessment: 2.1E+4 kg/yr - all sites
EPA 2016 Expanded Assessment: 2.2E+4 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 192
Basis: The submission estimates up to 3 worker/site. The GS for Plastic Compounding estimates up to 24 workers/site.

Inhalation:

Exposure to Particulate
High End of Range: 4.4E+0 mg/day over 126 days/yr
Low End of Range: 3.0E-2 mg/day over 126 days/yr
Number of workers (all sites) with Inhalation exposure: 192
Basis: Fugitive Air Emission During High Temperature Extrusion; User-defined Inhalation Model. The 2004 GS for Plastics Compounding suggests that inhalation exposure is negligible for non-volatile substances during compounding. A 2008 EU Risk Assessment on MCCP provided by the submitter contains monitoring data from plastic compounding operations is the EU. The monitoring data is based on 32 air samples from 4 sites. Results showed MCCP air concentrations ranging from <0.003 to 0.44 mg/m3 with a median of 0.03 mg/m3 and a 90th percentile of 0.15 mg/m3. It is unknown whether these data represent area or personal monitoring data. As conservative, exposures estimates are presented based on the low and high of the range for these data.

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+3 mg/day over 126 days/yr
Number of workers (all sites) with Dermal exposure: 192
Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

PROC3: Formulation of Adhesives and Sealants (9.4% of PV)
Number of Sites/Location: 3 sites
unknown site(s)
Days/yr: 200
Basis: The submission estimates 5% PMN in adhesives and 10-30% in sealants. The 2009 ESD for the Formulation of Adhesives an adhesive production rate of 17,000,000 kg/site-yr for large sites and 1,600,000 kg/site-yr for small sites. CEB assumes small sites based on production volume of PMN. Assuming 5% conc to maximize the number of sites, the ESD estimates the number of formulation sites as: (236,352 kg/yr) / (1,600,000 kg/site-yr x 0.05) ~ 3 sites. The ESD also estimates the number of batches as follows: 1,600,000 kg/site-yr / 4,000 kg/bt = 400 bt/yr. CEB assumes 30% conc in product to conservatively assess exposures. CS calculates a use rate of 199.46 kg/bt.
Process Description: PMN (liquid, 100%) unloaded from containers ---> transfer to mixing vessel ---> mixing assuming unsealed process ---> PMN (5% in adhesives, 10-30% in sealants) packaged for shipment to customers (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 releases estimates were based on a combination of sources provided by the submitter and estimates from the 2009 ESD for Adhesive Formulation. Due to the uncertainty at multiple downstream use sites, the most conservative data were chosen when evaluating releases for downstream operations.
2016 EPA Expanded Assessment: Based on industry comments, releases to uncertain as well as releases to wastewater treatment (wastewater treatment efficiencies of 50, 70, and 99%) have been assessed.

EPA 2012 Assessment
Water or Incineration or Landfill
High End: 1.2E+1 kg/site-day over 200 day/yr from 3 sites
to: Water or Incineration or Landfill (ESD)
2016 Expanded EPA Assessment (50% on-site pretreatment)
High End: 6.0E+0 kg/site-day over 200 day/yr from 3 sites
to: Pretreatment (50% efficiency) then to POTW, incineration or landfill
2016 Expanded EPA Assessment (70% on-site pretreatment)
High End: 3.6E+0 kg/site-day over 200 day/yr from 3 sites
to: Pretreatment (70% efficiency) then to POTW, incineration or landfill
2016 Expanded EPA Assessment (99% on-site pretreatment)
High End: 1.2E-1 kg/site-day over 200 day/yr from 3 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 2009 ESD for Adhesive Formulation assesses container residuals to uncertain media using the drum residual model.
2016 EPA Expanded Assessment (on-site pretreatment with 50%, 70% and 99% efficiency): Industry information indicates discharge to POTW would first be pretreated  -  50 - 99% efficiency. This presents release to POTW (with pretreatment 50%, 70% and 99% removal efficiency).

EPA 2012 Assessment
Water or Incineration or Landfill
Conservative: 8.0E+0 kg/site-day over 200 day/yr from 3 sites
to: Water or Incineration or Landfill (submission, GS)
2016 Expanded EPA Assessment (50% on-site pretreatment)
Conservative: 4.0E+0 kg/site-day over 200 day/yr from 3 sites
to: Pretreatment (50% efficiency) then to POTW, incineration or landfill (2005 EU RA from the submitter, ESD, and industry comments)
2016 Expanded EPA Assessment (70% on-site pretreatment)
Conservative: 2.4E+0 kg/site-day over 200 day/yr from 3 sites
to: Pretreatment (70% efficiency) then to POTW, incineration or landfill (2005 EU RA from the submitter, ESD, and industry comments)
2016 Expanded EPA Assessment (99% on-site pretreatment)
Conservative: 8.0E-2 kg/site-day over 200 day/yr from 3 sites
to: Pretreatment (99% efficiency) then to POTW, incineration or landfill (2005 EU RA from the submitter, ESD, and industry comments)
from: Equipment Cleaning Losses of Liquids from a Mixing Tank
basis: User-Defined Loss Rate Model. A 2005 EU RA for MCCPs provided by the submitter estimates a loss rate of up to 5% from equipment cleanout with releases to incineration or landfill. The 2009 ESD for Adhesives Formulation assesses equipment cleaning wastes to uncertain media using a 2% loss fraction.
2016 EPA Expanded Assessment (on-site pretreatment with 50%, 70% and 99% efficiency): Industry information indicates discharge to POTW would first be pretreated  -  50 - 99% efficiency. This presents release to POTW (with pretreatment 50%, 70% and 99% removal efficiency).

Water or Incineration or Landfill
Output 2: 2.0E+2 kg/site-day over 4 day/yr from 3 sites
to: water, incineration, or landfill (ESD)
from: Off-Spec Material
basis: User-Defined Loss Rate Model. The 2009 ESD for Adhesive Formulation estimates releases from off-spec batches with 1% of batches being off-spec and released to water, incineration, or landfill. This is equal to (400 bt/site-yr x 0.01) = 4 bt/yr. At 199.46 kg/bt and 1 off-spec bt/day, it is assumed that 199.46 kg/site-day will be released over 4 days/yr.

RELEASE TOTAL

2012 EPA Assessment: 1.4E+4 kg/yr - all sites
2016 EPA Expanded Assessment (on-site pretreatment with 50% efficiency): : 8.4E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 66
Basis: The 2009 ESD for Adhesive Formulation estimates 22 workers/site exposed during formulation.

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: 66
Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

Dermal:

Exposure to Liquid
High End: 5.3E+2 mg/day over 34 days/yr
Number of workers (all sites) with Dermal exposure: 66
Basis: Loading Liquid Product into Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

USE1: Use of Metalworking Fluids 73.8% of PV)
Number of Sites/Location: 207 sites .
unknown sites

Days/yr: 247

Basis: The submission does not provide an estimate for the number of metalworking fluid use sites. The 2011 ESD for MWF Operations estimates 247 days/yr of operation. The Assuming 20% PMN in MWF, the ESD estimates the number of sites as: (1,879,171 kg/yr) / (12,000 gal/site-yr x 1 kg/L x 3.785 L/gal x 0.2) = 207 sites. Environmental releases are of concern for this PMN. As conservative, CEB assumes 247 days/yr of operation and the ESD estimate of 207 sites to maximize kg/site-day release. CEB assumes up to 20% PMN in raw material for straight oils.  Per ESD, straight oils are not expected to be diluted prior to MWF use; therefore, CEB assumes 20% PMN during use to maximize exposure to mist. CS calculates 36.7535 kg/site-day.
Process Description: Bulk MWF containing PMN (liquid, 10-20% for neat oils, 5% for emulsions) is unloaded from transport containers ---> transfer to mixing vessel ---> dilution of MWF ---> diluted MWF containing PMN (liquid, 10-20% for straight oil, assume 10-fold dilution for water-based emulsions, 0.5%) transferred to metal shaping trough ---> metal shaping operation ---> shaped metal part is rinsed and dried ---> spent MWF is drained and discarded (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 releases 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.  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: 1.2E+0 kg/site-day over 218 day/yr from 207 sites
to: water, incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Oil-Based Fluids)
Incineration or Landfill
High End: 1.2E+0 kg/site-day over 18 day/yr from 292 sites
to: incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 50% on-site pretreatment)
Water, Incineration or Landfill
High End: 6.2E-1 kg/site-day over 77 day/yr from 292 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: 3.7E-1 kg/site-day over 77 day/yr from 292 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: 1.2E-2 kg/site-day over 77 day/yr from 292 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 2011 ESD for MWF Operations estimates releases using the EPA/OPPT drum residual model (3% loss rate) with releases to water, incineration, or landfill. Due to uncertainty at multiple downstream sites, these releases are assessed to uncertain media using a 3% loss rate.
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: 3.9E+0 kg/site-day over 247 day/yr from 207 sites
to: on-site WWTP or POTW (ESD)
2016 Expanded EPA Assessment (Oil-Based Fluids)
Water or Incineration or Landfill
Output 2: 1.4E+0 kg/site-day over 247 day/yr from 292 sites
to: water, incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 50% on-site pretreatment)
Water
High End: 7.0E-1 kg/site-day over 247 day/yr from 292 sites
to: on-site WWTP or POTW (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 70% on-site pretreatment)
Water
High End: 4.2E-1 kg/site-day over 247 day/yr from 292 sites
to: on-site WWTP or POTW (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 99% on-site pretreatment)
Water
High End: 1.4E-2 kg/site-day over 247 day/yr from 292 sites
to: on-site WWTP or POTW (ESD)
from: Dragout Losses
basis: User-Defined Loss Rate Model. The 2011 ESD for MWF Operations estimates workpiece dragout to account for 1 to 2% with releases water or chemical waste and grinding swarf dragout is estimated to be 30 to 90% with releases to incineration or landfill. A 2010 EU CSR for MCCPs estimates overall process losses to be 1 to 6% with releases to water. 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: 1.3E+1 kg/site-day over 247 day/yr from 207 sites
to: water, incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Oil-Based Fluids)
Incineration or Landfill
Output 2: 4.5E+0 kg/site-day over 247 day/yr from 292 sites
to: incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 50% on-site pretreatment)
Water, Incineration or Landfill
High End: 2.3E+0 kg/site-day over 247 day/yr from 292 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: 1.4E+0 kg/site-day over 247 day/yr from 292 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: 4.5E-2 kg/site-day over 247 day/yr from 292 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 submission 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: 1.6E+1 kg/site-day over 247 day/yr from 207 sites
to: water, incineration, or landfill (ESD)
2016 Expanded EPA Assessment Oil-Based Fluids)
Incineration or Landfill
Output 2: 6.7E+0 kg/site-day over 247 day/yr from 292 sites
to: incineration, or landfill (ESD)
2016 Expanded EPA Assessment (Water-Based Fluids, 50% on-site pretreatment)
Water, Incineration or Landfill
High End: 3.4E+0 kg/site-day over 247 day/yr from 292 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: 2.0E+0 kg/site-day over 247 day/yr from 292 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: 6.7E-2 kg/site-day over 247 day/yr from 292 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: 1.8E+0 kg/site-day over 247 day/yr from 207 sites
to: air (2005 EU RA from submission)
from: Misting/Evaporation
basis: User-Defined Loss Rate Model. A 2005 EU RA for MCCP provided by the submitter 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: 1.8E+6 kg/yr - all sites
2016 Expanded EPA Assessment (Oil-Based Fluids): 9.2E+5 kg/yr - all sites
2016 Expanded EPA Assessment (Water-Based Fluids, 50% on-site pretreatment): 4.7E+5 kg/yr - all sites
2016 Expanded EPA Assessment (Water-Based Fluids, 70% on-site pretreatment): 2.8E+5 kg/yr - all sites
2016 Expanded EPA Assessment (Water-Based Fluids, 99% on-site pretreatment): 9.4E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 9,936
Basis: The 2011 ESD for MWF Use estimates 48 workers/site.

Inhalation:

Exposure to Mist
High End of Range: 7.1E+0 mg/day over 247 days/yr
Typical: 2.0E+0 mg/day over 247 days/yr
Number of workers (all sites) with Inhalation exposure: 9,936