I
                               CHEMICAL ENGINEERING BRANCH
                                MANUAL FOR THE PREPARATION
                                OF ENGINEERING ASSESSMENTS
                                             by

                                  IT Environmental Programs, Inc.
                                      11499 Chester Road
                                     Cincinnati, Ohio 45246
                                    Contract No. 68-D8-Q112
                                   Work Assignment No. P3-7
                                          PN 3786-64
                           U.S. ENVIRONMENTAL PROTECTION AGENCY
                                 OFFICE OF TOXIC SUBSTANCES
                                      401 M STREET, S.W.
                                   WASHINGTON, D.C. 24060
                                       February 28, 1991

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PREPARATION OF ENGINEERING ASSESSMENTS

                 VOLUME I
         Chemical Engineering Branch
       Economics and Technology Division
           Office of Toxic Substances
      U.S. Environmental Protection Agency
           Washington, D.C.  20460

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                                  CONTENTS



Figures                                                                    vii
Tables                                                                     vii
Acronyms                                                                  ix

   I. Introduction                                                           1-1

   II, Review Processes                                                     2-1

     A,  New chemical review                                               2-1
     B.  Existing chemicais review                                           2-7
     C.  Section 313 petitions                                               2-10

  111. Approaches and Data Sources for Assessment                           3-1

     A.  Approaches                                                        3-1
     B,  Data sources                                                      3-3

  IV. Modeling Workplace Exposure                                          4-1

     A.  Estimating inhalation exposures                                      4-1
     B.  Estimating dermal exposure                                         4-33
     C.  Personal protective equipment                                       4-39
     D,  Engineering controls                                               4-49

  V. Modeling Release to Water                                             5-1

     A,  Cleaning of equipment                                              5-1
     B,  Tank truck and  tank car cleaning                                    5-5
     C.  Phase  separation                                                  5-8
     D.  Condensers and scrubbers                                         5-11
     E,  Poly-electrolytes                                                    5-15
     F.  Metal working operations                                           5-17
     G,  Filtering solids from  water                                           5-18
     H,  Spray-coating operations                                           5-19

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                             CONTENTS (continued)
     I.   Leather dyeing
     J.  Drilling operations
     K.  Recirculating water-cooling towers

  VI, Modeling Release to Air                                                6-1

     A.  Process vents                                                      6-1
     B.  Tank working and breathing tosses                                  6-3
     C.  Fugitive releases                                                   6-4
     D,  Secondary sources                                                 6-6

 VII, Evaluating  Release Controls                                            7-1
     A.  Water controls                                                     7-1
     B.  Air controls                                                        7-3
     C.  Liquid and solid waste controls                                      7-8

 VIII, References                                                           8-1

Appendices

  A.     Sample Initial Review Engineering Report                             A-1
  B.     Guidelines for Coordinated ETD PMN Standard Review                B-1
  C.     Sample Production Exposure Profile  (PEP)                            C-1
  D.     Sample TRI Data                                                   D-1
  E.     Industrial Process Profiles and Other Completed Studies               E-1
  F,     Summary of Guidelines for Statistical Analysis of
          Occupational Exposure Data                                       F-1
  G,     Derivation of Formulas for Calculation of Workplace Airborne
           Concentration                                                   G-1
  H,     Chart of Body Areas and Estimation  of Skin Area                      H-1
   I.     Other Factors to be Considered in Respirator Selection                1-1
  J.     Standard Language for 5(e) Orders and SNURs                       j-1
  K.     Derivation of Equation for Evaporation From Open Surfaces (Revised)   K-1
                                       VI

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                                  FIGURES



Number                                                                 Page



  3-1     Matrix of Data Contained in Volume II                               3-8



  3-2     Matrix of Data Bases Contained in Volume til                        3-9



 5-1     Schematic of Cooling Tower System                               5-25



  7-1     Venturi Scrubber Collection Efficiencies                             7-9
                                      VII

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                                    TABLES

Number                                                                   Page

  4-1     Inhalation Rates                                                   4-2

  4-2     Estimated Airborne Concentrations of Total Mist for Spray Coating
           Operations                                                     4-8

  4-3     Typical Parameters for Dye Weighing Operations                     4-10

  4-4     Estimated Airborne Concentrations for Metalworking                  4-11

  4-5     Typical Compound Composition for Tire Manufacturing                4-13

  4-6     Summary of NIOSH Monitoring Data for Particulate Exposures in
           Tire-Manufacturing Operations Based on Seven Plants              4-14

  4-7     Default Distribution Factors                                         4-23

  4-8     Saturation Factors for Bulk Loading Operation                        4-26

  4-9     Air Emission Factors for Loading                                   4-27

  4-10   Typical Diameters and Areas                                       4-31

  4-11   Summary of Concentration Calculations for Transfer Operations        4-32

  4-12   Summary of Concentration Calculations for Open Surfaces            4-33

  4-13   Typical Factors for Calculation of Dermal Exposure                   4-36

  5-1     Summary of Residue Quantities  From Pilot-Scale Experimental Study   5-4

  5-2     Typical Cooling Water Additive Concentrations                        5-21

  6-1     Average Fugitive Emission Factors for the Synthetic Organic Chemicals
           Manufacturing Industry                                          6-5

  7-1     Optimal Operating Conditions for F!ares                             7-11


                                       vi

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                            LIST OF ACRONYMS

ACGIH      American Conference of Governmental Industrial Hygienists
AIHA        American Industrial Hygiene Association
ANSi        American National Standards Institute
APF        Assigned Protection Factor
ASTM       American Society for Testing  and Materials
CCD        Chemical Control Division
CEB        Chemical Engineering Branch
CEPP       Chemical Emergency Preparedness and Prevention Office
CFR        Code of Federal Regulations
CHIP        Chemical Hazard Information Profile
CPSC       Consumer Products Safety Commission
CRSS       Chemical Review Search Strategy
CSB        Chemical Screening Branch
DD         Division Director
ORE        Destruction and Removal Efficiency
EAB        Exposure Assessment Branch
ECAD       Existing Chemical Assessment Division
EED        Exposure Evaluation Division
EPCRA     Emergency Planning and Community Right-to-Know Act
ESP        Electrostatic Precipitator
ETD        Economics and Technology Division
HEPA       High Efficiency Paniculate Absolute
HERD      Health and Environmental Review Division
HHE        Health Hazard Evaluation
ICB        Industrial Chemistry Branch
1DLH       Immediately Dangerous to Life or Health
1H         Industrial Hygienist
IPPEU      Industrial Process  Profiles for Environmental Use
                                      IX

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IRER        Initial Review Engineering Report
ITC         tnteragency Testing Committee
IWS         Industry-Wide Survey
LEL         Lower Explosive Limit
LEV         Local Exhaust Ventilation
LVE         Low Volume Exemption
MCCEM     Multi-Chamber Chemical Exposure Model
MSDS       Material Safety Data  Sheet
MSHA       Mine Safety and Health Administration
NCB        New Chemicals Branch
NiOSH      National institute for  Occupational Safety and Health
NOES       National Occupational Exposure Survey
NSPS       New Source Performance Standards
ORD        Office of Research and Development
OSHA       Occupational Safety  and Health  Administration
OSWER     Office of Solid Waste and Emergency Response
OTS        Office of Toxic Substances
PEL         Permissible Exposure Limit
PEP         Production/Exposure Profile
PM         Program Manager
PMN        Prernanufacture Notification
PQTW       Publicly Owned Treatment Work
PPE        Persona! Protective Equipment
RAB        Risk Analysis Branch
RCRA       Resource Conservation and Recovery Act
RIB         Regulatory Impacts Branch
SAT        Structure Activity Team
SIC         Standard industrial Classification
SNUR       Significant New Use  Rule
STEL       Short-Term Exposure Limit

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Ti          Technical Integrator
TME       Test Market Exemption
TRl        Toxic Chemcial Release Inventory
TSCA      Toxic Substances Control Act
TWA       Time-Weighted Average
VOC .      Volatile Organic Compound
                                    XI

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     INTRODUCTION
     Engineers in the Chemical Engineering Branch (CEB) evaluate occupational
exposures and environmental releases of new and existing chemicals under the Toxic
Substances Control Act (TSCA, PL94-469),  CEB engineers also evaluate petitions
submitted under Section 313 of the Emergency Planning and Community
Right-to-Know Act (EPCRA, PL99-499), provide technical support to the Office of Solid
Waste and Emergency Response's (OSWER) Chemical Emergency Preparedness and
Prevention Office (CEPP), and participate in other Agency activities regarding the
regulation of chemicals, releases, and wastes.  This manual describes the CEB
engineer's role in these activities.  It also describes approaches and resources
available to conduct these activities in the absence of data on exposures or releases.
     The duties of CEB engineers include:
         Evaluating the methods used to manufacture, process, or use a specific
         chemical substance in order to identify potential exposures and release
         points.
          Evaluating or estimating the extent of exposure or release (e.g., the airborne
         concentration of a volatile liquid when it is drummed).
          Evaluating the effectiveness of control alternatives, including personal
          protective equipment and engineering controls, for reducing exposures or
          releases.
          Recommending appropriate controls for regulatory action.
     To perform these duties, the CEB engineer  collects information from many
sources.  These include,  but are not limited to, industry contacts, unpublished
contractor reports, journal articles, and scientific  texts. The Environmental Protection
Agency (EPA), other government agencies, and industry increasingly are collecting
quantitative data on releases of chemicals from industrial facilities and exposures  to
chemicals in the workplace. Databases and hard copy reports are routinely accessed
by CEB staff to obtain these data. Evaluating and accurately representing these data
are important functions of the CEB engineer.  CEB also continues to develop

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databases, reports, and standardized approaches in order to use existing data more
efficiently.
     The ideal exposure/release assessment would define the range of potential
releases  and/or exposures, the central tendency of the estimates (mean or median),
the descriptive statistics of the exposure/releases (percentiles, standard deviation),
and characterize the uncertainty in the estimates.  Sufficient data on releases and
exposures rareiy exist to permit full analysis. Frequently, outer bound or "reasonable
worst case" estimates are ail that can be made when tittle or no data exist,
     In the absence of data, the CEB engineer must estimate releases and exposures.
Estimation methods are often used in the review of new chemicals that have yet to be
manufactured or used at the time of the review.  Estimation methods are also used
during the assessment of existing chemicals under conditions that have not been
studied.  To estimate releases or exposures, the CEB engineer must either use an
analogy (i.e., apply data on similar chemicals used in similar circumstances) or use
modeling techniques based on physical parameters such as vapor pressure or
solubifity in water.  At times, the CEB engineer also must evaluate the reasonableness
of reported data.
     Several standardized  methods are available for estimating environmental releases
and workplace  exposures  under various  conditions.  Use of these methods provides
consistency in the review of a variety of chemical substances. This manual describes
these methods and provides values  for key parameters necessary for their use. CEB
engineers and support contractors developed  many of these estimating techniques
and parameters using the  best available  information,  These methods are periodically
updated as new information becomes available.
     The formulae presented in this  manual are intended for use when better
information is not available.  Conceptually, these formulae  provide assessments of
"typical case" and "reasonable  worst case" scenarios. In the absence of reliable
information, the "reasonable worst case* calculations should be used. If controls are
in use or will be used, the "reasonable worst case* estimates should be revised to
provide credit for the estimated effect of  the controls.

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     A "reasonable worst case" represents conditions that may affect worker exposure
during the operation of a process or performance of a certain task by trained workers,
For example, it is reasonable to expect that a trained worker will occasionally spill a
chemical, or that limited  ventilation conditions will exist during bagging of powders.
The intent of the formuiae, however, is not to represent such  extraordinary
occurrences as a worker failing into a chemical tank, though such events can occur.
     Although the actual exposures and releases may  be considerably less than levels
derived from "reasonable worst case" scenarios, these estimates define an outer
bound to the potential for exposures and releases. This outer bound becomes an
important factor in the risk assessment of many chemicals. If the "reasonable worst
case" exposures lead to little or no concerns for risks to a substance, it may be
possible to drop the substance from further review. This will allow resources to be
focused on better characterization of other chemicals.  If exposures estimated for the
worst case scenario are of concern, the engineer must reevaluate the parameters
used to develop the scenario and determine how representative they are of the
majority of situations.
     The engineer should always attempt to obtain release and exposure monitoring
data for the substance under review or any substance with similar properties. If such
data more accurately represent the substance and the exposure and release scenarios
under review than "reasonable worst case" estimates, then they should be used in
preparing the assessment.

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H.    REVIEW PROCESSES
    CEB engineers routinely review chemicals as part of three structured processes:
1} new chemical review, 2) existing chemica! review, and 3) Section 313 petitions.
Less-structured reviews conducted by CEB (and not further described in this manual)
include the review of regulatory proposals and supporting  documentation developed
by other EPA program offices.  CEB engineers also may evaluate consequences of
possible chemical accidents to decide whether characteristics such as flammability or
reactivity need be considered in listing chemicals for Section 302 of EPCRA.
    A,   New Chemical Review
         The new chemical review process has two parts: 1) Premanufacture
Notification review and 2) fotlowup review.
              Under Section 5 of TSCA, companies must submit a Premanufacture
Notification (PMN) at least 90 days before the commercial production (including
import) of any  chemical that is not on the TSCA Inventory of chemicals in commerce
{"existing chemicals").  The PMN review focuses on the company's intent. The Agency
may act to restrict certain aspects of their activity by orders issued under Section 5(e)
and 5(f) of TSCA, "New Chemical Review: Process Manual" contains a full description
of the Office of Toxic Substances (OTS) process for evaluating new chemicals (USEPA
1986b).
              The PMN rule provides exemption from the reporting requirements for
several chemical categories, including  1) chemicals being test marketed, 2} chemicals
used for research and development, 3) certain polymers, 4) chemicals manufactured
in quantities of less than 1000 kilograms per year, 5} certain non-TSCA uses, and
6) chemicals considered nonisolated intermediates.
              Under 40 CFR 720.3, the PMN rule excludes from reporting chemicals
that are considered nonisolated intermediates. Based on this, OTS intends to exclude
from the PMN  requirements any chemical substance that is manufactured and
consumed in the manufacture of another substance without intentional removal from

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the process during its manufacture and use (Wong 1988). The chemical is considered
nonisolated if it is not intentionally removed from the equipment in which  it is
manufactured,  This includes the use of several reactors in a continuous  process.  The
definition does not apply if the chemical is transferred to tanks or other vessels in
which the chemical is stored after its manufacture. Mechanical or gravity transfer
through a closed system is not considered intentional removal if the chemical is not
transferred to storage or shipping containers. Volume II contains a more  complete
discussion of nonisolated intermediates (Wong 1988).
               Engineering analyses of new chemicals  for which PMNs have been
received occur in two stages:  1) an initial (screening) review of all cases, and 2} a
detailed analysis for cases where it is decided in the Initial Review that the combination
of health/ecotoxicity concerns and exposure/release estimates may require regulatory
action,
               a.   Initial Review
     [NOTE: At ihe present time, CEB is considering using a panel of engineers to prepare initial
     reports and has begun a pilot effort.]
                   During the Initial Review, the CEB engineer prepares an Initial
Review Engineering Report (IRER) for presentation at the FOCUS meeting,
     [At FOCUS, representatives of CEB, Industrial Chemistry Branch (ICB), and Regulatory impacts
     Branch (RIB) present the results of initial assessments regarding the PMN chemical, FOCUS
     occurs by day 21 of the review process (counting the date EPA receives the PMN) to cover
     groups of cases at this step in the process.  It is regularly scheduled on Mondays and Thursdays
     at 1:00 p.m.]
               In the screening stage, the CEB engineer drafts an  IRER for all cases
not dropped at the CRSS meeting (see Appendix A for a  sample IRER),
     [CRSS stands for Chemical Review Search Strategy,  This is a meeting of chemists from ICB to
     determine chemical identity, physical properties, and other Information. CRSS can terminate the
     review of polymers found to have high molecular weight without certain reactive end groups and
     with negligible water solubility,]
The draft IRER forms the basis for CEB's presentation  on exposure/release at
FOCUS.  The CEB engineer has access to the Initial Review Chemistry Report (IRCR).

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A brief description of health and ecotoxicity concerns identified by the Structure Activity
Team (SAT) is also available.
     (SAT meets three days prior to FOCUS. It evaluates the potential hazard of the PMN based on
     readily available data on analogues or information submitted with the PMN.]
The CEB engineer must use these resources to prepare the IRER, The CRSS
provides reaction pathways and estimates of properties. SAT results provide some
idea of the extent to which the CEB engineer should concentrate on exposure or
release (or on an impurity in the PMN) when doing the initial assessment,  A complete
assessment is expected despite SAT outcome, however.
                  The CEB  engineer should spend two to four hours reviewing the
PMN and preparing a draft IRER.  Resources on hand should be used, including
reviews of past cases noted in the CRSS report,  reference texts, standard scenarios
developed for specific end uses, Agency documents (e.g., Development Documents
for Effluent Guidelines), and National Institute for Occupational Safety and Health
(NIOSH) documents  on workplace exposure. The engineer should contact the PMN
submitter to resolve any questions, Any such contact must be cleared with the
Program Manager (PM) and all information documented for the file,
     [The Program Manager is a member of the New Chemicals Branch (NCB) of the Chemical Conlrol
     Division (CCD) and is responsible for all policy and regulatory matters on a case. PMs are
     assigned when the PMN is received.]
Generally, there is insufficient time before FOCUS to search databases, periodical
literature, or patents to obtain information to improve the assessment.  CEB engineers
develop special expertise in one or more industrial categories and assignments are
made to take advantage of this  expertise,
                   A panel of two or three CEB engineers and industrial hygienists
reviews the completed  IRER for completeness, accuracy of estimates, and
reasonableness of assumptions. The release estimates are provided to the Exposure
Assessment Branch  (EAB) for use in estimating environmental concentrations. One
panel member presents the engineering assessment to the decision makers at
FOCUS.

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                  The FOCUS Representative informs the CEB engineer of FOCUS
results.  If the case is dropped at this point, the CEB engineer completes the IRER.
This involves making any corrections or additions directed by the Focus
Representative and filing the report within two weeks. The IRER is completed in the
same manner when cases go to Follow-up for analysis of uses other than those
intended by the submitter (see Section H.B),
                  Cases may be subject to  analysis based on either total exposure
(exposure-based cases) or risk (Standard Review),  Exposure-based cases are
non-polymeric PMN chemicals with production volumes of 100,000 kg or greater,
These cases must meet at least one finding of worker exposure, environmental
release, or  consumer exposure. PMN chemicals not meeting these findings are
dropped at FOCUS. Worker exposure findings are based on the overall exposure (the
total number of workers with routine  dermal exposure or inhalation exposure during
manufacture,  processing and use),  EAB makes the findings on consumer exposure
and environmental releases.
              b.    Detailed Analysis
                   In risk-based cases, a risk assessment team is formed of the
appropriate disciplines. Teams usually consist of an engineer, a chemist,  an
economist, 'lexicologists, environmental fate assessors, a Technical Integrator (T!), and
the PM.  The CEB engineer generally must analyze exposures or releases in more
detail and respond to specific questions raised by the Tl.  The Tl is responsible for
overseeing all technical aspects of the case to make a risk determination.
                  Three to four weeks are allotted for CEB's detailed analyses. The
CEB engineer prepares a draft report that is due before the Mid-Course Meeting, The
Section Chief reviews the report prior to submittal.  CEB's report is consolidated into
an Economics and Technology Division (ETD) report. See Appendix B for a
description of the ETD report.
     [Mid-Course Meeting is held by day 45 of the process.  Its purpose is fo Inform revi&wers of each
     others' findings and arrive a! a consensus on the overall assessment.]

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cases may be dropped after this meeting.  If the Tl recommends dropping the case, it
will be presented at CCD DISPO.
     /CCD DISPO considers 1) cases that have been reviewed' in detail and are recommended to be
     dropped, and 2) cases for which limited reviews have been conducted to decide whether more
     detailed analyses are necessary.  It is regularly scheduled for Monday and Thursday aterrtoons,
     Again, chemist^1, health/ecotoxiciP/, and exposure/release estimates are presented to a
     decision-maker from NCB,}
                   A subsequent draft of the engineering report, also reviewed by the
Section Chief, forms the basis for CEB's presentation at the ETD DtSPO,  ETD DISPO
is regularly scheduled on Wednesdays at 3 p.m. At ETD DiSPO the CEB engineer
presents ail findings on exposure/release to ETD management and the ETD Division
Director,  After ETD DISPO, the engineer files a completed report. The final step in the
review process is the Division Director's meeting.
     [Division Directors meet each week. They review all cases for which regulatory actions are
     recommended, with the Director of CCD determining ultimate recommendations for case
     disposition. The engineer on the case should attend.  Detailed analyses also will have been
     prepared on health and ecotoxicity, environmental fate, consumer exposure, and economic
     considerations, as needed, and are presented at this meeting.}
               In completing a more thorough analysis, the CEB engineer should
research literature on specific end uses. This is often the most difficult area for which
to quantify exposure and release. The engineer also must search databases for
exposure data on analogues, it is especially important that the CEB engineer make
use of information gathered by the chemist and economist (also members of the
assessment team),
                   A written, fully-referenced report is prepared as support for
possible regulatory actions.  In the event the Division Directors decide that regulatory
controls are needed, the CEB engineer identifies potential control alternatives  and
participates as needed in drafting or reviewing orders under Section 5 of TSCA. Such
orders require the submitter  to control exposure or release or to test the compound.
The CEB engineer also must participate in meetings with the submitter of a PMN, at
the request of the Program Manager.

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                  It is the policy of CEB that engineers inform PIVIN submitters of
their findings regarding exposure or release and the basis for those  findings. This
helps ensure that faulty assumptions are not used and that the submitter has an
opportunity to provide more data or information to clear up any discrepancies. During
detailed analysis of a case (and before ETD DtSPO), the CEB engineer should not
hesitate to check assumptions with the submitter.
         2,
              During the PMN review process, the Agency may identify concerns for
the chemical under conditions not covered by the PMN.  The purpose of Foliow-up is
to decide whether Significant New Use Rules (SNURs) or Section 8 reporting rules are
needed to control exposure or release if 1) a chemical is manufactured rather than
imported; 2) a chemical is manufactured by another company, at another site, by
another process, or in larger volume; or 3) uses other that those intended  by the
submitter could lead  to increased exposure or release.  PMNs reviewed in  Follow-up
include those subject to regulatory controls for the intended use, and those not thus
controlled but presenting  potential health/ecotoxicity hazards if used differently,
              The Follow-up consists of an ETD Use Analysis, which occurs in three
steps:
         Identification  of possible uses for the PMN.
         An assessment of promising uses,  conditions of  use, and the volume of
         PMN that could be so used.
         An evaluation of exposures and releases for these uses.
              An ETD chemist, economist, and engineer are assigned to each case.
The chemist and economist are responsible for developing information on the potential
uses which  are assessed in more detail by the economist.
              The engineer prepares estimates of exposure or environmental release
for the new  uses with the highest probability and completes a written report that is filed
after review by the Section  Chief (usually within one week),

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              Other aspects of Follow-up include a Toxicity Validation review by
HERD (usually before a case is referred to ETD Use Analysis) and preparation of a
proposed rule (if needed) by CCD,  The CEB engineer may be called on to contribute
to the proposed  rule or to review public comments on the proposal.
              Although there is little activity on individual Follow-up cases, many
SNURs are being prepared based on the TSCA Section 5 orders. These rules are
being promulgated under the "Generic SNUR," a lengthy rule with lists of requirements
such as control technologies,  personal protective equipment, and disposal restrictions.
An individual  case or rule would be  promulgated under the Generic SNUR by listing
only the relevant requirements.
     B.   .Existing	Chemical Review Process
         Under  Section 6 of TSCA, OTS selects chemicals and evaluates the need to
control aspects of their manufacture, processing, use, distribution in commerce, or
disposal, OTS may refer chemicals reviewed in the existing chemicals program to
other Federal agencies for action under TSCA Section 9.  It also may regulate the
existing chemicals under TSCA Section 4 (testing for toxicity), TSCA Section  5 (SNUR
for other uses), or TSCA Section 8  (reporting rules), or refer them for action  under
other EPA authorities.
         Typically an existing chemical review has 3  phases: 1) risk characterization,
2) detailed risk assessment, and 3)  risk management  and implementation.  Once
assigned to a particular chemical, the CEB engineer is typically responsible for work
on it throughout  the process.  This  process may require several years to complete,
although there are significant variations with individual cases. The ETD existing
chemical coordinators, section chiefs from each branch, manage the existing chemical
activities.
         Currently, the existing chemicals review process  is being redefined. The
current process  is based on the 3 phases mentioned above.  The first phase is called
RM 1 short for Risk Management Phase 1. RM 1  is a 12 to 13 week review of a .
chemical based  loosely on the PMN process.  In this  process there is a chemistry

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review, a market study, an engineering assessment, a fate assessment, and a health
assessment all done in the first 7 weeks of the process. Approximately, 100 hours of
total OTS staff effort is expected to be expended on a typical RM 1 chemical case.
The CEB engineer will use readily availabte sources of information to determine the
populations exposed, the occupational exposures and the environmental releases,
The level of CEB effort is in the range of 10 -15 total hours per RM 1 case.
         Over the next 3-4 weeks the lead ECAD person on the case would perform
a cursory risk assessment and recommend several options to control the risks. This
ECAD document is called a chemical's dossier. The engineer on the case will review
the dossier for technical accuracy and reasonableness of the proposed control
options. After the dossier has finished review the case is presented at a decision
meeting called the RM-1 meeting. At this meeting the case is discussed and final
recommendations are agreed to by the division directors.  Decisions from this meeting
include: 1) drop the case as there ts no unreasonable risk or that the existing risks are
being dealt with by another agency (referral), 2) gathering more data under the RM 1
process, 3} putting the chemical into RM 2 or RM 3, or, 4) non-regulatory options such
as writing concern letters to the companies or an informal referral of the chemical case
to other agencies or organizations such as OSHA, NJDSH, CPSC, ACGH-J, and  FDA.
         The second phase  of the existing chemical process is RM 2. This phase is
currently being redefined to better match with the division director's needs on pollution
prevention, toxic use reduction, and international activities. This phase is a type of a
risk assessment phase for cases which OTS  may want to regulate under TCSA.
Although there is a risk assessment performed during the  RM 1 process rt is very
cursory and it is not of sufficient quality to regulate under the "will present" finding
needed for section 6 regulations. However, the RM 1 risk assessment focuses on the
highest risks to see whether they are "unreasonable",
         CEB's role during RM 2 is to evaluate the potential for worker exposures or
environmental releases associated with manufacture, processing, use, or disposal of
the chemical. Tasks to be performed by the engineer may include: 1) gathering and
reviewing al! available literature information on the chemical including TRI data, NIOSH

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and OSHA data and data from other offices of EPA; 2} contacting manufacturers,
processors,  or users and other sources for unpublished information; 3) characterizing
the releases and exposures expected in industry and the controls typically used; 4)
developing estimates of the populations exposed and the duration, frequency, and
levels of releases and exposures (where insufficient data exists). This assessment
should characterize the range and the central tendency of the available data or  provide
estimates  in  the absence of data.  The uncertainities in the presented information
should be discussed; 5) identifying monitoring techniques for EED to validate and
providing  input on the data's quality; and 6} recommending exposure or release
scenarios  that could be considered for additional monitoring studies.  The actual tasks
the engineer preforms on a given case may vary a great deal from the list above.
          The last phase of the existing chemicals  review process is called RM 3. This
is the risk  management and implementation phase. In RM 3 the regulatory and non-
regulatory options are selected to control unreasonable risks posed  by a chemical and
they are implemented.  The CCD lead person  manages these activities drawing
support from the different branches in OTS as needed.  CEB support includes refining
the exposure, release, and control technology assessments as needed to support the
different regulatory options and responding to comments generated  by proposed rules
and advisories.  Any changes or new information may impact on RIB's support
documents.
          Bisk management requires the identification of feasible alternatives available
to reduce  the risks associated with production, use, or disposal of a chemical.  This
includes a consideration of substitutesmaterials and an economic assessment of the
control alternatives. The tasks assigned to CEB include: 1) identifying potential control
schemes to  limit exposures and releases including engineering controls, administrative
controls, and personal protective equipment.  The  use of pollution prevention alter-
natives should be emphasized; 2) determining the  effectiveness of the control alter-
natives and  estimating the potential exposures after their application; 3) estimating the
operating  and capital costs of each control alternative; and 4} assessing the impact of
substitutes'  use on industrial processes.

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                                                       issued: February 28, 1991
                                                       Revised:
                                                       Page No.:  2-10
         Section 313 Petitions
         Section 313 of EPCRA requires annual reporting of releases for over 300
listed chemicals and chemical categories.  The TRI database, which has all reported
information, is a valuable source of data for the engineer in existing chemical cases
and PMN reviews.
         Under  Section 313 of EPCRA, EPA may be petitioned to add chemicals to or
delist chemicals from the list of chemicals subject to TRI reporting. For chemicals
already on the list, the release information reported in the previous year is reviewed,
For chemicals to be added, data must be gathered from many disparate sources.
Anyone can petition EPA to add a chemical to or remove  a chemical from the list.
EPA has  180  days either to deny a petition or take the initial rulemaking steps to
change the list
         In the case of deleting a listed chemical, the engineer's role in petition review
is to review and evaluate all release data in the database for the previous reporting
years.  The basis of the engineer's report is  a printout of release data reported by
each facility, grouped by Standard Industrial Classification (SIC) Code (See Appendix
D for sample  TRI data).  The engineer must  evaluate the reasonableness of reported
data, which are after all, estimates. Evaluation includes comparing the releases of
similar facilities, independently estimating a release based on such parameters as
known production volume  of a facility and published emission factors, and contacting
the facility to  discuss the data upon which the release estimate was based.
         In the case of a  petition to add a chemical to the list, the engineer must
develop an assessment based on published data, contact with manufacturers, and
various estimation methods. The economist's assessment of markets for the chemica!
is most important in beginning this work.
         Petition review draws on a team representing all technical disciplines within
OTS.  Other EPA program offices  participate as well. If the Assistant Administrator
decides on a rutemaking, the engineer participates in preparing a proposed rule,
evaluating public comments on the proposal, and completing the rule.

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                                                      Issued:  February 28, 1991
                                                      Revised:
                                                      Page No,: 3-1
ill.  APPROACHES AND DATA SOURCES FQR ASSESSMENT
    A.   Aggma,chgs
         Ideally, the CEB engineer would use information specific to the chemical
under consideration in all evaluations. This ideal may be possible in longer term
analyses of existing chemicals where existing data can be identified or monitoring can
be conducted.  However, data on environmental releases and workplace exposures
almost never exist for PMN chemicals.  These data also may  not exist or be readily
accessible for many end uses of an existing chemical.  The engineer therefore may
have to make preliminary estimates to decide whether further analysis is warranted.
         When data are not available for the specific chemical (e.g., monitoring data
at onty one potential use site under one set of conditions), exposure or release may
be estimated based on analogy to similar chemicals with similar physical characteris-
tics that are  similarly handled. Great care must be used in drawing such an analogy,
and the results should be presented recognizing the uncertainties in the data used and
any assumptions made.
         The engineer must determine the process characteristics of operations
involving the chemical,  as process details chosen  by manufacturers or users of
chemicals directly affect exposure or release. For example, often the choice to use a
given reactor or a solvent cleanup is based solely on the existence of the necessary
equipment (i.e, the particular reactor is available or an existing solvent recovery system
at the site makes solvent use feasible).  Engineering controls, personal protective
equipment, batch sizes, reactor types,  and many other factors will vary even for
chemicals in the same  class.
          For PMN chemicals, where the single (usually) manufacturer is known, exact
information (e.g., number of sites,  number of ¥/orkers, days per year, activities) may
be available and should be used.  However, these plans may not be final and may
change. In addition, where there are multiple use sftes,  conditions can be expected to
vary greatly  and the identify of users is often not revealed (if known).  The engineer
must try to accommodate these variations by estimating a range of exposures or

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                                                      Issued: February 28, 1991
                                                      Revised:
                                                      Page No,:  3-2
releases (e.g., reporting the range, not just the mean, of measured airborne
concentrations of a material).
         Where information specific to the manufacturers, processors, or users of a
chemical is not available, the engineer should use a "reasonable worst case" analysis
to arrive at an estimate.  For example, genera! ventilation rates in industry range from
a low of 500 ft3/min to over 10,000 ft3/min, with a typical value of 3000 fts/min
(Clement 1982).  If no information is available on the general ventilation rates of the
users (individually or as a group), a "reasonable worst case" assumption  is thai the
rate could be as low as 500 ft3/min.
         The reasonable worst case approach is adopted for PMN chemicals in
particular to cover the range of possibilities for the future use of the chemical,  If these
conditions do not pose an unreasonable risk, then concerns for the chemical may be
resolved.  Careful consideration must be given to all aspects of the case  to ensure
that the assessment is reasonable.  For example, exposure or release may already be
controlled due to OSHA or  EPA requirements for associated chemicals, or materials
may be corrosive so that workers wear gloves of necessity, or the industry in question
may be known to use local exhaust (rather than just general ventilation) to control
known hazards.
         It is of fundamental importance to establish the circumstances of exposure
or release (e.g.,  daily handling  of large quantities of a powder material).   Estimated
levels of exposure can be misrepresented unless firmly based on an understanding of
the operations, work practices, controls, and other circumstances involved in the
manufacture or use of the chemical.
         End use scenarios also must be developed through an understanding of the
operations involved in the use of a chemical.  These scenarios  are best constructed by
considering the principal business of the user. For example,  based on the number
and range  of automobiles built at an average facility and the amount of primer applied
per car, the engineer could estimate the amount of a pigment in the primer used per
site, the number of sites at which it could be used, and the number of workers
potentially involved (the business of the user is building cars, not using pigment).

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                                                      Issued:  February 28, 1991
                                                      Revised:
                                                      Page No.: 3-3
         Section IV presents models that should be used to estimate levels of worker
exposure in the absence of data on the chemical or on analogues.  These models
require judgment by the engineer in choosing parameters to fit each case. Section V
presents standard approaches for estimating water release for basic operations often
found in manufacture. Section V! presents standard approaches for estimating
releases to air.  Section VII presents information on controls that may be used to
reduce release to both water and air.
     B,   Data
         There are many resources available to the engineer besides the information
provided by the PMN submitter or other direct industry sources.  Appendix E identified
ORD, OTS, CEB, and OAQPS documents for different processes and chemicals.  Six
standard sources should always be checked for relevant process and release infor-
mation.
         Effluent Guideline Series.  This source contains information on the release of
         many pollutants to wastewater for industries that represent major sources of
         wastewater release. See  Volume II for a more complete list of the guidelines
         (CEB n.d.).
         .NewJjQurce Performance Standards (NSPS). This  source contains air
         release limitations that apply to new sources in 58 industries.   Many
         standards involve particulates or VOCs that may be useful in determining
         reasonable releases for constituents of the release.  Background documents
         prepared in support of the New Source Performance Standards are most
         helpful A  listing of the New Source Performance Standards is contained in
         Appendix E.
         Industrial Process Profiles for Environmental  Use QPPEU).  This source
         contains detailed process flow diagrams including input materials, process
         conditions, and release estimates for 29 broad industries. A separate
         volume addresses each industry, and some industries (e.g., plastics and

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                                                      Issued:  February 28, 1991
                                                      Revised:
                                                      Page No.: 3-4
         resins) contain over 20 specific process flow sheets and 60 process
         descriptions,  A listing of the IPPEU's is contained in Appendix E.
         Kirk-Othmer Encyclopedia gf Chemical Technology.  This source contains
         detailed  and well documented  information on almost every type of chemical
         process. The bibliography after each section represents an excellent source
         of additional information. The  author of each section represents an expert in
         the fieid who is typically knowledgeable of current trends in the industry,
         Compilation of Air Pollutant Emission Factors. AP-42. This source contains
         process descriptions, emission factor estimates, and control information on
         more than 120 processes. Emission factors are for the criteria  pollutants.
         Factors  for total particulates or VOC can be used with composition
         information to prepare rough estimates of releases from similar processes.
         Sections on release from the storage and transfer of organic liquids are
         particularly useful in calculating release for CEB assessments.
         Past PMN cases.  Many PMNs involve similar types of chemicals and similar
         processes. Past PMNs therefore represent an excellent source of informa-
         tion on methodologies that may be used to calculate worker exposure and
         environmental release.
         Title IJLSection J13JBMeasjJlejDortJn^                     These  reports
         contain  brief descriptions of the industry, identify  potential release points,
         and model calculations for estimating releases. A listing of these guidance
         documents is contained  in Appendix E,
         In addition, there are standard sources that the engineer should always
check for occupational exposure information:
         NIQS.H Health Hazard Evaluations (HHEsj  and Industry-Wide Surveys
         jQWSjj)-  These sources contain well-documented occupational exposure
         measurements. They generally also contain process and job descriptions,
         OSHA NatimM^iiJIJl^irnpliDfl-Results.  This source contains occupational
         exposure  measurements of approximately 600 chemicals from 1979 to.
         present. Summaries are in CEB files.

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                                                      Issued: February 28, 1991
                                                      Revised:
                                                      Page No.:  3-5
         NIOSH National Occupational	Exposure ...Survey	(NOES). This source
         contains estimates of the number of workers exposed to many existing
         chemicals.  It also contains a product database giving the concentration of
         the chemical in many product formulas.
Besides these sources, Appendix E contains a list of process-specific reports that
should be consulted when applicable.
         Volume II of the manual contains copies of additional reports that may be
useful in the preparation of release or exposure assessments. These reports are
unpublished contractor reports done for CEB or published  reports that  were not widely
distributed.  A description of the documents follows,
         CEB Research Project:  Effluent Guidelines Information  (Parts A and Bj.
         This document contains information that may be  used to estimate release of
         pollutants to wastewater from tank truck cleaning operations. It also
         provides a description of the contents of development documents produced
         by the Office of Water.
         Carbon Adsorption Report.  This document provides information on the use
         of carbon adsorption systems,  chemicals treated by carbon adsorption,
         occupational exposure to spent carbon, and the  environmental impact of
         carbon adsorption.
         Generic Engineering Assessment - Spray Coating:  Occupational  Exposure
         an,d,.EnyirQnmienial. Release.  This document contains generic exposure  and
         environmental release scenarios for various spray painting operations.  It
         contains specific information on automotive finishing and refinishing, metal
         and wood furniture finishing, large appliance finishing, non-autornotive
         transportation finishing, and heavy machinery finishing,
         CEB Research Project:__Engjnggring Standards.  This document contains a
         listing  of organizations that voluntarily develop standards that are of interest
         to CEB.  it also provides descriptions of the standards or recommended
         practices suggested by each organization.

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                                              Issued:  February 28, 1991
                                              Revised:
                                              Page No.: 3-6
generic Engineering Assessment - LeatheLDyjng:  Occupational
and Environmental Release.  This document contains generic exposure and
release scenarios for leather dying operations.  It also provides specific
information on the weighing and transfer of smal! quantities of dyes.
.CEB Research Project:  Industrial Hazardous Wj§it. incineration. This
document describes methods of incineration, types of incineration devices
and expected efficiencies, air emission estimation,  cost estimation, Federal
regulations, and occupational exposure.
PoJyetectrolytes. This document describes how polyelectrolytes are used
and how they are removed from wastewater. It also provides a method for
estimating release of polyelectrolytes to water.
Drilling _FMfe=:=&wirQjinigMal Release Analysis. This document describes
the types of waste fluids produced from off-shore and land-based drilling
operations.  It also provides  information on the types of chemicals that are
contained in drilling fluids and provides methods for estimating their release
to all media.
Information on the loading and Unloading of Chemicals under Nitrogen
Blanket,  This document provides typical workplace concentration levels of
three chemicals during unloading and loading under nitrogen blanket.   It
also describes general procedures for loading and unloading chemicals
under nitrogen  blanket.
Particulates in the Workplace.  This document compiles data on typical
paniculate concentration and size listed by industry segment and worker
activity.
Strategy for Recommending  Respirators for CgntroljgfJExggguiggJo
.Substances Undergoing PremajTyfajctuj^J3evi.ew. The document provides
information to be used to identify types of alternative respiratory protection
when limited  information is available on a PMN  substance.  It includes tables
listing the different types of respirators, their assigned protection factor
levels,  and the capabilities and limitations associated with each.

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                                                       Issued; February 28, 1991
                                                       Revised:
                                                       Page No.:  3-7
         Use of Oil Separators .in Drum Reconditioning and Transportation
         Vessel-Cleaning Facilities.  This document profiles the drum reconditioning
         and transportation vessel-cleaning industry and characterizes the waste
         streams generated and wastewater treatment devices employed in the
         industry.  It describes oil separation processes and presents estimates of oil
         separator effectiveness,
         Cost of Selected Engineering Controls.  This document presents cost data
         for engineering controls for five activities.  These activities are quality control
         sampling, drumming of a liquid, bagging of a solid, reactor process vent,
         and open tank operations.
         industrial Process Profiles to Support PM.N Review:  Metal Treatment
         Chemicals. This document provides descriptions of many types of metal
         treatment operations and the chemicals used in each operation.  It also
         contains  information on occupational exposure and environmental releases
         associated with metal treatment operations.  (A listing of other Industrial
         Process Profiles to Support PMN Review is contained in Appendix E).
Figure 3-1 contains a matrix of the references contained in Volume II and the types of
information contained in each.
     Volume 111 of this manual contains descriptions of the databases that may be
accessed for specific information.  Figure 3-2 contains a matrix of these databases
and the types of information that  may be accessed.

-------



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                                                       Issued:  February 28, 1991
                                                       Revised:
                                                       Page No.: 4-1
IV. MODELING WORKPLACE EXPOSURE
     CEB has developed standard approaches for estimating exposure levels to
workers via the inhalation and dermal routes and for assessing the effectiveness of
controls, including ventilation, respirators, and gloves.  In the absence of represen-
tative data, CEB engineers should use these approaches to quantify worker expo-
sures.
     A.   Estimating Inhalation Exposures
         The amount of substance inhaled by a worker is a function of many
variables including the airborne concentration of the substance, the amount of time
spent in an atmosphere containing the substance, the breathing rate of the worker, the
worker activity or job performed, the physical and chemical properties of the sub-
stance, the temperature changes,  seasonal changes and the effectiveness of engi-
neering controls or  personal protective equipment in protecting the worker.  In
assessing the potential for worker exposures at multiple processing and use sites, the
controls used at any or all the sites may not be known.  Thus, CEB engineers must
estimate reasonable worst case exposures representing sites where no controls are
used.  If information is  available about a particular site or general industry practices,
the engineer atso may  estimate exposures assuming an effectiveness for the expected
control.
         This section describes the assessment  of occupational exposure in the
absence of respirators  and engineering controls.  Sections IV.C and tV.D discuss the
effects of respirators and engineering controls, respectively, in reducing worker
exposure.
          1-   Genera! Approach
              As stated previously, inhalation exposure is a function of many factors
including airborne concentration, duration of exposure, inhalation rate, and effective-
ness of engineering controls and personal protective equipment. Neglecting any use
of controls or personal protective  equipment to reduce the airborne concentration, the

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                                                       Issued: February 28S 1991
                                                       Revised:
                                                       Page No,:  4-2
amount of substance available for inhalation is calculated in units of mg/day as:
                                   / = Cn bh                       Equation 4-1

where:   \     =    Daily inhalation exposure, mg/day
         Cm  =    Airborne concentration of substance, mg/rn3
         b    =    Inhalation rate, rn3/hr
         h    =    Duration,  hr/day
Determination of inhalation rate and duration of exposure is generally straightforward,
and is discussed in the following paragraphs,  Determination of airborne concentration
can be difficult, and is discussed in detail in Section IV.A.2.
     With increased physical activity, inhalation rate increases. The typical worker
breathes about 10 m3 of air in 8 hours, or 1.25 m3/hr (NIOSH 1976). This value is
slightly above the volumetric flowrate for light work (NfOSH 1976).  During the
workday, the volumetric flowrate at any given instant may vary widely as a function of
the type of work being performed.  Inhalation rates range from about 0.56 m3/hr
during rest periods to 7.9 m3/hr during the maximum work, as shown in Table 4-1,

                          TABLE 4-1.  INHALATION RATES


Activity
Rest
Light work
Medium work
Hed, heavy work
Heavy work
Maximum work
Minute volume
air flow
rates
myhr
0.56
1.18
1.75
2.63
3.6
7.9
Source: NIOSH 1976
     The duration of exposure can only be estimated on a case-by-case basis through
knowledge of the activities that may lead to exposure.  This information can be
obtained from persons knowledgeable about the process or from descriptions of
similar operations. Airborne concentrations (Permissible Exposure  Levels [PELs]) or

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                                                      Issued:  February 28, 1991
                                                      Revised:
                                                      Page No,:  4-3
measured data are often expressed as an 8-hr Time-Weighted Average (TWA),  When
using an 8-hr TWA for purposes of estimating exposure, the actual duration of
exposure is not used to calculate the exposure,  A TWA value implies that exposure
may be high for short periods of time as long as those periods are compensated by
periods of lower exposure and the average exposure over 8 hours does not exceed
the TWA.  The maximum daily exposure is the total amount of substance to which the
worker can be exposed per 8-hr shift whether the exposures are for short duration at
high concentrations or long duration at low concentrations. It is calculated using a
duration of 8  hr/day.
     If the inhalation rate on average is 1.25  m3/hr, the equation for calculating the
amount of substance available for inhalation  becomes:
                                 ! =  1.25/1 Cm                       Equation 4-2
When Cm is estimated as an 8-hr TWA concentration, the duration of exposure is
assumed to be 8 hr/day and the equation reduces to:
                                   I * 10Cm                        Equation 4-3
The remainder of this section  discusses methods for estimating airborne
concentrations for use in Equations 4-1, 4-2, or 4-3.
         2.
              Worker inhalation exposure is best determined using personal
monitoring measurements for workers performing the job under study while being
exposed to "typical" pollutant levels.  Section 111 discusses some sources of monitoring
data. Examples of chemicals for which the engineering assessments have been
based on industrial hygiene monitoring data include butadiene, acrylamide, and
chlorinated solvents.
              Since monitoring data are seldom available for PMN chemicals, CEB
engineers usually rely on other methods to assess worker exposures. These methods
are also used in the analysis of existing chemicals for which no monitoring data exist
or when available monitoring data are not applicable to a particular exposure scenario.

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                                                       Issued:  February 28, 1991
                                                       Revised:
                                                       Page No.: 4-4
Predictions of the expected airborne concentration of a substance may be based on
monitoring data for analogous substances, OSHA PEL'S for substances present  in the
workplace, and mass balance models.
              a.   Using  Monitoring Data
                  When  monitoring data on occupational exposure are available, the
utility of the data should be evaluated following the process established for CEB  that is
described in "Guidelines for Statistical Analysis of Occupational Exposure Data" (PEI
1989},  The quality of the exposure data that CEB assesses varies from poorly
characterized,  summary data to well-characterized sets of individual data points.   In
almost all instances, the quantity of available data is limited.  The guidelines describe
the treatment of uncertainties, assumptions, and biases in the data.  With the assis-
tance of an industrial hygienist and a statistician, the CEB engineer can use the
guidelines to categorize the data and perform the statistical analysis.  Appendix F
briefly describes these guidelines.
              b.   Using  Analogous Data
                  (1)
                       The airborne concentration of vapors and particulates may be
estimated using personal monitoring measurements for analogous chemicals or
processes, In each case,  similarities must exist in physical/chemical properties of the
chemicals, nature of workplace environment, quantites of material handled, and worker
activities associated with use of the chemical.  Chapter HI discusses typical sources of
chemical-specific data, such as the OSHA Compliance Database, NIOSH industry-wide
surveys, and NIOSH  Health Hazard Evaluations (HHE's). In addition, CEB has
developed descriptive generic scenarios that include summaries of the available
monitoring data for industries that are frequently assessed.  Currently, these scenarios
cover metalworking, textile dyeing, and  spray coating.
                       Although estimates of airborne concentrations may be based
on analogous  chemicals or processes,  caution should be used when making the

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                                                      Issued:  February 28, 1991
                                                      Revised;
                                                      Page No.: 4-5
analogy.  This is a type of reality check, If the exposure calculations exceed the PEL,
Short-Term Exposure Level (STEL), or Immediately Dangerous to Ufe or Health (IDLH)
levels, then the assumptions or calculation methods should be checked for their
validity.
                       To estimate airborne concentrations for vapors from
analogous data, the following simple relationship has been derived:
                                           P X
                                C   = C ,    s                      Equation 4-4
                                 V..     V,
where:   Cvc  =   Estimated airborne concentration of the PMN chemical, pprn
         C, ,  -   Measured airborne concentration of the known chemical, ppm
         Ps,   =   Vapor pressure of PMN chemical, torr
         Pk   =   Vapor pressure of known chemical, torr
         Xs   =   Mole fraction of PMN chemical in mixture
         Xk   =   Mole fraction of known chemical in mixture
The derivation of this relationship assumes that;
         Vapor generation is driven by either evaporation from an open surface or
         the displacement  of saturated vapors from a container.
         The liquid temperatures (T) and the mass transfer coefficients (K) of the
                                 \
         PMN chemical and the known substance are simiiar.
         The workplace environments are similar: the ventilation rates (0) and mixing
         factors (k) for the workplaces in which the PMN and the known chemical are
         handled are essentially the same; the quantities of materials handled  are
         similar (for example, in an activity such as drumming, the volume of the
         container and the fill rate  for the PMN and the known are equal).
         Raou!t's  Law is valid.
                       Assuming  the ideal gas law, the airborne concentration
 expressed  on a volume basis in units of ppm [C ] can be converted  to airborne

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                                                      Issued:  February 28, 1991
                                                      Revised:
                                                      Page No,: 4-6
concentration expressed on a mass      in units of mg/m3 [Cm] using the following
equation:

                                 Cm = Cv   —                      Equation 4-5
where:   Cm  =   Airborne concentration, mg/m3
         Cv   =   Airborne concentration, ppm
         M   =   Molecular  weight of the chemical of interest, g/g-mole
         V   =   Molar volume, liter/mole (use 24,45 liter/mole at 25* C and 760
                  mm Hg)
                       For participates, the analogous data may be expressed as
the airborne concentration of a particular substance or as total solids.  To calculate the
airborne concentration, assume that the composition of the airborne parttculates is the
same as the composition of the bulk material. A ratio of the weight fractions of each
substance is used to calculate the airborne concentration of the PMN from
concentration of the known chemical,

                                Cm  = Cmk  -4                    Equation4-6
where:   C^,,,  -  Estimated airborne concentration of the PMN chemical, mg/m3
         Cm>  =  Measured airborne concentration of the known chemical, mg/m3
         Y5    =  Weight fraction of PMN chemical in mixture
         Yk    =  Weight fraction of known chemical in mixture
If the airborne concentration is measured as total solids, this equation becomes:

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                                                       Issued:  February 28, 1991
                                                       Revised:
                                                       Page No.:  4-7
                                 Cm.s =  C^ >y                      Equation 4-7
where;   C,Tj,   =  Estimated airborne concentration of the PMN chemical, mg/m3
         Cn, k   =  Measured airborne concentration of total dust, mg/rrr
         Y5"   =  Weight fraction of PMN  chemical in the solids
                       When using an analogy for particulates, the following
parameters should be judged to be similar: hygroscopicity, moisture content, density,
particle shape, particle size and distribution, and static buildup potential Whenever
available, the engineer should obtain particle size information for the PMN chemical.
This information may be presented in several different ways, from a complete particle
size distribution to the limited  identification  of average size or percent of particulates
above or below certain cutoff sizes.  Depending on the type of data submitted, the
p article size information may be used to more completely characterize the exposure to
the worker.  The data should  represent the PMN particle size distribution at the
potential exposure points.
                        If properly collected and analyzed, particle size information
may be used to identify the percent of particles in the respirabie range,  Respirable
particulates  are defined as those with an aerodynamic diameter of 3.5 ^m or less,
These particles are expected to reach the  alveolated gas exchange portions of the
human respiratory system where they may be absorbed.  Almost at! particulates that
are inhaled and are larger than the respirabie size are deposited in the upper respira-
tory tract. Those which deposit in the nasopharanx behind the nasal hairs tend to be
carried downward to the throat. Those which deposit in traecNobronchiai system are
carried upward to epiglottis. Those particles that are larger than the respirabie
particles tend to be ingested.  A CEB industrial hygienist should be consulted to
determine the appropriate type of testing protocol for particle size testing, and  to
provide guidance to the submitter.
                   (2)  Spray Coating
                        One use scenario which CEB frequently assesses is industrial
spray application of coatings.  To standardize and facilitate the engineering analysis,

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                                                       Issued: February 28, 1991
                                                       Revised:
                                                       Page No.:  4-8
CEB developed a report entitled "Generic Engineering Assessment Spray Coating"
(CEB 19878) that describes several generic spray coating scenarios. The report,
which is included in Volume II, is organized according to the industry of application:
automotive finishing and refinishing, wood and metal furniture finishing,  large appliance
finishing, railroad car finishing, light aircraft finishing, and heavy machinery finishing.
For each industry, a matrix provides information that can be used to estimate typical
usage rate of coating, number of use sites, numbers of workers exposed by activity,
duration and frequency of exposure, types of protective equipment likely to  be used,
and inhalation exposures to total mist and organic solvents,
                       Of the PMN chemicals that are intended for use in coatings,
most are nonvolatile substances used as resins, pigments, or other additives in the
coating.  Therefore, the PMN  chemical is usua!ly part of the solids, and inhalation
exposures can be estimated based on expected airborne concentrations of total mist
using Equation 4-7. Table 4-2 lists airborne concentrations of total mist categorized by
scenario.
                 TABLE 4-2.   ESTIMATED AIRBORNE  CONCENTRATIONS
                   OF TOTAL  MIST FOR SPRAY COATING  OPERATIONS
             Industry              Estimated  8-hr  TWA (mg/m3)  Total
           	Hist	
             Automotive
              -  Finishing        Not  expected  to exceed levels for
                                refinishing  operations.
              -  Refinishing      5
             Furniture
              -  Wood             0,1  to 2,5
              -  Metal            0,1  to 23.5
             Large  appliance    35
             Railroad car
             Light aircraft
             Heavy machinery    1  to 18
             Source: O'Brien 1981, CEB 1987a

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                                                       Issued:  February 28, 1991
                                                       Revised:
                                                       Page No,: 4-9
                       When no particular scenario represents the PMN use, the
OSHA PEL for particulates, not otherwise regulated, should be used to represent the
upper bound for potential exposure. Estimation of exposure based on PELs is
discussed later.
                       If the PMN is volatile, the potential airborne concentration can
be based on the airborne concentration of a known similar volatile compound.
Airborne concentration levels for a variety of known solvents are listed in the NIOSH
technical report entitled "Evaluation of Engineering Control Technology for Spray
Painting" (O'Brien 1981),  If most of the volatile portion of the coating becomes
airborne during spray application, the airborne concentration of the PMN is estimated
to be a  function of the ratio of moie fractions:

                                 CViS - CVih  -1                     Equation 4-8
                                             Mi

where:   C¥,t =  Estimated airborne concentration of the PMN chemical, ppm
         Cy_ =  Measured airborne concentration of the known chemical, ppm
         Ys    =  Weight fraction of PMN chemical in mixture
         Yi   =  Weight fraction of known chemical in mixture
                   (3)  Textile Dye Weighers
                       A description of textile dyeing operations is found in the
in-house report entitled 'The Dyeing and Printing of Textile Fibers" (Heath 1984).  This
comprehensive overview includes information on types of dyes, typical formulations of
dyes, days of operation, numbers of workers, throughput rates, and releases for both
batch and continuous dyeing operations.  Based on the report, dyes are used that
range from less than 0.001 percent to greater than 4 percent fiber active coloring
material based on the weight of the fiber (wof). The level of dye as formulated will
depend on the depth of color needed.  For example, the active coloring agent may be
1  percent of the dye solution if  used as a moderate-deep base color and 0,1  percent if

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                                                      Issued;  February 28, 1991
                                                      Revised:
                                                      Page No.: 4-10
used as a shading agent. Darker shades such as black, navy blue, and orange  may
require 5 percent or more dye as formulated.
                       A typical dyehouse employs one dye weigher per shift and
may operate 3 shifts per day over 5 to 7 days per week. Inhalation exposures to
particulates during dye weighing are expected.
                       To better assess occupational exposures to powder dyes,
EPA has conducted a study of dye weighers at 24 textile dye/print houses.  Quantities
of individual formulated dyes handled  by workers in the  study using a "scoop/shake/
pour"  method ranged from 0.001 to 54 kg/worker/shift.   On an interim basis, CEB
estimates the worst case and average dye dust concentration per weighing ratio as a
basis  for assessing workplace inhalation dust exposures. The assessment of worker
exposure to dust via the inhalation route is calculated from the following formula:
Typical Case:
    /   =  0.0314  x  % concentration, x   no, weighings/day      Equation 4-9
                       based on solids
Worst Case;
    /   =  0,170  x  % concentration   x no. weighings/day       Equation 4-10
                     based on solids
                       The percent concentration is either provided in the PMN or
other  source or may be  estimated (see Appendix C of Heath 1984).  The number of
weighings of dyestuff is an engineering judgement based on mass used per site  and
conditions of use. Table 4-3 provides typical values.

          TABLE  4-3.   TYPICAL PARAMETERS  FOR DYE WEIGHING OPERATIONS
          Type  of   No. of dye  units   No. of dyelots   No. of dyeings
         operation      per  site-day    per shift/unit	per  dyelot
        Batch               3                1,33              1-3
        Continuous           1                1                3-4
      JPrint        	 1       	_ _	_1            2-4/screen
         Source: Seath 19B4

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                                                          Issued: February 28, 1991
                                                          Revised:
                                                          Page No.:  4-11
                    (4)  Weighing and Transfers of Small Quantities ofJSojids
                        Workers who weigh or transfer chemicals similarly to those in
dye weinghing activities (i.e., similar quantities of less than 54 kg/worker/shift and
similar handling techniques of "scoop/shake/pour") are expected to be exposed to
similar levels of dust.  For example, airborne concentration levels of paper and leather
dyes have been found to be similar to levels of textile dyes (Heath 1988).  Thus, in
these instances, the equations for dye weighers can be used to estimate exposures.
                    (5)  Metal Working Operations
                        Information on the operations, numbers of workers and
activities,  and occupational exposures at machine shops and selected metalworking
operations can  be found in "Exposure to N-Nitrosodiethanolamine in Machine Shops'*
(CEB 1984b) and "Exposure to N-Nitrosodiethanolamine in Selected Metalworking
Operations" {CEB 1984c). Table 4-4 presents estimated inhalation exposures based
on NIOSH field  studies and OSHA compliance monitoring data collected for n-nitro-
sodiethanolamine (NDELA) and oil mist during the period of  1972 to 1984,
         TABLE  4-4,  ESTIHATEO  AIRBORNE CONCENTRATIONS FOR HETALHQRtCING
Type of
facil ity
Machine shops
Machine shops
Rolling mill
Contaminant
NDELA (vapor)1
Oil mist
Oil mist
Airborne concentration
arithmetic average
(range)
0.04 M9/m3
(rtondetectable to 0,08 jug/itt }
1.2 mg/m3
(0.001 to 5 mg/m3r
0.24 ing/m3
(0.18 to 0.3 mg/m5)
          * N-Nltrosodiethanolamine (NOELA)
           CAS:      1116-54-7
           HW:      110
           VP:      not available
           The upoer end of this rsnqe based On OSHA monitoring data Is
           actually 8.3 ing An' which exceeds the OSHA PEL for oil wist.  Since
           exeeedance of the PEL occurred only in a small number of Inspec-
           tions and the DSKA data ray be biased by the fact that Inspections
           are often conducted based on employees complaints aboyt the work-
           place, the DSHA PEL fcr oil trust has been used to represent the
           upper bound.
           Source;  CEB 1983b, CEB !9B4c

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                                                       Issued:  February 28, 1991
                                                       Revised:
                                                       Page No.: 4-12
                       The OSHA PEL for oil mist should be used to represent worst
case exposures for metalworking operations, Use of OSHA PEL'S as surrogates for
exposure or as upper bounds is discussed later.
                  (6)  Pjjntjng
                       In assessing inhalation exposures in the printing industry,
CEB relies on a very  limited data set. High-speed letterpress and lithographic printing
operations are expected to generate ink mist.  High-speed processes include printing
of newspaper (300 to 400  m/min) and publications (300 to 370 m/min).  Based on
two studies, occupational exposures to ink mist during printing operations range from
0,3 to 6.2 mg/mj (Gikis 1983), Occupational exposures to solvents during printing
operations are also expected.
                  (7)  lire	Manufacturing
                       Air monitoring data for occupational exposures to total
particulates are available for tire manufacturing (SIC code 3011).  From 1979 to 1980,
NIOSH conducted detailed control technology assessments of seven tire
manufacturing sites. The individual  plant reports contain air sampling  data, identify
emission sources, describe work practices, and evaluate engineering controls for
various operations such as weighing, mixing, milling, and curing.  The results of these
field  studies are summarized in the NIOSH report entitled "Control of Air Contaminants
in Tire Manufacture"  (NIOSH 1984).
                       The  NIOSH studies found that workers may be exposed to
particulates from  rubber, carbon black, process oils, vulcanizing agents, accelerators,
activators pigments,  softeners, and plasticizers. Table 4-5 gives a typical compound
for tire manufacture.

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                                                          Issued:  February 23, 1991
                                                          Revised: November 8, 1991
                                                          Pae No.:  4-13
                     TABIE 4-5.   TYP1C3UL OMPOOND OMPOSEElai
                                    TjDRE
                                                     wt %
                          Rubber                     71
                          Carbon black               is
                          Zinc oxide                  2
                          Stearic acid                1.4
                          Softener                    3 , 4
                          Antioxidant                 o . 7
                          Sulfur                      2 . 0
                          Primary accelerator        0.5
                         j>econdary accelerator      o.i
                          Source:  N10S» T9S4
                         Workers may be exposed to dusts during transfers, weighing,
and mixing of raw materials.  During milling, extrusion, calendering, and curing, workers
may be exposed to fumes that are emitted from the hot milled rubber.  During tire
repair, workers are potentially exposed to rubber panicles from grinding. Exposures are
generally higher in the earlier stages of the  manufacturing process when dry ingredients
are handled than in the latter stages that involve the  building and handling of cured
product. The NIOSH report describes the operations and worker activities in detail.
                         PMN chemicals are frequently nonvolatile substances used as
resins, pigments, or other additives in rubber compounds. Therefore, the PMN chemical
is usually pan of the solids and inhalation exposures can be estimated based on  expected
airborne concentrations of total solids  using Equation 4-7.
                        Table 4-6 lists airborne concentrations of total paniculates
categorized by worker activity based on the NIOSH field studies. In engineering
assessments for lire manufacturing, note that carbon black has an OSHA PEL of 3.5
mg/rrr. 8-hr TWA.
                        An  earlier study found that paniculate levels in compounding
and mixing are about  1 to 3 mg/nr', while those in milling, curing, and finishing are
generally less than 1 mg/nv7 (Williams  1980).  These results agree with the NIOSH data
presented in Table 4-6.

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                                                        Issued:  February 28. 1991
                                                        Revised: Novembers, 199
                                                        Page No.: 4-14
         TZSJ3EE 4-6.   SU-WKRY OF NIOSI M3OTORING DKEA FOR
              EXPOSURES  IN Tim~wtiUFMmmm QPERKTICNS  BSSED cw
                                  SEVEN
                                                      Total partlculates
                                                      range of exposures
       _ Activity _                (mg/m ) _
        Bin-filling  (emptying bags into bins)            0,6 to 4,3
        Manual weighing with LEV                         1.5 to 2.2
        Manual weighing without LEV                      2.1 to 2.5
        Mixing                                           0.08 to 1.54
        Milling with  LEV                                0.2 to  1.22
        Calendaring  (under canopy hood)                 0.07 to 0.4
        Curing  (automatic  press/general ventila-        0.1 to  0.22
        lion)                                            0,17 to 0.26
        Tire repair with LEV _ ^^
         Source;  MIOSH *984
                        If the PMN is volatile, the potential airborne  concentration can
he based on the airborne concentration of a known similar volatile compound using
Equation 4-4.
                        Worker exposure to pentane, hexane, heptane, benzene, and
toluene during tire manufacture has been studied (Van En 1980),  Since PMN  chemicals
typically are non-volatile, the solvent exposure data are not presented here.
              ,*.    Use of OSHA PEL'S
                   When neither representative monitoring data nor a generic scenario
are available to describe potential exposures to the chemical of interest, the upper boimJ
"o the airborne concentration may be estimated using OSHA PELs for  analogous
substances or substances present in the same workplace as the PMN chemical.  To
estimate the airborne concentration, the PEL is used in the same equations as those u-<>J
to calculate concentrations from measured data,
                   The most frequent use of PELs is in the estimation of airborne
concentrations of solids for operations such as spray coating or solids handling.  The
OSHA PEL for Paniculate, Not Otherwise Regulated, is  IS mg/nrl 8-hr TWA (29 CTR
1910.1000, Table Z-l-A). Data collected by OSHA and NIOSH for total dust exposure-.
have been tabulated by SIC code (Mure 1985).  A mean  exposure value was

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                                                      Issued:  February 28, 1991
                                                      Revised:
                                                      Page No.: 4-15
calculated for each SIC code.  The mean exposures support the use of 15 mg/m1 to
represent airborne concentrations of total dust in the worker's breathing zone as a
substitute for specific data.  This study has been included in Volume II.
                  The OSHA PEL is frequently used to describe exposures to oil
mists generated in operations  such  as metalworking and printing presses.  The 8-hr
TWA PEL for oil mists is 5 mg/m3 (29 CFR 1910.100, Table 2-1-A).
                  To calculate the airborne concentration of PMN from either of
these PEL's, the following variant of Equation 4-7 is used:
                                 Cn... = KC,  y.'                     Equation 4-11
where:   Cfns  =  Estimated airborne concentration of PMN substance
         KCK  =  8-hr TWA  airborne concentration of known (either paniculate, not
                  elsewhere regulated or oil),  mg/m3
         Ys'    =  Weight fraction  of PMN chemical in the solids or oil
                  To calculate the airborne concentration for vapors based on the
PEL, use Equation 4-4 substituting the PEL concentration (in pprn) for the measured
concentration.
              d,   US£-QLMajsJM3.nce Models
                  When information on analogous chemicals is not available, CEB
engineers use mass-balance or "box* models to predict airborne concentrations.
These models are most applicable for vapor and gaseous emissions because vapors
follow currents freely and are not influenced by  gravity,
                  Worker exposures can be influenced by many variables: 1)
degree of automation, 2) employee work practices, 3) equipment design, age, and
frequency of maintenance, 4)  container and closure design, 5) ventilation type and
rate, 6) employee use of protective equipment, 7) effectiveness of emission control
devices, and 8) product flammability.  These factors must be considered before
estimating worker exposure using these models. This is especially true I the default
parameters are used to represent worst and typical conditions in the workplace?.

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                                                     issued;  February 28, 1991
                                                     Revised:
                                                     Page No,;  4-16
                  One check of the models is that good design of equipment keeps
concentrations below 25 percent of the Lower Explosive Limit (LEI). A reasonable
worst case assumption should not exceed good design practice. For PMN chemicals,
however, the LEL or operating practices may not be known,
                  (1) Dimple Mathematical Model
                      The model frequently used to estimate worker exposures is
based on the mass balance of a substance in an enclosed space.  It assumes the
fol towing:
         There is perfect and instantaneous mixing of the contaminant with  incoming
         general dilution  air,
         The airborne concentration of the contaminant in the exfiltration air is the
         same as in the room.
         Only one source within the work area emits the contaminant,
The basic mass balance is expressed as:
                         dC
                       V—! = QC,  + S -
                          eft
0  * el  VC
Equation 4-12
  ,    ,   c  _  Contaminant concentration in workplace, [volume chemical/volume
                air]
         Q  =  Volumetric ventilation rate [volume/time]
         ~  _  Contaminant concentration in incoming dilution {infiltration) air
         \j  —
                [volume/volume]
         S  =  Source generation rate (volumetric) [volume/time]
         e  =  Extinction rate [time"1]
         V  =  Room volume [volume]
 The following assumptions are made to simplify the model:
             Extinction of the chemical (adsorption, absorption, or chemical
             transformation) resulting from deposition on walls and equipment,

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                                                          Issued:  February 28,  1991
                                                          Revised; November 8, 1991
                                                          Page No,:  4-17
              condensation of hot vapors, and photodegradation of chemicals is
              negligible.
              The incoming air  is contaminant-free,
              The concentration of contaminant at initial time (t=0) is negligible.
              The generation and ventilation rales are constant over time.
              Room air and ventilation air mix ideally,
              The concentration approaches the equilibrium concentration,
In its most simplified form, the model is expressed as:

                                      C,.  = £                        Equation  4-13
where:    C,_,  =  Contaminant concentration in workplace, ppm
          S   =  Source generation  rate (volumetric), cmj/h
          Q   =  Volumetric ventilation rate, cnrVb
                        If available, a known ventilation  rate for the workplace under
study is used.  Volumetric ventilation rates are conventionally represented by units of
tV/min or cfm. General ventilation rates in industry range from a tow of 500 frVmin to
over 10,000 ftj/min; a typical value is 3,000 frVmin (Clement 1982).  If the ventilation
rate is not known, a rate of 3,000 cfm (85 rrr/min) is considered typical and 500 cfm
(14.2 rrr/min) represents worst case.  For outdoor operations with only minimal structure,
the ventilation rate in cfm is estimated as 26,400 v where v is the wind speed in mph
(Clement 1982).  The average wind velocity is assumed to be 9 rnph (Clement  1982).
                        In reality, general dilution ventilation air does not  always mix
perfectly and instantaneously with contaminated room air.  Pockets of poorly mixed air
may be found in the room. Thus, a dimensionless mixing factor (k) is introduced to
describe the degree of mixing of the displaced ventilated air. Ideal mixing is represented
by a mixing factor (k) of L This mixing factor is a function of room size and locations of
the air iniet and exhaust. The ACGIH Ventilation Handbook suggests the following

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                                                          Issued:  February 28, 1991
                                                          Revised: November 8. 1991
                                                          Page No.:  4-18
 factors (ACG1H  1988):  best (0,67 to 1), good (0.5 to 0.67), fair (0.2 to 0,5), and poor
 (0. i  to 0.2).
                         In using this model, a mixing factor of 0.5 represents a typical
 case and 0.!  represents a worst case. Incorporating the mixing  factor  and assuming the
 ideal gas law, the model is expressed as:

                                     (1.7 x I05) 7  G                 i--,,i
                                                                      Equation 4-14
                                       .If   Q   k


where:    Cv,  =  Contaminant concentration in workplace, ppm
          Ta  =  Ambient temperature of the air, K
          G   =  Vapor generation rate, g/sec
          M  =  Molecular weight, g/g-mole
          Q   =  Ventilation rate, tV/min or cfm  (Note that "cfm" is a conventional unit
                 for volumetric ventilation rates)
          k   =  Mixing factor, dimensionless
          Note:  the factor 1.7 x itf in Equation 4-14  accounts for  units con%'ersion and
                 is expressed in units of:
                                             i »* i
                                  sec atm cm' fr
                                 g-rnole K min cm3

                 Equation 4-14 is the model which CEB engineers frequently use to
estimate  the airborne concentrations of contaminants in the workplace.  Use of this
model for specific scenarios will be discussed later.
                   (2)    Comp'ex	Mass Balance Models
                          The basic mass balance approach can be used to derive
models for other scenarios  (e.g.. when the infiltration air is not contaminant-free,  the con-
centration is not constant, or the initial concentration of contaminant is known).  There
are three complex mass balance models that have previously been used by CEB to

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                                                         Issued:  February 28, 1991
                                                         Revised: Novembers, 1991
                                                         Page No.: 4-19
 estimate room concentrations. These are the Multi-Chamber Chemical Exposure Model
 (MCCEM), the Consumer Products Safety Commission (CPSC) model, and the Monte
 Carlo Simulation model. They have similar mass balance approaches  to model exposures
 to chemicals,
                   The MCCEM was developed for EPA, Office of Research and
 Development  (ORD)  in Las Vegas, Nevada. MCCEM is available on diskette and
 estimates airborne concentrations in the home based on user-supplied  generation rates
 (Geomet  1989).  The  model provides default values for room size, house size, infiltration
 rales, and interzonal air flows. CEB has used this model to estimate occupational
 exposures to house painters when using latex paints containing formaldehyde-releasing
 biocides.  Further information about the model is available in Volume  III.
                         The CPSC model calculates exposure concentrations resulting
 from a continuous release of a chemical substance in an enclosed  space. This model has
 been used by CEB to  estimate exposure  to chlorinated solvents. If the release of the
 PMN chemical occurs  over a relatively short time but the worker remains in the area for
 other activities throughout the period, the mass balance equation must be solved for two
 distinct periods.  The first period is the time when the PMN chemical is released (t0)
 until the  time  the PMN chemical has ceased being released (tL). The second time period
 is after the PMN chemical has ceased being released (tj) until the  time the worker leaves
 the room (t2).  Other assumptions for the model include that the pollutant concentration
 at  the start of  the release, the outdoor pollutant concentration, and the rate of removal
 by extinction are all zero. The model also assumes that the source strength and air
changes per hour are constant over the time of interest. The model also assumes ideal
 mixing.  The general solution for  estimating room concentrations during the two time
 periods is  presented in Equation 4-15,

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                                                         Issued;  February 28, 1991
                                                         Revised:  Novembers, 1991
                                                         Page No.: 4-20
M =
                               a V
                                       £- [1  - e^'r'o^-oWi^ Equation 4- 15
                                                               l
where:    C(t)      =     Contaminant concentration in the workplace, ppm
          S  =     Source strength, crrr/hr
                   Number of air exchanges per hour for the ventilation system, hr"1'
                   Room volume, trr1
                   Time when the  pollutant is released, hr
                   Time when the  pollutant release ceases, hr
                   Time when the  worker leaves the room, hr
                          The Monte Carlo Simulation Model is a combination of a
complex mass balance mode] to estimate exposure concentrations of the chemical
substance  in an enclosed  space and a Monte Carlo analysis.  The continuous release
model estimates the concentration of a chemical substance that is released at a constant
rate over a period of time until the exposure duration ends or the source ceases to emit
a substance, whichever comes first. This mode! has  been computerized by EPA, ORD.
This model has been used to estimate room concentrations after  releases of enlorofluoro-
carhons in various scenarios such as  mobile air conditioning and refrigeration.  Assump-
tions for this model  include ihat the  pollutant concentration at  the start of the release,
the outdoor pollutant concentration,  and the rate of removal by extinction are  zero.  The
model contains a factor that accounts for nonideal mixing,  The solution of the mass
balance mode! for this model is presented in Equation 4-16.

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                                                          Issued:  February 28, 1991
                                                          Revised: November 8, 1991
                                                          Page No,: 4-21
                       C =
                             Sr.
                                         l-e
                                                                     Equation 4-16
m =
V =
C0 =
where:    C  =     Contaminant concentration in the workplace, g/m3
          S  =     Source generation rate, g/hr
                    Residence time of the  indoor air, hr
                    Mixing factor
                    Room volume, m3
                    Outdoor concentration, g/m3
          Cjn, =     Concentration in the room at the beginning,  g/m3
          t   =     Time, hr
                          The Monte Carlo analysis portion of this model consists of
three major steps. First, the CEB engineer selects a mean, standard deviation, minimum,
maximum, and  distribution type for each of the input variables in Equation 4-16. Second,
the model is executed numerous times (usually between 500 and 1000 times), each  time
wnh a unique combination of values for the input  factors.  The unique sets of inpui
factors are generated by the Monte Carlo model randomly sampling from the distribution
assigned to the  factors,  Third, the  numerous values of exposure generated from this
iteration technique are then analyzed statistically to estimate a mean, standard deviation,
minimum and maximum, and  95th percentile. The primary statistic  is the mean value for
each scenario.   This value is more appropriately referred to as the estimated likely
exposure because it is derived using a variation in  input  values.  In most cases, the
predicted 95th percentile value may be  used to represent the reasonable worst-case
exposure.  The  validity of this model is highly dependent on how well the distribution of
each input parameter is understood. Interpretations of the results must be made very
cautiously if uncertainty exists in the understanding of the input distributions,

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                                                          Issued:  February 28, 1991
                                                          Revised: November 8, 1993
                                                          Pas,; No.: 4-22
                          Other approaches
                          Other approaches that are not commonly used are included
 here for general information.  The mass balance modeling approach does no! account for
 dispersion patterns, room size, or location of the worker with respect to the source.  To
 determine the effect of worker location on inhalation exposures, data were collected
 during laboratory pilot studies and an empirical model for predicting airborne concen-
 trations during drumming was developed (MRI  1986). This model incorporates a factor
 to account for the positioning of a motionless worker in relation to the source and the
 ventilation flow direction. This distribution factor (d) represents the amount of time a
 worker .spends in from of the  fill station.  The mode! does not incorporate the effect of
 worker movement because standardization of worker movement is nearly  impossible.
 Slight movement may reduce the breathing height that may affect  concentrations. The
 model  is expressed as:
                           Cm =
                                     Q
- (100fW)S  G             Equation 4-P
where:    Cm  -  Airborne concentration,  mg/mj
          Q   =  Ventilation rate, frVmin
          d   =  Distribution factor, sec/or'
          G   =  Vapor generation rate, g/sec
The final MRI report provides the following table of default distribution factors for drum
filling operations of liquids.  One conclusion drawn from the study is that cross ventila-
tion ;iir flow produced lower exposures than rear ventilation air flow.  CEB has not used
this model to dale in preparing assessments.

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                                                     Issued: February 28, 1991
                                                     Revised:
                                                     Page No.;  4-23
               TABLE 4-7.  DEFAULT DISTRIBUTION FACTORS
Filling operations
Automated
Manual
Airflow
Side
Rear
Side
Rear
d factors (sec/m3)
MW < 100 MW > 100
0.2 0.1
0,6 0.6
0.3 0,1
3 3
         Source;  MR! 1986.
                  (4)    Modeling the Generation Rates
                        To estimate the airborne concentration of the contaminant,
the generation rate of the contaminant must be estimated. Several approaches to
calculating the generation rate have been developed.
                        Many models which CEB routinely uses to estimate the
generation rate are functions of vapor pressure of the substance or mixture. The
vapor pressure of a pure substance may be available in the literature,  ICB usually
provides estimates of vapor pressure for  PMN chemicals based on the chemical
structure.
                        if two boiling points at two different temperatures (T1t T2)
and pressures (P,,Pj) are known, the vapor pressure  at 25"  C (P25) may be calculated
as shown in equation 4-18;

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                                                       Issued: February 28, 1991
                                                       Revised;
                                                       Page No.:  4-24
                                  25
                                              ito
                               [P] = aim
where:
                               b  =
                                       (298 - 7t)
               Equation 4-18
                                    2QB(T2 - 7,)
                               [TJ = Kelvin -  K
Equation 4-16 is derived from the Clausius-Clapeyron Equation, and assumes that the
heat of vaporization,  'H^, is constant.  If the heat of vaporization and  one boiling point
(T1 at P,,) are known, the Clausius-Clapeyron equation may be used to calculate the
vapor pressure. This is presented in Equation 4-19,
                          ln\
                               25
                                      •H.
                                       m
1
                                                 298
Equation 4-19
v/here:       R     -     Universal gas constant, 8,314 J/mol "K
             ° Hm   =     Heat of vaporization, J/mol
                         For mixtures, the vapor pressure of a component {Pa in
atmospheres) may be calculated using Raoult's Law as shown in Equation 4-20:

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                                                      Issued: February 28, 1991
                                                      Revised:
                                                      Page No.:  4-25
                                  Pa = P° Xa                      Equation 4-20
where:
                      M.
               M
                8
         P *    = Vapor pressure of pure substance, atm
         X     = Mole fraction of component
         W-    = Weight percent of component
         M.    = Molecular weight of component, g/g-mole
         (3,0,1 denote components)
Raoult's Law may be too simplistic in certain circumstances because vapor/liquid
equilibria data do exist for certain binary systems. Where data exist, this should be
used instead of calculated values. For chemicals that are solid at ambient temperature
and volatilize by sublimation, standard chemical engineering techniques for estimating
physical properties are not adequate for predicting vapor pressure.
                       Transfer ....... Operations.  When liquids are transferred,
displacement of saturated vapor from the container must be considered.  If
evaporation rate is negligible in comparison to the displacement rate, the generation
rate is expressed as:

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                                                      Issued: February 28, 1991
                                                      Revised:
                                                      Page No.:  4-26

                              «    / M  V  r  P*                 !-.•„„<
                              G  = 	_                 Equation 4-21
                                     3600 Ft TL                    *
where:   G    =   Vapor generation rate, g/sec
         I    =   Saturation factor, dimensioniess
         M    =   Molecular weight, g/g-mot
         V    =   Volume of container, cm3
         r    =   Fill rate, units/hr
         P °   =   Vapor pressure of pure substance, aim
         R    =   Universal gas constant, 82.05 atm cm3/g-mol ° K
         TL   =   Liquid temperature, ° K
                       Equation 4-21 is frequently used to estimate worker
exposures during tank truck or tank car loading and drumming operations.  Summary
Table 4-11 at the end of Section 4A presents the default values generally assumed by
CEB for container volume and fil! rate. If complete saturation of the vapor space within
the vessel is assumed, the saturation factor is equal to 1.
                       This model is used to estimate losses due to vapors
generated from bulk loading of petroleum products as described in AP-42  (USEPA
1985b), Saturation factors for tank  truck loading of petroleum liquids are expected to
range from 0,5 to 1.45 (USEPA 1985b). Table 4-8 lists typical saturation factors by
mode of loading for tank trucks and tank cars,
           TABLE 4-8.  SATURATION  FACTORS FOR BULK  LOADING OPERATION
          Mode of operation                    Saturation  Factor  (f),
         	dimensJonless	
          Submerged  loading;
            Clean cargo vessel                          0.50
            Normal dedicated service                    0,60
            Dedicated vapor balance service             1.00
          Splash loading
            Clean cargo vessel                          1.45
            Normal dedicated service                    1.45
            Dedicated_vagor_ba1ance service	1.00      	
         Source; U.S. EPA 19B5b.

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                                                      Issued: February 28, 1991
                                                      Revised:
                                                      Page No.:  4-27
                       CEB engineers typically assume complete saturation of the
vapor space within the vessel (f = l) for both tank truck and tank car loading,  Typical
and worst case parameters for tank truck and tank car loading are- presented in
summary Table 4-11 at the end of Section 4A.
                       An alternative method for estimating the vapor generation
rate for bulk loading of tank trucks and cars is the use of emission factors.  OAQPS
has collected information on  air emissions of volatile chemicals from different industrial
processes. These data  are compiled into a report entitled Toxic Air Pollutant
Emission Factors - A Compilation for Selected Air Toxic Compounds and Sources"
(USEPA I988a).  Emission factors from tank truck and car loading expressed as
amount of chemical released per tank truck/car loaded are presented for several
chemicals.  Table 4-9 presents estimated generation rates assuming that two tank
trucks or one tank car can be loaded in an hour.
              TABLE 4-9. AIR EMISSION FACTORS  FOR LOADING
                                                    Generation rate
            Operation/chemical                       (9/sec)
            Tank truck loading
              ethylene dibromide (product)            1 x 10"6
              ethylene dibromide (gasoline)            1 x 1fJ3
              ethylene dichloride (product)             1 x 10"5
              ethylene dichloride (gasoline)            2,6 x 10"3
              benzene                               0,06
              carbon tetrachloride, controlled           0.4
              carbon tetrachloride, uncontrolled        2.7
              chloroform                             3.9
            Tank car loading
              acrylonitrile, wet scrubber                4.72 x 1CT6
              acrylonitriie                            4.6 x 1CT4
            Source:  USEPA 1988a.
                        These generation rates were compared to the model
 (Equation 4-21).  The model was found generally to overestimate the generation rate
 by several orders of magnitude.  This overestimation is likely because the model does

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                                                       Issued:  February 28, 1991
                                                       Revised:
                                                       Page No.:  4-28
not consider the effects of engineering controls used to recover vapor losses as do
the actual data.
                       Two modes of drum-filling were studied under two simulated
drum-filling conditions:  1) splash filling in which the liquid dispenser remains at the top
of the container and the liquid splashes freely, and 2) bottom filling in which the liquid
dispenser remains at the bottom of the drum to minimize volatilization (MRI 1986).
During splash filling, the saturation concentration was reached or exceeded by misting
(MRI 1986). The generation rate for bottom filling was one-half that for splash filling.
Thus, for bottom filling  of drums, the  saturation factor is expected to be about 0.5.
                       .Open Surfaces. Open surface operations include work
related to open vats or tanks, solvent dip tanks, open roller coating, and cleaning or
maintenance activities.  Although this model is frequently used to estimate air
emissions from spills, CEB typically estimates exposures only during routine
operations.
                       Under contract to EPA, the evaporation rates of different pure
compounds in a test chamber were measured to determine an empirical model to
describe the relationship between evaporation rate and physical chemical properties.
The experiment is described in "Evaporation Rate of Volatile  Liquids" (Pace Laborato-
ries 1989). The data are presented in this reference for 16 compounds studied at
different air velocities and temperatures,  The data were curve-fitted. CEB is especially
concerned about low volatility chemicals and low air flow rates.
                       Based on mass balance of a differential element above a
liquid pool, the evaporation rate was  derived  (see Appendix K),

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                                                          Issued:  February 28,  1991
                                                          Revised: November 8, 1991
                                                          Page No.:  4-29
                        G  =
13,3167 M P" A
       f
                                                          MX5
                                                                      Equation 4-22
where:    G    =    Generation rate, Ib/hr
          M   =    Molecular weight, Ib/lb-mole
          P8   —    Vapor pressure, in. Hg
          A    =    Area, ft2
          D^  =    Diffusion coefficient, ft2/hr of a through b (in this case b is air)
          v2    —    Air velocity, ft/hr
          T    =    Temperature, °K
          Az   =    Pool  length along flow direction, ft
Gas diffusivities of volatile compounds in air are available for several existing chemicals.
However, the diffusion coefficient often will not be known. An equation to estimate
diffusion coefficients has been developed (see Appendix K). The expression for the
diffusion coefficient is expressed as:
                                                    0.5
                             4.09 x ltrW[JL + Ij  (M)-*33        Equation 4-23
                                            P,
where:    Dab  -    Diffusion coefficient, crrr/sec
          T    =    Temperature, °K
          M   =    Molecular weight, g/g-mole
          Pf    =    Pressure, atm

-------
 Substituting into evap:
where:    G
          M
          P*   =
          v-i   =
          A   =
          T   =
          A 2   =
                                       yO.OSAr0.5 p».5

                    Generation rate, g/sec
                    Molecular weight, g/g-mole
                    Vapor pressure, mm Hg
                    Air velocity, ft/min
                    Area, cm2
                    Temperature,  CK
                    Pool length along flow direction, cm
                    Overall pressure, atm
                                                           Issued:  February 28,  1991
                                                           Revised; Novembers, 1991
                                                           Page No.:  4-30
                        8.24 x 1')(v°'625)
where:
     G    = Generation rate, lb/hr ft2
     M   = Molecular weigh! of evaporating substance, Ib/Ib mole
     Pe   = Vapor pressure  at liquid temperature, in.Hg
     v    = Air velocity, ft/min
                                                                      Equation 4-25

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                                                         Issued: February 28, 1991
                                                         Revised: November 8,  1991
                                                         Page No.:  4-31
 Because open surface operations are highly process-specific, the engineer must make a
 judgment about the surface area from which volatilization is occurring. Table 4-10 gives
 conversions for typical diameter openings and surface areas:

                 TABLE 4-10.  TYPICAL DIAMETERS AND AREAS
Diameter
3 ft
2ft
1 ft
6 in
3 in
2 in
1 in
z, cm
91.5
61
30.5
15.25
7.6
5.08
2.54
Surface area, cm2
6,500
3,000
700
180
42
20
5
                        Sampling.  Sampling methods vary and include dipping, open
loop and closed loop sample bombs.  For worst case assumptions, sampling from a tap
into an open container should be assumed. Equation 4-24 is used assuming that the
surface area is equivalent to the sample bottle opening.  When no other information is
available, estimate the surface area to be 80 cm2 and 40 cm2 for the worst case and
typical case, respectively.
                        Fugitive Releases. Fugitive releases from  valves, pump seals,
and connections can lead  to significant occupational exposures, especially in enclosed
areas.  Potential exposures are expected to be  much less outdoors.   To estimate occupa-
tional exposure from fugitive releases of gas or vapor for a new chemical from equipment
used in its manufacture, the number of fugitive sources and the duration of worker
exposure must be  known.  This information is typically not available at the PMN review
stage. OTS rareiy estimates occupational exposure from fugitive emissions of PMN
chemicals during the review process since it is assumed that fugitive  releases are not the
most significant sources of occupational exposure.
                        The amount of contaminant leaking into the atmosphere can
be estimated based on emission factors for the different equipment components (see

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                                                          Issued; February 28. 1991
                                                          Revised:  Novembers. 199!
                                                          Page No,:  4-32
Table 6-1).  The vapor generation rate is calculated as a function of the number of
components, the appropriate emission factor for the component, and the weight fraction
of the component in the process stream.  These emission factors were developed for air
pollution purposes and are discussed in Section VI of this manual.
                   (5)  Summary Tables
                        The appropriate vapor generation rate is substituted into the
mass balance model to calculate the airborne concentration of the pollutant.  The worst
case workplace conditions are represented by low general ventilation rates; typical
conditions are represented by greater ventilation rates.  If the  workplace is known to
have different ventilation rates than  those generally assumed, the  documented values
should be used as the basis for estimation.
                        To facilitate calculations of exposure, Tables 4-1] and 4-12 list
the typical and worst case assumptions for each potential source of exposure and present
the simplified concentration model  The generation rates are "based on equation 4-21 for
transfers and 4-24 for open surfaces.  The engineer should consider the applicability of
the parameters before using ihese models.
      TABLE 4-11. SUMMARY OF CONCENTRATION CALCULATIONS FOR
                            TRANSFER OPERATIONS

Drumming (55 gal ) .
worst case
Typical case
Can5/boc:'.cs (5
93 1 . )
Worgt CflSC
typical case
Tanlr truck (5,000
gat . )
Uorst case
Typical, case
*ank ear (20,000
gal.)
worst case
"VD-. cal case
f CI«1

1 2.1 x 10*
0.5 2.1 x 105

1 '.9 x tot
„ 0,5 t.9 x 10"


1 1.9 * 10^
1 1.9 x 10'


1 7.6 x 1fl£
1 ?.S v, 10

r^

30
20

30
20


2
2


1
1

Q
ft /win

500
3,000

500
1,000


b
26,400 v
237,600


26,400 v
237,600

C
k

0.1
0.5

0.1
0.5


0.1
0.5


0,1
0.5

= 0.00075^ vPfr/Qk
ppm*

95 P
o

8,6 P
0.1 P


11 P/v
0. 24 P


22 P/v
0.48 P

       The units for P are in run Hg.
       Worst case out*»r ventilation (lowest yfnd sisced, v in nph) should be estimated by CEB engineer.

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                                                            Issued:  February 28,  1991
                                                            Revised:  November 8. 1991
                                                            Page No.: 4-33

       TABLE 4-12.  SUMMARY OF CONCENTRATION CALCULATIONS FOR
      	OPEN SURFACES	
                     *    z        a     k     Cv = 31.4 P (1/29 * t/M)°-25 A/M °-165z°'5CSc
                    cm    era     ft /win
      Sampt ing
      Worst case
      Typical cas*
     Open surface
      Worst ease
      Typicttl  c»se
80    10     500      0.1    16 P (1/2-?+ 1/M)°-2S/M °"1d5
40    7      3,500    O.S    0.3 P (1/29 + 1/H)°'Z5/M 0>1i5

b     b      500      0.1    0.628 P (1/29 + l/M>°-25 A/H D-1651°-
b     b	3000     Oj    0.021 ? (1/29 + i/«)°-25 A/H °-165Z:0-5
                 The units for P are  in am Hg.
                 See Table 4-10.
     B.   Estimating Dermal Exposure
          1.    General  Information
               In comparison to inhalation exposure, the assessment methodology for
predicting dermal exposures is relatively simplistic. To assess the potential for derinal
contact with a chemical,  it is necessary to identify the activity where potential contact
may occur, the likelihood of contact, the frequency of contact, the potential surface area
•.'-{ contact, the  physical state of the contacted substance, associated chemicals, and the
likelihood and effectiveness of the use of protective equipment.   With this information.
appropriate assumptions can be made to complete the assessment.
               For liquids and many solids such as powders, granules, or flakes,, a
quantitative estimate of contact should be made.   For materials  such as gases, cast solids,
or corrosives, a quantitative estimate should not be made.  For these materials a
qualitative estimate should be made using the following guidelines:
          Corrosives - Express contact as negligible due to the corrosive nature of the
          substance or associated  compounds.  Use for PMNs determined to be corro-
          sive by SAT/HERD or for PMNs/mixtures with pH greater than 1.2 or less than
          2. Consider contact points at which conrosivity may not apply, as in dilute
          solutions, and  quantify for them as needed.

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                                                          Issued;  February 28, :
                                                          Revised: November 8, 1991
                                                          Page No.; 4-34
          High temperatures - Express contact as negligible for materials that are at
          temperatures above 140°F.  Consider contact points at which temperature
          would not be a factor.
          Cast	sQlids/PMN in .matrices - Do not quantify contact. If the material is
         .manually transferred, acknowledge that some  surface  contact may occur,
          "Dry" surface coatings (e.g.. fiber spin finishes) - If manual  handling is neces-
          sary and there is an indication that the material may abrade from the surface,
          quantify contact with fingers/palms as appropriate.
          Ssses^agors - Do not quantify contact, but acknowledge thai some dermal
          contact will occur in the absence of protective clothing.
              Qualitative estimates should describe dermal exposure  using the following
exposure categories:
               - This is used  to describe workers who have no  chance of dermal contact
          during normal job activities.
          Very low - This is used to describe workers who during typical job activities
          would have no dermal exposure but who, on occasion, may have short periods
          of exposure after which all contact  surfaces would be washed.
          Incidental contact - This is used to  describe workers who during typical job
          activities have occasional  dermal contact of a minor nature.
          Intermittent contact  - This is used to  describe  workers who  during typical job
          activities have dermal contact such  as splashes, wiping with  contaminated rags,
          contact with contaminated tools, or surfaces,  Contact may be with either
          liquids or soiids.
          Routine contact - This is used to describe workers who during typical job
          activities routinely have dermal contact not including immersion in a liquid.
          Routine immersion - This is used to describe workers who typically immerse
          their hand(s) into a liquid,
              Worker practices and the use  of dermal personal protective equipment
are strongly  dependent on the  industry under study. Therefore, when making

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                                                      Issued:  February 28, 1991
                                                      Revised:
                                                      Page No.: 4-35
qualitative estimates it is important to obtain as much current information on work
practices in the industry as possible.
         2.    Quantifying Dermal Contact
              Dermal contact is best quantified with measurements made in specific
operations in the industry under study. Techniques used to quantify dermal exposure
include a patch type of derma! dosimeter made of gauze or charcoal cloth, a skin
wash technique (most appropriate for chemicals with low rates of dermal absorption),
urinary excretion of the chemical or metabolites of the chemical,  and fluorescence of
selective chemicals.  It  should be noted that these methods are commonly used to
quantify exposure, but  are very difficult to interpret (this science is still in formative
stages).  Since many of these techniques may be applied when the worker is wearing
personal protective equipment it is important to find out the exact circumstances when
the measurements were made.
              Once it  has been determined that dermal contact is likely and no
monitoring data are available, the contact may be quantified by using Equation 4-26.
          D   =   SOC                                             Equation 4-26
where:    D   =  Dermal exposure, mg
          S   =  Surface area of contact, cm2
          Q  =  Quantity typically remaining on skin, mg/cnf
          C  =  Concentration of chemical of concern, percent
The time of  exposure is estimated qualitatively and the dermal exposure calculated
using Equation 4-26 is then expressed as mg/day.  It is very important to note the
methodology used to determine the amount of dermal exposure.
              Table 4-13 provides typical factors for estimating  the amount of dermal
contact that may occur in particular situations, if such contact is  not ruled out by
factors such as temperature or corrosivity.  When using the typical values In

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                                                               Issued:  February 28, 1991
                                                               Revised:
                                                               Page No.:  4-36

 TABLE 4-13. TYPICAL FACTORS FOR CALCULATION OF DERMAL EXPOSURE
          Activity
          Routine immersion,
          2 hands
          Routine contact,
          2 hands
Typical examples
Cm"
       mg/cm
' Handling wet surfaces       1300

" Filling/dumping con-
 tainers of powders,
 flakes, granules

* Spray painting

1 Maintenance/manual        1300
 cleaning of equipment

* Unloading filler cake

* Changing filter

* Pi King drums with
 liquid
         1-3
Resulting
 typical
contact,0
  mg
         6-14     6500 to 18,200
                  1300 to 39GQ
Routine contaci,
1 hand
IneidersSaf contact,
2 hands

Incidental contact,
i hand
660 1-3
• Connecting transfer 1300 1-3
line
* Weighing powder/scoop-
ing/mixing (i.e., dye
weighing!
* Sampling 650 1-3
* Ladling liquid/bench
scale liquid transfer
650 to 1950
1300to 1900

65010 1950
            Popendort and Leffingwetl 1982.

           3 Versar 1984.

           " These estimates also must be adjusted by the conoentratson of the chemical in the mixture and
            the percent of the hand exposed if this is less than- what wouW be typical, Concentrations
            that change over time due to evaporation of other factors tlsc should be aeeownlecf for.
Table 4-13, the exposure estimate also should be adjusted by the following factors
when applicable:

           The concentration of the chemical in a mixture;

           The percent of the hand exposed if less than what would be typically
           expected for the activity;

           Rapid evaporation of the chemical (lessening exposure time); and

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                                                       Issued:  February 28, 1991
                                                       Revised:
                                                       Page No.: 4-37
         The effect of an industrial hygiene program,
              The likelihood of the use of protective clothing and its effectiveness
should be evaluated as described in Section IV.C.  If gloves are worn for reasons
other than strictly to protect against corrosivity, it must be assumed that there is some
potential they will not always be used. In instances where gloves are expected, the
engineer should dearly state the reasons for their use and estimate contact if they are
not worn.  The engineer must always clearly state the reasons for the conclusions,
              The surface areas used in Table 4-13 are derived from Poppendorf and
Leff ing well 1982,  Additional values for other parts of the body may be found in
Appendix H.  These surface areas may be used in some special circumstances,
              In Table 4-13, the amount per cm2 of skin contacted is derived from
Versar 1984.  In that study, immersion of the hands in liquids of varying viscosity was
found to result in retention of 5 to 14 mg liquid per cm* surface area (increasing with
increasing viscosity).  This range is appropriate for activities where there is frequent,
required contact with the material. Versar also reported results generally ranging from
1 to 3 mg/cm2 for activities such as  wiping up a spill or wiping the hands with a
contaminated cloth, and for the amount  remaining when the hands were "partially"
wiped with a dean cloth after immersion. This range is appropriate for situations
where there may be contact, but immersion is not expected,
                   Versar evaluated immersion by immersing a hand in a jar of liquid,
allowing excess liquid to drip into the jar, and weighing the jar to determine how much
liquid was removed.  Six liquids of various viscosities were used. The  data for
immersion of the hand range from 4,99 to 13.85 mg/cm? (for water and mineral oil,
respectively).  The concentration was a direct function of the  kinematic viscosity of the
liquid being tested.  After partial wiping, the  range was 1.3 to 2.72 mg/cm2, and was
not related to viscosity.  The lowest  quantities remaining after partial wipe were for the
more viscous  liquids tested.
                   The data for handling a rag ranged from  1.37 to 3,88 mg/cm2. The
least viscous materials had the highest data points.  Data for cleaning  a spill ranged
from 0.67 to 1,11 mg/cm3 and were not related to viscosity.  Partial wiping of the hand

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                                                       Issued: February 28, 1991
                                                       Revised:
                                                       Page No,:  4-38
afterward resulted in the remaining liquid ranging from 0.31 to 3,44 and 0.48 to 1,27
g/'cm?, respectively. Full wiping after the handling of a rag reduced the amounts
remaining to 0.01  to 3.3 mg/cm2,
                  The tests for initial and secondary uptake gave results of 1 .2 to 3.0
rng/crrf for the initial quantity on the hand. Again, the highest values were for the
least viscous materials.  Partial and full wipes reduced the amounts to 0.1 to 2.7
mg/cm7,
                  These data suggest that for contact with rags and for liquid
remaining after partial wiping when the hands have been immersed, the amount of
material on hands ranges from 1 to 3 mg/cm2 in nearly ail cases, as concluded by
Versar,  No relationship to viscosity is obvious. For immersion (without wiping) values
ranged from about 5 to 14 rng/cm?.
                  The Versar data are the most complete known for liquids.  A PMN
submitter measured immersion data and found a similar relationship to viscosity when
gloved hands were used.
                  Kin Wong evaluated wiping both hands with glycerin, paraffin, oil,
and water.  He obtained values of 0.5 to 1.8 g on the hand, equivalent to 0,4 to 1.4
mg/cm'2, assuming 1300 cm2 surface area for two hands.
         3.
              The inclusion of duration of exposure must acknowledge, If not
quantify, several mechanisms affecting dermal absorption. First is the issue of
volatilization of some (if not most) of the initial deposit from the skin before  complete
absorption can take place,  Second are workplace factors affecting the dermal
absorption rate. These include humidity (skin hydration), dermatitis, abrasion, and
clothing practices. Some  consideration also  should be given to the presence or
absence of chemical warning properties such as visual changes to the skin, irritation,
or corrosive properties. The engineer must  check that an estimated dermal exposure
does not exceed the amount of material that could be present on the worker's skin.

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                                                      Issued:  February 28, 1991
                                                      Revised:
                                                      Page No.: 4-39
             The amount of time for which the contact can occur should generally
be estimated as 1 to 4 hours, based on the expectation that the worker will, at a
minimum, thoroughly wash the  hands at lunch or end of the day.  However, volatile
materials may evaporate rapidly from the hand.  The actual duration of dermal contact
therefore may not exceed the duration of the activity leading to the contact. For
example, the volatilization model used to  estimate airborne concentrations of materials
can be used to show that a thin layer of toluene will evaporate in several minutes. If
an activity such as sampling were estimated to require half an hour, this duration can
be used as the maximum exposure time. The number of contacts per day can be
estimated as one or more, depending on whether the worker is expected to handle
the chemical throughout the day or the chemical is rapidly absorbed  but replenished
by additional contacts.  This is  based on expecting the worker to wash up at meal
breaks, When two distinct periods  of contact are expected, the duration, but not the
quantity, of potential contact should be doubled. That is,  if a worker's activities
involving a particular chemical last throughout the day, the engineer should report
contact as potentially lasting 8  hours, but totalling only the estimate for a  single
contact.
              This method provides an estimate of the amount of material on the
skin.  The Health and Environmental Review Division (HERD) usually estimates
absorption of the material through the skin as a percent of the amount of contact.
Sometimes the flux of a material through the skin may be known or estimated in terms
of mg absorbed per cm2 per unit of time. In such cases,  the amount absorbed  could
be calculated based on CEB's estimate of area contacted and duration of contact,  not
the amount on the skin.
     C.   Personal Protective Equipment
          The primary types of personal protective equipment used to reduce worker
exposure are gloves and respirators. Aprons, coveralls, goggles, and face shields
also may be used v/here necessary.

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                                                       Issued: February 28, 1991
                                                       Revised:
                                                       Page No,:  4-40
         1,   Gloves
              The ability to predict glove use practices, especially for end-users of a
chemical, is poorly established. Glove protection depends both on glove selection and
work practices. Therefore, it is difficult to define the level of protection resulting from
the general use of gloves.  There are no gloves available that are totally impervious to
chemicals.  Also, there are no  existing models to predict the degree of protection
offered by a gtove of a particular material when used in contact with a specific
chemical.  However, if gloves are properly selected and appropriately used
(considering available information on  permeation, penetration, degradation, and
frequency of replacement), their use will significantly reduce exposure.  The
effectiveness of gloves is a function of characteristics of the glove, the type of
chemical to which exposure may occur, the conditions of exposure, and the activities
of the worker.
              The permeation rate is the rate at which a chemical moves through a
glove material.  It is normally measured by testing a small piece of glove material using
a standard method such as ASTM  F-739-81, Resistance of Protective Clothing
Materials to Permeation by Hazardous Liquid Chemicals.  Breakthrough times for
many chemicals are listed in A.D. Little  1985.  Where many breakthrough times are
consistent for a chemical or chemicals, this may be referred to as a guide for
breakthrough times for that chemical.
              Glove materials (plastics or rubber) are  not impermeable. Permeation
tests of intact glove material usua !y result in the determination of a breakthrough time
(i.e., the time between start of the test and the first detection of the test chemical in the
test chamber). Only after breakthrough has occurred can steady-state permeation
rates be established. The ASTM method aims to establish this steady-state rate.
              Gloves or glove materials are a!so subject to penetration  (ASTM
definition:  "flow-through zippers, seams, pinholes, or other imperfections") and to
degradation by chemical or mechanical means.  Permeation rates do not refer to these
phenomena, although a materiai undergoing a permeation test may degrade to the
point that the test is invalid.

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                                                       Issued; February 28, 1991
                                                       Revised:
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              Requirements for gloves aiso must address the conditions of exposure
{e.g., one hour with the glove immersed in the chemical). A sufficiently long
breakthrough time relative to the duration  of exposure may mean that a glove prevents
exposure as long as it is intact and undegraded. The glove may be determined to be
"impervious" because exposure is too short for the chemical to achieve breakthrough.
              The ASTM method states that resistance is determined by measuring
the breakthrough time and monitoring the subsequent permeation rate.  A "resistant"
material is not defined in the standard. Gtove makers do rate the resistance of gloves
subjectively as "excellent, good," etc.  Unless "resistance" is very strictly defined, this is
a less stringent requirement than that the  material be "impervious."  A material that
resists breakthrough for 30 minutes may be rated resistant though exposure may
occur for hours.
              "Guidelines for the Selection of Chemical Protective Clothing" contains a
matrix of glove materials rated for many chemicals (A.D. Little 1985). The guideline
provides qualitative  recommendations for  twelve common glove materials based on
both computer predictions and test data.  The recommendations are presented by
chemica! and chemical class.  This matrix should be used only as guidance.
              A computer model that predicts the amount of a chemical that will
permeate glove  materials has been developed by A.D, Little (A.  D, Little 1989),  It is
designed to predict the amount of  permeation through five different glove materials for
some organic chemicals. The glove materials are natural rubber, nitrile rubber,
neoprene, tow density polyethylene, and butyl rubber.  Material thickness can be
varied.  Besides gloves, the model can predict permeation rates for aprons, coveralls,
and other protective clothing that are constructed of one of the five materials.
              The model requires chemical-specific input:  molecular weight, density,
and vapor pressure or molecular structure of the chemical. The mode! also
incorporates specialized versions for certain  chemical groups for which rt requires
more detailed input resulting in a more accurate prediction. The output is a cumulative
amount of chemical permeating through the  material over time,  presented as mass per
surface area for a designated  period.  The model also provides breakthrough times.

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                                                        Issued:  February 28, 1991
                                                        Revised:
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              The following language has been adopted as standard for requiring the
use of gloves in orders written under Section 5 of TSCA:
     Workers who may be dermaliy exposed to the PMN substance shall wearjgloves determined by
     the Company to be impervious to the PMN substance under the conditions of exposure, including
     the duration of exposure. The Company may decide this either by testing the gloves under the
     conditions of exposure or by evaluating the specifications provided by manufacturers of the
     gloves.  Testing or evaluation of specifications should include consideration of permeability,
     penetration,  and potential chemical and mechanical degradation by She PMN or associated
     materials.
              A requirement for gloves usually should not specify their length (e.g.
elbow length).  For most exposure scenarios, it seems reasonable to require
protection of the hands when there is potential that they would be immersed in a PMN
chemical or otherwise contact bulk amounts of the chemical Longer gloves should
only be needed where there is considerable potential for splashing of the material.  In
such cases, aprons or other body covering also may be in order.  The engineer on
the case may be  in the best position to  make recommendations in this area, based on
familiarity with the processes that may lead to extensive exposure.  It should be noted
that CEB does  not consider the physical environment in which the gloves will be worn,
but considers only the potential for chemical permeation, penetration, and degrada-
tion.  The physical environment is an important consideration as gloves are often
composed of polymeric materials that may  be stressed, punctured, or otherwise
damaged in actual used.
          2.    Respirators
               Respiratory protection for new and existing chemicals  presents some
unique and complicated problems for the assessment and control of occupational
exposure.  Often, the potential for inhalation exposure is a primary concern for the
workers who handle new  or existing  chemicals.
               a.   OS HA Reguirernents
                   OSHA regulations in 29 CFR  1910.134 cover the  proper use,
selection, care, and maintenance of respiratory protection.  OSHA Permissible Practice

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                                                       Revised;
                                                       Page No,:  4-43
requires that engineering controls are first considered for reducing worker exposure
levels.  However, if engineering controls are not feasible, need to be supplemented, or
are in the process of being instituted, appropriate respiratory protection should be
used to reduce worker exposure.  Use of even one respirator by one employee
requires the implementation of a respirator program that meets the minimum program
elements specified by OSHA,  Besides the use of an appropriate NIOSH or Mine
Safety  and  Health Administration (MSHA)  approved respirator, the minimum
requirements for this respirator program are summarized as follows:
         Written standard operating procedures.
         Selection based on the hazards to which the worker is exposed.
         Training and instruction.
         Provisions  for cleaning, disinfection, storage, and maintenance,
         Respiratory Program inspection and evaluation.
         Determination that employees are physically abie to perform the work and
         use the respiratory  protective equipment.
                   Further respirator use, selection, and program details are available
in the American National Standards Institute (ANSI) Standard Z88.2 1990  (in publica-
tion).  Details on respirator construction and performance testing are covered in the
Bureau of Mines regulations at 30 CFR 11 (latest revision 7/26/89). tt should be
noted  that the OSHA standard (29 CFR 1910.134) and the NIOSH certification
standards (30 CFR 11) are both being revised at this time.
               b.   Selection of a Respirator
                   (1)   Background
                        industrial hygienists go through a series of decisions to select
the appropriate respirator. These include:
         The desired exposure level (e.g., TLV);
         The ambient concentration of the chemical in the work environment; and
         The specific work conditions under which the respirator will be worn.
These and other human factors are discussed more fully in Appendix I.

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                                                       Issued;  February 28, 1991
                                                       Revised:
                                                       Page No,: 4-44
                       NIOSH has developed a document entitled "A Guide to
Industrial Respiratory Protection" which contains a decision logic for assessing the
respiratory protection requirements under many conditions (NIOSH 1976).  This
decision logic was updated in 1987 (NIOSH 1987).  This reference should be
consulted when selecting respirator needs.
                       TLVs are rarely established for new chemical substances and
no information about absorption of the chemical by  carbon in organic vapor cartridges
or odor threshold is typically available. Selection of an appropriate respirator is difficult
without this information. Therefore, the rationale of  selection should be clearly
presented. It also must be remembered that wearing  a respirator is often a burden to
a worker performing tasks. Not all worker activities or types of respirators are
amenable to use of respirators over extended periods of time.
                   (2)  Sejeclion	o.f	EespJr.atQ.ry/Protection by CEB
                       Selection of respiratory protective equipment by CEB is
constrained by many factors as described in Appendix I.  For CEB, selection is limited
to recommending different classes or categories of  respirators based on state-of-the-
art knowledge of respiratory protection.  The document "Strategy for Recommending
Respirators for Control of Exposure to Substances Undergoing Premanufacturing
Notice (PMN) Review" (Myers nd), which is contained  in Voiume II, should be used to
select the appropriate class of respiratory protection for a  PMN chemical  The
selection of a particular device within a recommended category must be made by a
knowledgeable person at the workplace who is familiar with the actual conditions of
use. When respiratory protection is required, industrial hygienists typically weigh  many
factors into the consideration of alternative respirator devices including;
          The permissible exposure limit (PEL) specified by OSHA or threshold limit
          value (TLV) specified by the American Conference of Governmental
          Industrial Hygienists (ACGIH) or other allowable  exposure level established.
          The warning properties of the contaminant

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                                                       Revised:
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         The concentration of the contaminant (and other contaminants) in the work
         area.
         "The type of hazard (gas, fume, mist, particulate, etc.).
         The degree of protection afforded by various respirators.
         The conditions of use of the respirator including other hazards present, such
         as lack of oxygen or confined space.
         The workers' ability to wear a particular device.
         Worker comfort, degree of wear time, need for communication or specific
         duties that may be affected by the respiratory device.
                       For PMN substances, there is generally no established PEL
or TLV and it is generally unknown whether there are adequate warning properties.
According to 30 CFR 11, air-purifying respirators are prohibited for protection against
organic vapors  with poor warning properties unless there is an OSHA or other Federal
standard that permits their use. OSHA has allowed the use of air-purifying devices for
substances with poor warning  properties (e.g., acrylonitrile, benzene, and vinyl
chloride), if cartridges or canisters are changed prior to the end of the service life
(before breakthrough) or before the beginning of the next shift, whichever comes first
(29 CFR  1910,1017, 1910.1028, and 1910.1045).
                       The selection of an air-purifying, organic vapor respirator
requires a complex analysis of the anticipated performance of the chemical cartridge
or canister in atmospheres containing the substance of concern,  CEB must consider
the following factors in this analysis:
          Human levels of detection (odor threshold) or properties that make
          recognition easy (irritation, lacrimation).
          How  long it takes the PMN substance, at the concentration in the workplace,
          to break through the sorbent (cartridge service life),
          The expected duration of exposure compared to the cartridge service life.
          How  often and when cartridges will be replaced.
          Reaction products or amount of heat generated during sorption,

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                                                       Issued: February 28, 1991
                                                       Revised:
                                                       Page No,:  4-46
                       The consideration of an organic vapor respirator for a PMH
substance should be based on the following:
         A decision by Division Directors that a protection factor of 50 or less will
         afford adequate protection for the PMN substance.
         An initial screening by CEB that determines that the PMN is a good
         candidate for an air-purifying organic gas and vapor respirator based on
         consideration of:
              Warning properties.
              Possibility for heat generation or generation of toxic chemicals upon
              sorption,
              Results from models that predict cartridge service life.
              Other sources of information, such as ACGIH, NIOSH, American
              Industrial Hygiene Association (AIHA recommendations for analogues,
              etc.
                       If CEB determines that a PMN substance is not a good
candidate, the 5(e) Order would specify a supplied-air respirator, but the company
could petition EPA and provide the necessary documentation proving that an
air-purifying respirator is acceptable and that the organic vapor cartridge provides
acceptable performance.
                       In either case, the submitter would be required to document
the effectiveness of  an organic vapor cartridge respirator by submitting the following
information:
              The service life of the cartridge.
              Information showing that high temperatures (>40°C) or toxic chemicals
              are not generated upon sorption of the PMN substance.
              A respirator cartridge change-out schedule established as part of the
              respirator program.
              Any known information  on the warning properties of the PMN
              substance.
              Any administrative controls that will be used by the submitter.

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                                                       Issued:  February 28, 1991
                                                       Revised:
                                                       Page No.; 4-47
                       NIOSH is preparing guidance to be used for testing organic
gas/vapor cartridges for service life.  However, until this guidance is available, CEB
recommends that organic gas/vapor cartridges be tested in accordance with the
proposed NIOSH 42 CFR 84, Tests and Requirements for Certification of Permissibility
of Respiratory Protective Devices Used in Mines and Mining, published in the Federal
Register on August 27, 1987, A CEB industrial hygienist should be consulted to
determine the appropriate test concentrations for the PMN substance, and answer any
questions the submitter may have.
                       This information should be submitted for CEB review before
OTS approves use of  an air-purifying respirator. This occurs  either before  an order is
written or upon a company's request to modify an existing order.  Submitted
information will be reviewed by a CEB industrial hygienist on a case-by-case basis.
                       (3)  Protection Factors
                       Protection factors for various classifications of respirators
have been assigned by NIOSH (see Appendix J).  CEB  uses  these values  will be used
to decide the appropriate type(s) of devices necessary to achieve the degree of
protection determined by Division Directors,
                       The protection factor of a respirator  is an expression of the
performance based on the ratio of the concentration of  contaminant measured outside
the facepiece cavity to the concentration of contaminant measured inside the
facepiece cavity. The Assigned Protection Factor (APF) is defined by NIOSH as a
measure of the minimum anticipated workplace level of  respiratory protection that
would be provided by a properly functioning respirator or class of respirators to a
percentage of properly-fitted and trained users.
                       The table of protection factors  developed by NIOSH may be
simplified since most classes of respirators have Assigned Protection  Factors that fall
into one of four  categories:  APF >  = 2000; APF >  = 50; APF > =  25; and APF > =
10, Thus, respirators will be selected based on the need for  a 100Q-, 50-,  or  10-fold
reduction in the  estimated potential  inhalation  exposure.

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                                                       Issued: February 28, 1991
                                                       Revised:
                                                       Page No.:  4-48
                       APF of at Least 2000 is Considered.  Devices  which have
been assigned a protection factor of 2000 or greater are suppfied-air respirators
equipped with a full facepiece and operated in positive pressure mode. Since the
selection of a supplied-air respirator is independent of the physical and chemical
properties of the contaminant, no further information is required to make this choice.
                       APF of at Least 50 is Considered. Supplied-air devices that
have been  assigned a protection factor of at least 50 are equipped with a tight-fitting
facepiece and operated in continuous flow mode, or are equipped with a full facepiece
and operated in demand (negative pressure) mode. However, QSHA does not allow
the use of supplied-air respirators operated in demand mode.  Supplied-air respirators
operated in positive pressure mode have much better performance as facepiece
leakage is minimal with positive pressure. Thus, EPA will allow the use of positive
pressure, supplied-air respirators only.  Air-purifying respirators equipped with a full
facepiece and powdered air-purifying respirators equipped with a tight fitting facepiece
have been  assigned protection factors of 50.
                       APF of at Least 25 is Considered. Powered air-purifying
respirators  equipped with a loose fitting hood or helmet have been assigned a
protection factor of 25.
                       APF of at Least 10 is Considered. Most approved respirators
have a protection factor of at least 10.  For a paniculate exposure, a high efficiency
particulate  filter is required. To recommend the use of an organic vapor respirator, the
effectiveness of the cartridge or canister must be evaluated as described above.

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                                                      Issued: February 28, 1991
                                                      Revised:
                                                      Page No.:  4-49
                  (4)  StandatilLanguage for 5(ej Orders
                       The standard language as presented in Appendix J reflects
the use of the NIOSH APF values. It describes the general classes of respiratory
protection that should be recommended in 5(e) or other orders.  Any questions
regarding respiratory protection for 5(e) Orders should be referred to a CEB industrial
hygienist
          D.   Engineering Controls
              1.   Local Exhaust Ventilation
                  Local exhaust ventilation (LEV),  in addition to general ventilation, is
the primary control used to reduce worker exposure to  chemicals. If LEV is used for a
specific activity, the specifications of the control should  be compared to the recom-
mendations made by ACGIH in "Industrial Ventilation: A Manual of Recommended
Practice" (ACGIH 1986).  Although a qualitative determination of control use can be
made, it  will  usually not be possible to account quantitatively for local exhaust.
                  The actual reduction in worker exposure from the use of LEV is
not a simple  relationship.  It is dependent on several factors:
              The design capture efficiency of the LEV system;
              The work practices of  the employee;
              Air currents in the work area;
              Other process-specific factors such as dragout or sudden releases;
              and
              Actual maintenance of the LEV system over time,
                  The design capture efficiency is primarily dependent on hood
design and exhaust volume.  The best hood design is one that encloses or confines
the process. This is not always possible when worker access to the process is
considered.  Exhaust volumes (or face velocities) presented in the ACGIH ventilation
manual for a similar process should be compared with  information supplied by the
submitter to  ensure that adequate face velocity will be used in the design.

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                                                       Issued;  February 28, 1991
                                                       Revised:
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                  The addition of an LEV system can affect the work practices of the
employee.  Enclosure of the process can cause changes in work practices that may
make the LEV less effective. The LEV design should never allow the breathing  zone
of the worker to pass between the pollutant source and the exhaust.
                  Air currents in the work place from other processes, natural
ventilation, general ventilation, or movement in the area can reduce the effectiveness
of an LEV system. All possible cross currents should be minimized.
                  Process-specific factors such as dragout can cause the chemical
to be carried out of the capture zone of the LEV system,  thus decreasing its efficiency.
Processes that release sudden surges of hot gases or vapors must design the  LEV
system to account for these releases.
                  Finally most LEV systems are not maintained at  peak efficiency
throughout their life.  If a system is older, the questions of design parameters such as
face velocity versus actual parameters should be  addressed,
                  One process where standard LEV design can obtain very high
efficiencies is the  use of lay-on or slot LEV to control worker exposure during drum
filling.  In a series of tests on LEV use in drum filling performed for OTS, capture
efficiencies were between 99 to 100 percent when the ACGIH design flow rate was
used (PEI 1987).  The efficiency of the lay-on and slot LEV systems  in drum filling
operations generally  was independent of the concentration of emissions leaving the
drum. The efficiency was affected  by the fill rate that determines the emission velocity
at the drum bung hole.
              2.   JjitrQgen_BJ.a.n.Keting
                  Chemicals that are extremely volatile  or that react with water or air
on  contact are often  loaded into shipping containers  under a nitrogen blanket.  This
handling procedure (known as nitrogen blanketing, padding, or purging) displaces air
and moisture and therefore prevents degradation of the chemical and decreases the
chance of explosion.  Volume  il contains a description of the process and work

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                                                       Issued:  February 28, 1991
                                                       Revised:
                                                       Page No.:  4-51
activities associated with the procedure for aeetaldehyde, hydrazine, and toluene
diisocyanate (Mitre 1984).
                  The only release expected from nitrogen blanket transfer is a small
spilt from the end of the transfer line of the liquid remaining between the valve and the
end of the coupling collar. Assumptions to be made in the absence of other
information are described In the report and include:
              Nominal inside diameter of transfer line equals 3 inches.
              Distance between valve body and end of collar equals 3 Inches,
              Area of spill is assumed to be 730 cm2.
         In the original document describing nitrogen blanketing (Mitre 1984), a
model was assumed for the generation rate and an empirical equation for the mass
transfer coefficient.  In this revision of the  engineering manual, CEB has revised the
mode! for generation rate from an open surface. Using the equation for estimating
airborne concentration  from an open surface (Equation 4-25) and substituting the
surface area of the spill:
Worst case:
                                  Cv = 1679 P                     Equation 4-27

Typical case:
                                  Cv = 54,8 P                     Equation 4-28

where:    Ctf  =   Airborne concentration,  ppm
          P   =   Vapor pressure, mm Hg
              3.   Transfers
                   Emissions from controlled loading operations can be calculated by
multiplying the uncontrolled emission rate (Equation 4-21) by the control efficiency
term:

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where
G
E
I

M
V
         R
         T,
                                                      issued: February 28, 1991
                                                      Revised:
                                                      Page No.:  4-52
                           G -1 -
                        f M V r P*
                  100 J  3600  fl  IL

Vapor generation rate, g/sec
Control efficiency, percent
Saturation factor, dimensionless
Molecular weight, g/g-mol
Volume of container,  cm3
Fill rate, units/hr
Vapor pressure of pure substance, aim
Universal gas constant, 82,05 atrn cm3/g-rnol * K
Liquid temperature, • K
                                                        Equation 4-29
Measures to reduce loading emissions include use of vapor recovery equipment to
capture the vapors displaced during loading, recovery by refrigeration, absorption,
adsorption or compression, and piping back to storage. Vapors also can be
controlled through combustion in a thermal oxidation unit with no product recovery.
Control efficiencies of modern units range from 90 percent to over 99 percent depend-
ing on the nature of the vapors and the type of controls used  (USEPA 1985b).

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                                                      issued: February 28, 1991
                                                      Revised:
                                                      Page No.:  5-1
V.   MODELING RELEASE TO WATER
     This section covers standard procedures to be used when estimating release to
water during manufacture or processing of chemical substances.  It is primarily
intended for batch operations, so the basis for most estimates should be per batch.
In completing a scenario the engineer should obtain as much information as possible
from the submitter of a PMN or manufacturer of an existing chemical. The
assumptions presented here can be used in the absence of data from the submitter,
or when evaluating the reasonableness of data, or for preliminary evaluation of the
potential for release of existing chemicals. To reflect the uncertainty in the assessment
methodology, the engineer should report releases as a range and identify the basis for
the range.
     The areas covered are cleaning of equipment, tank truck/car cleaning, phase
separation, condenser/scrubber operation, and polyelectrolyte wastewater treatment.
These operations are commonly encountered in the PMN review process and are
often the most important sources of water releases.  Little data are available on actual
losses of chemicals to water from these simple batch operations.
     A.   Cleaning of Equipment
          To estimate the  amount of material that may be lost to water in cleaning of
equipment, the engineer should consider the equipment cleaning process, the
equipment to be cleaned,  the cleaning schedule,  the residual quantity of the PMN
chemical (or other material of concern) in the equipment, the type and amount of
solvent used (water or organic), the solubility/miscibility of the material in water, and
any treatment of the wastewater.
          Equipment is either rinsed or flushed with water or an organic solvent,
 depending on the solubility of the chemical in various solvents.  If water is used, the
 waste will typically be sent to wastewater treatment or reworked into a new batch.  If a
 solvent is used, it will typically either be recycled  or incinerated (for estimation of
 releases from incineration see Section VII).

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                                                      Issued:  February 28, 1991
                                                      Revised:
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         The first step in the analysis is to determine the type and volumetric capacity
of major equipment that is cleaned (or volume of chemical per batch processed
through that equipment).  Once all equipment and piping to be cleaned are identified,
the amount of chemical in the equipment during operation can be determined.  This
will be the batch volume.  Adjustments should be made for the concentration of the
chemical in the mass contained in the equipment
         When size of equipment is unknown, the engineer must assume values
based on experience in the industry in question or information from similar cases or
the literature.
         The frequency of cleaning of the equipment must be determined. Clean-out
after every batch may occur if quality of product demands it.  Other reasons for
frequent clean-out are changes in the type of batch being run (e.g., color change in   ,
paint mixing), possible solidification of product within a reactor, or proper operation of
mechanical equipment (e.g., a plate and frame filter may not  close if not cleaned after
each use). Clean-out after  every batch should only be assumed if a specific reason
for such cleaning can be identified. Otherwise,  the engineer  should assume cleaning
only after one week's run or at the completion of a campaign, whichever comes first.
The frequency  of cleaning must be clearly stated, and release per day from cleaning
reported.
          Another factor to be considered is the possible recycle of defining effluent
back to the process.  Although such flushing may occur after every batch, it may not
result in a release (Le., the  residue may be added to the product stream or used in the
next batch).  This can occur when mixing vessels are rinsed  with water that is sub-
sequently reworked into batches of similar product, or when  product is to be
subsequently isolated from the cleaning solvent by distillation.  Cleaning that results in
a release may  be very infrequent in these cases.
          The amount of the PMN chemical or other material of concern remaining in
equipment prior to cleaning is the amount available for  loss.  Many parameters affect
this quantity, including the design configuration of the equipment, the method of
removing or unloading the  chemical from the equipment, the viscosity of the chemical,

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                                                       Revised:
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and the material of construction or lining of the equipment.  Typically, the amount of
chemical available for loss is calculated as a percent of the total amount of the
material in the equipment during normal operation of a batch.
         Table 5-1 presents factors for estimating percent chemical remaining in
drums and tanks after unloading. These factors were derived from a pilot scale
research project investigating the effect of the four parameters listed in the preceding
paragraph on residue quantities (PEI 1986a). It was concluded that the amount of
residue is generally influenced  most by the method of unloading. The  viscosity ..of the
chemical and the design configuration of the equipment will affect residue quantities to
a lesser degree. Material of construction or lining of the equipment has little effect on
residue quantities. The values listed in the table represent residue quantities as a
weight percent of vessel capacity (pound chemical residue per 100 pounds of
chemical).  The mean values presented in Table 5-1 may be used to represent typical
residues, while the upper end of the range may be used to represent reasonable worst
case.  The values in Table 5-1  should only be applied to similar vessel types, unload-
ing methods and bulk fluid materials. The research was performed with materials with
viscosities below 100 cp.  For  materials with significantly higher viscosities (>200 cp),
estimates of percent residue were made based on engineering judgment.
          Dow has developed a new "drainable" drum design which they  claim has
residual losses of about 0.02 percent. Dow compares this to losses from conventional
drums of 0.5 to 0.68 percent for inversion draining and  0.68 to 2 percent for dumping.
 Engineers should be aware of these new drums and consider contacting Dow for
 individual PMN cases to estimate the likelihood that the new drums will be used.
          Besides drums and  tanks, losses from process piping should be considered.
 The amount of chemical available for loss from process piping is calculated as a
 percent of the total volumetric capacity of the piping being cleaned. A residue quantity
 of 1 percent of piping volume may be assumed.
          A final factor in estimating release is whether water or an organic solvent is
 used  in cleaning.  It should be assumed that water is used unless there is strong

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TABLE 5-1. SUMMARY OF RESIDUE QUANTITIES FROM PILOT-SCALE EXPERIMENTAL STUDY,
                        WT. PERCENT (Source: PEI 1986a)

Surfactant
Unloading method Vessel type Value solution8
Pumping Steel drum Range 3.06
Mean 3.06
Pumping Plastic drum Range Not available
Mean
Pouring Bung-top steel drum Range 0.485
Mean 0.485
Pouring Open-top steel drum Range 0089
Mean. O.OB9
Gravity drain Stope-bottom steel tank Range 0.048
Mean 0.048
Gravity drain Dish bottom stee! tank Range 0.058
Mean 0.058
Gravity drain Dish-bottom glass-feted tank Range 0.040
Mean 0.040
* Surfactant solution viscosity- 3 cenUpofsfl, surface tension* 31.4 dynes/cm2.
b For water, viscosity » 4 centlpofee, surface tension - 77.3 dynes/cm3.
° For kerosene, viscosity « 5 centlpoise. surface tension - 29.3 dynes/cm2.
d For motor ol. viscosity - 87 centipolse, surface tension » 34.5 dynes/cm2.

Water"
1.84-2.61
2.29
2.54 - 4.67
3.28
0266^.458
0;403
0.026 - 0.039
0.034
0.016- 0.024
0.019 .
0.033 - 0.034
0.034
0.020 - 0.040
0.033



Material
Kerosene0
1.93- 3.08
2.48
1.69- 4.08
2.61
0.244 - 0.472
0.404
0.032- 0.080
0,054
0.020^.039
0.033
0.031 - 0.042
0.038
0.024 - 0.049
0.040



e Residue quantities tor high viscosity material were not defined by the study; thus, the quantities presented are esthiwtesof a
based on engineering Judgment.
Source: PEI 1986a.




Material6 with
MotproC1 viscosityi 200 cp
1.97- 2.23 3
2.06
1.70 - 3.48 4
2.30
0.677 - 0.787 1
0.737
0.328 - 0.368 0.5
0.350
0.100 - 0.121 0.1
0.111^
0.133 - 0.191 0.2
6.161
0.112-0.134 0.2
0.127



reasonable worst case scenario
,/l






^O 33 rn
tO CD {/I
CO < C
0> W>" CD
.9 CD Q.
Tl
CD
cn OT
"** cu
ro
00
CD
to

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                                                       Issued:  February 28, 1991
      •.        ,   •'                                 •     Revised:
                                                       Page No.: 5-5
reason to believe otherwise.  Once .the use of water for cleaning has been established,
the release of chemical to water is simply the amount of chemical available in the
equipment.  Some reactions  must be carried out with the complete absence of
moisture, however.  For example, it is unlikely that a company would clean using water
if it were then necessary to dry the reactor thoroughly before the next batch. Other
reasons for not using water could include permits that prevent the release of any
process water, extreme reactivity of the product in water, or the existence of a solvent
recovery system for isolating product from the solvent in which it is made (in which
case it  can be assumed that the same system could be used to recover solvent from
cleaning wastes).  If an organic solvent is used, it should be assumed that all the
chemical available for loss is removed in the solvent and that this material is landfilled
or incinerated with or without separation from the solvent.  If information on the solvent
used is not available from the submitter, engineering judgment should be used.
          Companies may use water to flush a chemical from equipment, intending to
separate it from the water by settling, filtration, or use of an oil/water separator prior to
further  wastewater treatment. The engineer must account for this separation to
 present valid estimates of release.  The controls section (Subsection VILA) discusses
 these wastewater treatment methods.  Methods for adjusting release estimates to
 account for treatment are also discussed.
      B.   Tf nk Truck g"H T?nk Car Cleaning
           To estimate the quantity of material that is released during tank truck or tank
 car cleaning operations, the engineer must consider the cleaning process, the
 cleaning frequency, the solubility/miscibility of the material in water, the solvent used
 for cleaning (water or organic), the quantity of material residue in the tank truck or car,
 and any treatment of the wastewafer.
           Cleaning of tank  trucks and tank cars generally has four basic steps:
      .   Any material remaining in the tank is removed through draining or other
           means.  Sometimes, residue on the sides of the tank may have to be

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                                                       Issued: February 28, 1991
                                                       Revised:
                                                       Page No.:  5-6
         manually scraped to remove valuable material or to prevent a discharge of
         material to wastewater during rinsing with water,
         The tank is rinsed with either water or an organic solvent, depending on the
         solubility of the chemical in the various solvents.  If water is used, the waste
         will typically be sent to wastewater treatment.  If a solvent is used, it will
         typically be recycled, resulting in spent solvent (containing the chemical of
         interest) that is likely to be incinerated.
         The main wash step is performed with either a caustic solution, a detergent
         solution, or simply water.  Often, these solutions are filtered and reused in
         the washing process.  Spent or waste solution resulting from this  step is
         typically sent to wastewater treatment.
         The tank is rinsed with water and the resulting waste is typically discharged
         to wastewater treatment.
The engineer must consider at the points at which water will be used in the cleaning
process for the particular chemical in question, and the wastes that will be discharged
to water.
         The cleaning schedule of the tank trucks/cars must be known. For tank
trucks/cars dedicated to one chemical, cleaning is often limited either to when the
tank becomes contaminated or prior to tank inspections, repairs, and testing.  Some
shippers, however,  insist that the tank truck/car be cleaned after every load, whether
the container is dedicated to one chemical or not.  Tank trucks/cars used for general
purpose hauling (i.e., nondedicated service) are cleaned after each load. Cleaning
frequency must be  clearly stated,  and the release per cleaning reported.
         The amount of chemical remaining in  the tank truck/car and available for
loss should be estimated as a percent of the tank load.  This amount depends on the
method used to unload the tank truck/car and the viscosity of the chemical.  Studies
have been performed for specific materials and  residue data can be found in the
literature.   For example, one study determined that an average of 0.15 percent of milk
transported in tank trucks remains on the sides of the truck as residue (PEI 1986a).

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                                                       Issued: February 28, 1991
                                                       Revised:
                                                       Page No.:  5-7
         A typical tank truck hauls 3.5 loads per week and carries approximately
5,000 gallons per load [CEB n.d.].  A typical tank car carries up to 34,000 gallons per
load (Monsanto 1978).  A representative number of loads hauled  per week per tank
car cannot be determined since many tank cars are dedicated and, therefore, rarely
cleaned.  When data are not available, 0.1 percent (on a mass basis) can be used to
give a rough approximation of the quantity of chemical available for loss.
         Tank truck cleaning typically generates 500 gallons of wastewater per tank
truck cleaned, although up to 5,500 gallons of wastewater may be generated from a
full flushing operation (Monsanto 1978). Tank car cleaning can generate as little as
60 gallons of wastewater, although 34,000 gallons may be generated from a full
flushing operation (Monsanto 1978).
          Greater than 98 percent of the organic residue is generally removed during
the rinse and main wash steps (Monsanto 1978).  This value may be assumed except
for cases involving highly viscous chemicals such as crude petroleum products. The
remaining 2 percent of the residue is expected to be removed during the final
water/caustic wash.  ^   _
           ^^_^^^^
 percent of the tank load is assumed to be lost to solvent wastes that will likely be
                   ^^
 water rinse.       • .,
          If water or caustic solutions are used throughout the cleanup, It should be
 assumed that 0.1 percent of the tank load is discharged to wastewater.
          The solids and immiscibles may be separated from the wastewater prior to
 further treatment or discharge.  The quantity remaining  in the water after separation
 should be determined by multiplying the solubility of the chemical by the quantity of
 water used. , This approach will typically lead to lower than actual release quantities
 because it does not account for suspended solids entrained in the wastewater effluent.

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                                                       Issued: February 28, 1991
                                                       Revised:
                                                       Page No.:  5-8
     ,C.   Phase Separation                                             '    ,•
          The amount of a PMH chemical or other chemical of concern lost to water
 from phase separation will depend on thjs j/aJumejta
 the chemical in water.  If an organic solvent is also used in the separation, the volume
"ofth'at solventlanTfhe solubifcy of the chemical in the solvent will affect the amount of
 chemical lost to water.  Since PMN chemicals normally have undergone only bench
 scale or pilot plant production when they are reviewed by EPA, much of the infor-
 mation that is needed to estinraate loss must be based on professional judgment or
 standard chemistry/engineering estimation techniques.
          A typical phase separation problem occurs when the "product" PMN
 chemical is contained in the organic phase and a small amount remains in the
 aqueous phase. This situation  may arise when:
          Solvent is added to a reaction product to extract the chemical from water
          already present (doe  to reaction or  addition as a carrier for the reactants).
          Water is added to a chemical/solvent mixture to extract impurities into the
          water.
          The chemical constitutes the organic phase and water is the only other
          major constituent.
 The discussion presented here does not address a fourth case in which the "product"
 PMN chemical is removed wfth the water phase.
          The following assumptions are implicit in this scenario:
          The PMN chemical is present mainly in the organic phase from which useful
          product will be recovered. Due to tow solubility of the chemical in water, a
          small amount is also present in the aqueous phase.
      •   The process is batch.  Sufficient residence time is allowed to achieve the
           interphase in the phase separator.  Separation is assumed to be perfect (i.e.,
          the water can be  drawn off with no entrapment of undissolved organics).
           Losses from auxiliary operations such as cleaning and distillation, are not
           considered.                         '    .  '

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                                                      Issued:  February 28, 1991
                                                      Revised:
                                                      Page No.: 5-9
To estimate release, the engineer must determine the amount and type of solvent
present, the amount of water present, and either the partition coefficient for the
chemical in solvent/water or, more simply, the water solubility of the chemical.
         If the volume of the aqueous phase cannot be obtained from the submitter,
the engineer has several approaches to estimating the amount:
     .   A mass balance on the reaction can be used to determine the amount of
         water either added with reactants or produced in the reaction.  If there is
         insufficient information to perform a mass balance (e.g., processing steps
         are speculative), it can be assumed that water equals 10 to 50 percent of
         total batch volume.
     .   If water is added to wash impurities from the organic phase, it can be
         assumed water added equals 10 to 100 percent of batch volume.
         If the size of decantin^aqui^ment is known, the amount of^aqueousjphase
                                                                    '
          Va  *  Va(DL)(IL)                                         Equation 5-1
 where:   Va   =   Volume of aqueous phase
          Vd   =   Volume of decanting vessel
          DL  =   Decanter fill level, % of decanter height
          IL   =   Interphase level, % of decanter height
 If only the decanter volume is known, assume:
          V.  -  0.30 Va                            '               Equation 5-2
 based on an assumed fill height of 75 percent and an aqueous phase height of 40
 percent of decanter height.
          A similar approach can be used for estimating the volume of solvent
 present, if it is not specifically provided by the submitter. If only decanter volume is
 known, it can be assumed that:
           V,  m  0.45V,                                            Equations*
 based on a fill height of 75 percent, and a solvent height of 60 percent.
 This approach does not apply if the PMN 'chemical is the only major organic.

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                                                     Issued:  February 28, 1991
                                                .     Revised:
                                                     Page No.:  5-10
         Two approaches can be used depending on the constituents:
         The PMN is the only organic present. If the PMN chemical is the only major
         constituent other than water, the amount dissolved  in water is simpfy the
         volume of water times the water solubility of the PMN chemical, which can
         be obtained from ICB if needed.
         PMN chemical, solvent, and water are present.  The preferred method for a
         chemical/solvent/water system is to use the partition coefficient for the
         solvent/water system using Equation 5-4:
                               WL
                                *
                                        WL
                                          *
                                                                            ,
                                                                 Equation 5-4
where:   Wta  =   Weight of substance in aqueous phase, kg
         Wtb  =   Weight of substance in batch to be separated kg
           ^-~- — —~ ^  • ^-~~ - •— ^ .   • " - ,,- "                  x-/ '        '""^"^-•^ -
              = JJartitiorTcdefficlent of substance inolvent/water, dimensionless
         vT  =•   Volume of solvent phase
         Va   =   Volume of aqueous phase.
This equation is derived from the relationship:
    K    _   Concentration of PMN in Qrg^nic phase
      5W       Concentration of PMN in aqueous phase
                                                                  Equation 5-5
where:
              concentration in organic
                                                    moles/liter
                                           Wt
                                            *
              concentration in aqueous  =    *^v >   moles/liter

          M   =  molecular weight of PMN
          V0   =  Volume of the organic phase
 Partition coefficients may be obtained from ICB.  These may be based on measured
 values or on estimation techniques.  Often, it will not be possible to estimate the

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                                                        Issued:  February 28, 1991
                                                        Revised:
                                                        Page No.: 5-11
coefficient for the specific solvent.  The engineer may be abie to use the octanol/water
partition coefficient for solvents judged similar to octano! by ICB.  if the octanol/water
partition coefficient is not appropriate and the solvent/water coefficient cannot be
determined, the engineer should default to the water solubility of the compound to
calculate the amount dissolved in water. The water solubility alone also can be used
when the PMN chemical is highly soluble in the solvent and only slightly soluble in
water.
     D.   Condensers and Scrubbers
          Condensers and scrubbers may be used as integral parts of chemical
processing or manufacturing operations for product recovery or as air pollution control
devices.  Estimation of control efficiency of the equipment is presented in Section
VII.B.  Chemical release to water is likely to occur from use of condensers and
scrubbers (assuming water is used in the processes).  The following sections discuss
estimation of chemical release to water from  these operations.
          in estimating water release, the engineer should consider volume and
source of the water, water solubility of the chemical, the relative volatility of the
chemical, the presence of organics and their miscibility in water, process conditions
 such as temperature and pressure, the type  of equipment, the process configuration,
 and process variations (i.e., whether the purpose is to remove all the water or to
 evaporate some solvent).
          The relative volatility, «, is the ratio of the distribution coefficients of
 components A and B in the vapor and liquid.  It is a measure of the degree of
 separability of the substances.  Assuming constant relative volatility (over the range of
 rnole fractions being considered) and ideal solutions, or that Raoult's law is valid (the
 equilibrium partial pressure of a constituent is the product of the vapor pressure at the
 temperature and the mole fraction in the liquid), the relative volatility is given by
 Equation 5-6:

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                                                      issued: February 28, 1991
                                                      Revised:
                                                      Page No.:  5-12
                                        P
                                    « . _*                       Equation 5-6
where:   PA  =  Vapor pressure of more volatile component (A)
         PB  =  Vapor pressure of less volatile component (B)
Thus, « can be estimated independently from physical properties.
         1.   Condensers
              Three condenser scenarios are  presented below. The first scenario
involves water and an immiscible chemical. The second involves water and a miscible
chemical.  The third scenario involves a chemical, water, and an organic solvent.  In
the absence of information, it shall be assumed that there is total condensation of the-
overhead and no column ahead of the condenser.  If steam is used as a stripping
agent, the amount of steam used can be added to  the amount of water in the  process.
              a.   Case No. 1
                   Water and an immiscible chemical are present in  a batch,  as is
true of polymerizations yielding water as a byproduct.  If the substances are
completely insoluble, each component exerts its own vapor pressure  expressed by
Equation 5-7:
         PT  =  Pft   +  pe                                        Equation 5-7
The mixture produces a vapor of constant composition until all the  more volatile
component is volatilized. The equilibrium vapor composition of the most volatile
compound, A, may be estimated using Raoult's law, Equation 5-8:

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                                                      Issued:  February 28, 1991
                                                      Revised:
                                                      Page No.: 5-13
                                    y  .   A                       Equation 5-8
where:   PA   =   Vapor pressure of compound A
         PT   =   Total pressure
Similarly, the equilibrium vapor pressure of the less volatile component, B, may be
estimated using the relationship,

                                y: =  fl = 1  -yA*                   Equation 5-9
                                 B    D
                                     MT

where:    PB   =   Vapor pressure of compound B
The total weight of the less volatile material driven off can be calculated using Equation
5-10.

                           •    wt  - m* PB MB               '•• Equation 5-10
                                 B"    M.  PA
 where:   WtA  =   Weight of the more volatile component
          WtB  «   Weight of the less volatile component
          MA   =   Molecular weight of the more volatile component
          Ms   =   Molecular weight of the less volatile component
                   An example of the applicability of this method is in the
 manufacture of unsaturated polyester.  The amount of water to be removed can be
 estimated based on stoichiometry.
                   b.   Qa$e No.2
                        When a reaction is carried out in water and no immiscible
 phase is present, the composition  of the condenser overhead and thus the quantity of
 PMN  chemical can be calculated based on a one-plate distillation. The relative

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                                                      Issued:  February 28, 1991
                                                      Revised:
                                                      Page No.: 5-14
volatility and the amount of water to be evaporated must be determined to complete
the calculation.                              .    .  •
                  Assuming constant relative volatility and a binary mixture, one form
of the equation is given in Equation 5-11 0"reybal 1980):

                          ,n  FX? Soc/n£(1 "XF)             Equation 5-11
                             W~X~        W.(1 -Xw)
where:    F   =   Number of moles of the charge of composition X,
          W  =   Number of moles of residual liquid of composition Xw
          Xp  =   Mole fraction in feed
          Xw  =   Mole fraction in residue
          «   =   Relative volatility          .                                   -
 If mole fraction of chemical is to be. used as the basis of the calculation,  then the
 relative volatility must represent the ratio of chemical to water.
                   Typically, the engineer will know the moles of chemical produced
 in a batch and, batch composition. The terms in the denominator are therefore known.
 If the amount of water is not known, 0.1 mole percent can be  assumed. The moles of
 charge and charge composrtion can be determined by a trial and error solution of the
 above equation if the amount of water in the charge has been determined.  If mass
 balance  data are insufficient to determine  this value, it should  be assumed that water
 constitutes 50 percent by weight of the charge.  Once the amount of charge has been
  determined, the amount of chemical lost overhead is the difference between the
  amount  in the charge and the  amount in the residual (product).
                    c.
                         If a PMN chemical (or other chemical of interest), water (other
  than from reaction), and organic solvent are present in the batch, it should be
  assumed that phase separation occurs before batch distillation. The phase separation
  procedures in Section V.C should be used to calculate the amount of PMN going to
  the waste stream, whether organic or aqueous, from the separation.  If the chemical is
  then to be recovered from the aqueous phase by driving water off overhead, the batch

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                                                       Issued: February 28, 1991
                                                   .    Revised:
                                                       Page No.:  5-15
distillation method for binary mixtures should be used to calculate the amount of
chemical lost overhead.
                       Azeotropic mixtures of the solvent and water complicate
estimation because significant amounts of both solvent and water may remain to be
driven off.  In the absence of information to the contrary, it should be assumed that
the water will be separated from the solvent after condensation for subsequent
treatment/disposal and that the solvent is returned to the reactor.  The amount of
chemical lost in the wastewater may be calculated by the phase separation procedure
in Section V.C.
                       When the water solubility of the chemical is low, (or its
partition into the solvent versus water is high), an adequate assumption is that
sufficient chemical will be volatilized to support saturation in the water. That is, the
amount of water driven off and the solubility of the chemical in water will provide an
upper bound estimate of the amount of chemical lost.  The engineer can very roughly
calculate the amount of chemical driven  overhead with solvent to determine the
adequacy  of this assumption.
                   2.    Scrubbers
                        Assuming 100 percent efficiency of the scrubber, the amount
 of chemical released in the effluent can be calculated from distillation equations if there
 is no condenser before the scrubber. The calculation of the amount of material driven
 overhead  is thus the same; the only difference is that the material is scrubbed instead
 of condensed out of the exit gases.
                        If the condenser precedes the scrubber, it Should be
 assumed  all the chemical is condensed (and therefore discharged from the
 condenser) and none reaches the scrubber.  This is based on the assumption that
 total condensation is achieved.
      E.   po-lyelectroivtes
           Polyelectrolytes are used in wastewater treatment operations to remove
  suspended solids. They also may be used as stabilization and strengthening agents

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                                                       Issued: February 28, 1991
                                                       Revised;
                                                       Page No.:  5-16
in pulp and paper manufacture. A polyelectrolyte is either a negatively (anionic) or
positively (cationic) charged polymer chain (CEB 1989b). The ionic nature of these
polymers makes them useful in removing suspended solids from wastewater. They
are added to wastewater to bind with charged solid particles, resulting in neutralized
solids that are subsequently removed from the wastewater by settling, clarification,
filtration, or other means.  Release of the polyelectrolytes to water is likely to occur
from their use in wastewater treatment.  The following, section discusses estimation of
the release of polyeiectrolytes to water from wastewater treatment operations.
         The use of settling, clarification or filtration does not result in 100 percent
removal of suspended solids from wastewater.  Some solids, and thus, some
polyelectrolyte will pass through these treatment systems.  Several studies claim that
99 to 100 percent of the polyelectrolytes added to wastewater is  absorbed onto the  .
solids and  that essentially none is bibavailable through the liquid  phase (CEB 1989b),
Simple analytical methods  cannot detect the presence of polyelectrolytes in  effluent
streams. Thus, there are no definitive data on the amount of-free or bound
polyelectrolytes in wastewater (CEB 1989b).  In the absence of data specific to the
case being evaluated, the following assumptions may be-made:
      *   Polyelectrolyte dose  concentration typically between"!  and  5 ppm.
      . -  Essentially complete absorption of the polyeleetrolyte to solids.
      . •; 90 percent removal of solids from wastewater by clarification (carrying 90
          percent of the dose of polyelectrolyte along);
      .  The remaining 10 percent of the polyelectrolyte (primarily absorbed to
          solids) is carried to a stream, POTW, or to further on-srte treatment.
 The assumption of essentially complete absorption of the .polyelectrolyte-to solids does
 not imply that zero "free" polyelectrolyte leaves the elarifier, nor that the  material is
 permanently bound to the solids. Thus, from the above assumptions, 10 percent of
 the polyelectrolyte dose is released to water or sent to further on-srte treatment. To
 estimate the polyelectrolyte dose, the volume of wastewater generated by the process
 of interest must be estimated or obtained from the submitter. This volume  of
 wastewater generated (daily basis) is then multiplied by the typical dose concentration

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                                                       Issued: February 28, 1991
                                                   .    Revised:
                                                       Page No.:  5-17
(1 to 5 ppm) to calculate the quantity of polyelectrolyte added to the system per day.
This polyelectrolyte daily quantity may then be multiplied by 10 percent to estimate the
quantity of polyelectrolyte (bound or free) in the daily clarifier effluent.  This quantity
may be adjusted to account for further wastewater treatment if applicable.  Use of the
preceding estimation method will provide a reasonable worst case estimate in the
absence of actual  data. Volume II  contains the  CEB document "Pofyelectrolytes" that
presents a more detailed description of polyeiectrolyte use and release to water.
     F.   Mst^l Wgrking Operations
          Cutting fluids are used in metal cutting and finishing operations to lubricate,
cool, and flush the zone of contact between the tool and the workpiece. They also
coat and protect finished surfaces  from corrosion. Cutting fluids include oil-based
systems, miscible  aqueous fluids, and water-based emulsion systems. The choice of  -
cutting fluid is a function of the type of cutting or metal finishing operation, the
intended function  (i.e., cooling, flushing, or lubricating), cost, required surface finish,
quantity required,  and reliability of  the fluid. Types of cutting fluids and chemical
additives are described in "Industrial Process Profiles to Support PMN Review: Metal
Treatment Chemicals" (Walk n.d.).
          The inhouse report "pisposal of Metalworking Fluids" (CEB 1984c) describes
two scenarios developed by CEB to describe potential water releases from small
metalworking shops and from metalworking large shops. These scenarios are
frequently used for PMN cases when the submitter is unable to provide specific details
about use operations.  The following is a summary of the information provided in the
 report.
           Metalworking fluids are generally intended to be recycled within a single
 machine or a central cooling system serving  several machines.  During ust, cutting
 and grinding fluids become contaminated with  metal chips and dirt that must be
 removed continuously or periodically by using strainers, filters, centrifuges, or settling
 tanks. Fluid is lost as. carry-off on the workpieces or by evaporation.  Thus, frequent
 makeup is necessary to maintain the proper fluid concentration for good performance.

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                                                       Issued: February 28,1991
                                                       Revised:
                                                       Page No.:  5-18
 Eventually, the spent fluid must be pumped out and the system cleaned out to be
 refilled with fresh fluid.
          About 80 percent of all metalworking fluids is used in small shops while the
 balance is used in large shops. CEB defines a small shop as  a facility using a single
 machine system. Assuming a capacity of 25 gallons of fluid, a useful life of the cutting
 fluid as 1 to 3 months, and discharge of entire volume after the fluid's useful  life,
 releases of PMN chemical can be estimated based on its expected use concentration.
 CEB describes a large shop as likely to use a large coolant system serving groups of
, machines. Assuming a capacity as large as 24,000 to 80,000 gallons, a useful life of
 about 6 months, and discharge of entire volume after the fluid's useful life, releases of
 PMN chemical can be estimated based on  its expected use concentration.
          Disposal methods vary according to the type of industry the shop  is
 associated with and the size of the shop.  For water-based cutting fluids, small shops
 may discharge to municipal sewer. Wastewater from large shops is likely to be treated
 onsite before discharge.  Treatment  may include oil skimming, settling, neutralization.
 Some shops drum wastes out and dispose of them off-site. Depending on the volume
 of fluid used, spent oil-based fluids may be sold for reclamation or incinerated.
      G.   Filtering Solids From Water
          The major factors governing release to water from separation of a solid
 chemical substance (usually the product) from water through  filtration are its solubility
 in water and the volume of water used. Solubility is affected by temperature, pH,
 presence of dissolved salts or minerals, and presence of dissolved organic matter.
 Thus, it may be controlled by the manufacturer by adding materials such as salts or
 pH adjusters to the water.
           The chemical  release quantity can be determined from solubility data at
 processing temperatures of the filtrate and from the volumes  of water that will be
 directed to filtration operations. The amount of chemical lost to wastewater may be
 estimated from the volume of water used multiplied by the chemical's solubility in.
 water.  This calculation assumes that 100 percent of suspended solids  are filtered from

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                                                       Issued:  February 28, 1991
                                                       Revised:
                                                       Page No.:  5-19
wastewater.  If the necessary data cannot be obtained from the submitter, the
engineer can use the following steps to arrive at an estimate:
         Obtain estimates of water solubility from  ICB. These estimates may be
         based on analogues or standard estimation techniques.
         Estimate volumes of water at:
         -    Filtrate = 2 to 4 times chemical volume
              Rinse water * 2 times chemical volume
         if, based on professional judgment, it is expected that the chemical will be
         salted out (that is, a salt will be added that depresses the solubility of the
         chemical), reduce solubility in filtrate by 90 percent
         Estimate quantity of chemical spilled as 0.05 percent of chemical volume.
     .   Calculate chemical dissolved in filtrate-and rinse water (assuming both are  ;
         appropriate for the scenario).
         The sum of quantities released in rinse water, filtrate, and from spills and
 leakage is the total released to wastewater. Total losses should not be assumed to
 exceed 10 percent of production. This can be used as the upper bound for losses
 based on the  assumption that in the event that losses  exceed 10 percent,  the
 company will take steps such as salting out or cooling to reduce solubility to avoid
 larger losses.
          Additionatlosses can occur when disposing of the filter.  Assume, unless
 otherwise indicated, that this, may occur once every 3 to 6 months, and that up to 0.5
 percent of a batch can be lost to landfill or incineration in this way.
      H.  Spray Coating
          One use scenario which CEB frequently assesses  is industrial spray
 application of coatings.  Since submitters of PMN's frequently do not have much
 information about the operations at potential use sites, CEB  developed a report
 entitled "Generic Engineering  Assessment Spray Coating" (CEB 1987a) that describes
 several generic spray coating scenarios. The report, which is included in Volume II, is
 organized according to the industry of application:  automotive finishing and refmish-

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                                                      Issued:  February 28, 1991
                                                      Revised:
                                                      Page No.:  5-20
ing, wood and metal furniture finishing, large appliance finishing,  railroad car finishing,
light aircraft finishing, and heavy machinery finishing.  For each industry, a.matrix
provides information which can be used to estimate typical usage rate of coating,
coating composition, number of use sites, and transfer efficiencies.
         CFB generally expects releases from overspray.  The percentage of coating
that is  oversprayed is dependent on the spraying atomization technique, the type and
composition of the coating, and the type of substrate.  For spray coating operations
performed in spray booths, the overspray may be removed from air through capture
by a continuous curtain of moving water or by dry filter.
         Water curtains are more likely to be used to control overspray generated in
large scale spray painting operations such as the finishing  of automobiles, appli-
cances, and heavy machinery, Spent water from water wash systems can be a
source of water release if the water is disposed to a POTW or stream.  To estimate the
release of PMN chemical to wastewater, the quantity of PMN chemical in the spent
water must be estimated based on the expected amount of overspray and the capture
efficiency of the curtain. If we do not have this information, we will make worst case
estimates of water releases based on water solubility.  If the PMN chemical is
insoluble, we assume that little remains in the water wash and that the PMN chemical
is disposed of as part of the sludge.  If the PMN is soluble, we estimate the amount
that will remain in the water using the following information (Duff 1985):
          •  '   Spray booths with water curtains typically contain 1,000 to 2,000
               gallons of water.
               The water is dumped out once a week or less frequently (up to once
               yearly) depending on the efficiency of the paint sludge removal.
               Paint sludge is drummed and sent to landfill.
          The engineer should compare this estimated release to the estimated
 amount of overspray as a check to see if the release makes sense (namely, the
 release cannot be greater than the amount of PMN expected in  the overspray).

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                                                       Issued: February 28, 1991
                                                  •     Revised:
                                                       Page No.:  5-21
         For dry booths, we generally assume that the overspray Is disposed of as
part of the dry filter wastes which are likely to be landfilled.
     I.   Leather Dyeing
         Approximately 80 to 90 percent of all leather produced in the U.S. is dyed
(Rutland 1986).  Leather dyeing is performed after leather hides have been tanned with
chrome or vegetable tanning agents, cleaned, defatted, trimmed, shaved, graded,
weighed, split, and tested for quality. The hides are then placed on wooden drum
dyeing wheels.
         Dyeing or coloring of the hides is performed by rotating the dyeing wheels
while dyeing compounds are mechanically,pumped from a bath into the wheel through
an inlet port.  The dye usually consists of a mixture of three different dyes. The
tanneries use a large number of dyes per day; however, only a few dyes are used  in
large quantities (CEB I987c).  Primarily,  acid-based, metal complex dyes are used;
however, direct and solvent-based metal complex dyes are also used in the leather-
dyeing process. These dyes are generally manufactured in the powder form. Acid-
based dyes contain approximately 50 percent active colorant.
          Following dyeing, the spent dye bath solution  is typically discharged to the
plant sewer.  This is followed by rinsing of the hides and subsequent discharge of the
rins'ewater to the sewer.  Fat liquoring is the next step,  It consists  of addition of
chemicals to the hides to replace  the natural oils lost during processing. The spent
fat-liquoring solution is also typically discharged to the plant sewer. The process is
concluded with removal of the hides from the dye wheels followed by drying and
finishing. Finishing consists of buffing, polishing, or other surface treatment
          The main source of  release of PMN chemicals to water is discharge of spent
dye baths to water.  The bath is likely to contain some unexhausted PMN active
colorant. To estimate release of PMN colorant to wastewater from dye baths, the type
of dye, composition of the dye, and approximate quantity of dye used per batch must
be determined.  Also, the degree of uptake or exhaustion of the dye in the bath must
be estimated to determine what percentage of the dye remains in the bath.  If this

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                                                        Issued: February 28, 1991
                                                  .      Revised:
                                                        Page No.:  5-22
information is.not available from the submitter, CEB generally assumes that 10 to 30
kg of PMN active colorant is used per site day for dyeing of grain and suede, respec-
tively, and that the degree of exhaustion of dye onto the leather ranges from 60 to 95
percent (CEB 1987c).
         The document provides expected ranges of values for quantity of dye used
per year at an average tannery, type of dye used, and percent of active colorant in
dyes.  From this information, a water release estimate can  be made. The release
quantity should be adjusted to account for further wastewater treatment if applicable.
The removal  efficiency of the chemical by the designated treatment method can be
estimated using methods outlined in the Water Controls section, Section VILA.
     J.   prilling Operations
          Drilling fluids are essential to oil well drilling operations.  In commercial oil
and gas exploration and production well  drilling, rotary  drilling equipment is generally
used  A rotary bit is attached to and  rotated by a hollow drill through which drilling
fluid is pumped.  The drilling fluid is metered through the bit and subsequently fills the
volume of the hole or drill casing up to the surface.  Upon reaching the surface, the
used drilling  fluid is removed, cleaned, treated, and recycled back to the operation.
          Drilling fluids perform the following functions:  1) lubricate and cool the drill
bit, 2) remove cuttings from beneath the bit to the surface for removal, 3) prevent
formation fluids from flowing out of the formation, 4) coat the well to prevent migration
of fluid into permeable formations, 5)  suspend cuttings when circulation  is interrupted,
and 6) help support the weight of the drill apparatus. They are generally composed of
liquids and suspended solids, and  are either water- or  oil-based.  Water-based fluids
use water as the solids-suspending medium. They are comprised of approximately 70
to 90 percent water by volume, while the remainder consists of additives. Oil-based
fluids are comprised of oil, water, blown asphalt,  and additives.
          Drilling fluid additives include barite, clays,  lignosulfonates, lignites, lime,
 caustic soda, soda ash, silicates, salt, and phosphates. These additives are used to
 control a wide range of fluid properties, including alkalinity, bacteria growth, calcium

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                                                          Issued:  February 28, 1991
                          '           ..                     Revised: November 8, 1991
        ,           .                     .             '     Page No.: 5-23
buildup, corrosion potential, foaming, friction, viscosity, and density. More information
on specific drilling fluid additives is provided in "Drilling Fluids • Environmental Release
Analysis" (CEB 1987d), which is contained in Volume II of this manual. .
          The use of chemical additives in drilling fluids can result in  releases to water.
The major sources of release to water are disposal of spent drilling fluids and produced
water.  Spent drilling fluids or mud is generated during treatment of the drilling fluid.
Water-based drilling fluids are continuously removed from the well, passed through solids
control equipment, and circulated back to the well.  The solids control equipment varies,
but it generally consists of a combination of screens, settling pits, hydrocyclones, and
centrifuges. These control systems remove  sand and silt; however, they generally do not
have the capacity to remove fine particles.
          As drilling fluid recirculates, the concentration of fine particles increases  and
eventually the fluid becomes too viscous for further use. At this  point, a portion of the
fluid (mud) is removed. It is replaced with water and additives in order to adjust the
properties of the fluid for continued  use.  In the case  of oil-based fluids, the spent fluid is
usually sent back to the supplier for reconditioning. For water-based fluids used in on-
shore drilling, the spent fluid or mud is disposed in  mud pits which are covered with dirt
or it is reinjected  into the ground  below the water table (CEB 1987d).  In off-shore
drilling, the drilling mud is usually discharged into the ocean,  provided an oil film is not
left on the water surface (CEB 1987d). Therefore,  it  is likely that an attempt is made to
remove only oil prior to discharge of the  mud to the ocean (CEB 1987d).
          A second potential source of discharge  to water is disposal of produced water.
Produced water is a combination of formation water and drilling fluids, and is the
highest-volume waste source in the oil and gas industry (U.S.  EPA 1985c).  The quantity
of produced water is related to fluid production and varies from site to site. Prior  to
disposal, produced water is sent through  treatment  to remove oil. Disposal is the same
as for drilling mud. For on-shore drilling, produced water is either reinjected into  the
ground or placed in pits. For off-shore drilling, it is disposed to  the ocean, provided that
no oil sheen can be detected on the  water surface.

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                                                         Issued: February 28, 1991
                                                         Revised:  November 8,. 1991
                                                    '     Page No.: 5-24
         Releases of specific chemicals to the ocean from disposal of produced water
and drilling mud can be estimated using the concentration of the chemical in the  mud or
produced water multiplied by the mud or  produced-water discharge rate.  Where PMN
chemical concentration and mud or produced-water discharge rates are not available,
typical data can be used. The document "Drilling Fluids - Environmental Release
Analysis" presents the EPA Generic Drilling Fluids List, which provides concentration
data for eight generic types of mud (as defined by EPA).  This document also provides
drilling fluid discharge rates by geographical location and off-shore produced-water
discharge rates.
     K.  R ecirculating Water-Cooling Towers (Kunz 1977, Perry 1984)
         PMN chemicals are frequently used as water treatment additives in recir-
culating cooling systems to prevent corrosion,  scaling, and growth of microorganisms.   -
Typical concentrations of additives in the  recirculating water are listed  in Table 5-2.
               TKEfE 5-2.   OOCUM3 fOXER AEESTEVEi
                                              Typical  concentration
         :  Type of Additive              _    (gpn) _ ___     •   *
           Scale control                             1 to 5
           Corrosion control.                      50 to 1000
           Microorganism control*                   ^...^?r^

          3 This is a flfM use «nd not generally covered by TSCA.     .
          Source:  Walk (n.d)b.
          CEB typically assumes a recirculation rate of 2,000 gallons per minute (gpm)
for a moderatley-sized tower.  A large cooling system may  have a recirculation rate- of up
to 100,000 gpm.
          Makeup fresh water must be added to the system to replace losses from
evaporation,  entrainment (drift or windage), and blowdown. Releases from a
recirculating  cooling tower are shown in Figure  5-1.

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                       Cooling «««P Circulatiart
Blowdown

tO **K
                                                              Issued:  February 28,1991
                                                              Revised:
                                                              Page No.:  5-25
                                                                     Air
                                                                       TrMtmsnt Ctvwnical*

                                                                       wattr
                        Figure 5-1. Schematic Of Cooling Tower System.

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                                                      Issued:  February 28,1991
                                                      Revised:
                                                      Page No.:  5-26
              Description of Release
              Evaporative losses typically range from 0.5 to 3% of the recirculation
rate.  If the PMN chemical is-non-volatile, the losses of PMN chemical due to
evaporation are expected to be negligible.              ,  -        '
              Evaporation of water causes the nonvolatile materials to accumulate.
To keep the salt concentration at a predetermined level, a small amount of water is
deliberately discarded (biowdown). CEB generally  assumes that blowdown is about
0.5 to 0.6% of the recirculation rate.  Typically, blowdown is sent to either an on-site
treatment plant or POTW.
              Windage losses are a function of the mist eliminator design and
generally range from less than 0,1 to up to 0.2% of the recirculation rate. Some
cooling tower manufacturers warrant as low as 0.008% for windage losses.  In the
absence of other information, CEB assumes windage losses to be 0.1% of the
recirculation rate.
              Calculations
              Assuming that blowdown is equal to 0.6% of the recirculation rate, and
converting to the appropriate units, the water releases are estimated as follows:
                   B - 0.6% x Xr x Rx (5760 x 10~6 min-kg/hr-gat)
      where    B   =  blowdown  (kg/site/day)
               Xf   =  concentration of PMN chemical (ppm)
               R   =  recirculation rate (gpm)
               Assuming that the recirculation rate is 2000 gpm and that releases will
 occur over 360 days/yr, releases to onsite wwt or POTW are estimated as:

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                                                           Issued: February 28, 1991
                                                           Revised:  November 8, 1991
                                                           Page No.: 5-27
                                     B = 0.07 xXr
       where    B   = blowdown (kg/site/day)

                X   = concentration of PMN chemical (ppm)

                R   = recirculation rate (gpm)

                Assuming that windage is equal to 0.1% of the recirculation rate and
  converting to the appropriate units, air releases are estimated as:

                    W = 0.1% x Xf x R x (5760 x 10"6 min-kg/hr-gal)             ,

       where    W   = windage (kg/site/day)

                Xr   ~ concentration of PMN chemical (ppm) .

                R   = recirculation rate (gpm)

                Assuming that the recircuiation  rate is 2000 gpm and that releases will
,  occur over 360 days/yr, releases to atmosphere are estimated as;

                                    W  = 0.012 xXf

       where    W   = windage (kg/site/day)

                X   = concentration of PMN chemical (ppm)

                R   = recirculation rate (gpm)

                Makeup or throughput of the PMN chemical is estimated as the total  of

  the windage and blowdown losses.

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                                                      Issued: February 28, 1991
                                                      Revised:
                                                      Page No:  6-1
VI.   MODELING RELEASE TO AIR
     Air releases can occur from many sources.  Typical sources include process
vents, tank working and breathing  losses, fugitive releases, and secondary sources.  A
vapor generation rate will often have been calculated for some processes and been
used to estimate worker exposure  using the procedures described in Section IV. If a
vapor generation rate was calculated, the estimated release from the process should
be calculated using the same assumptions.  Some  equations presented in Section IV
are also used in this  section with the modification that vapor generation rates are
typically calculated in grams/second and retease is typically calculated in kg/day.
     When a chemical such as a PMN substance is used in low volumes and is of low
volatility, it may not be necessary to quantify release to air.  In these cases a
qualitative estimate should be substituted such as "transfer retease is expected to be
negligible."
     A.  Process	Vents
         Process  vents include the main air exhaust from the manufacturing process
including pressure  relief valves.  The methods that  can  be used to estimate releases to
air from a process  vent  include measurement, mass balance, emission factors,
engineering calculations, or a combination of these methods,
          1,   Measurement
              Measurement is the most straightforward means of estimating releases.
EPA emission test  procedures for  regulated compounds are described in 40 CFR 60,
Appendix A, July 1986,  The pollutant concentration and flow rate from a process vent
during typical operating conditions, if available, can be used to calculate releases.
Total annual releases are based on the plant operating schedule for the year.  The
actual emission rate  is  derived by  making a volume correction to account for the
difference between standard and actual vent gas absolute temperatures. The concen-
tration is then multiplied by the vent gas flow rate.

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                                                      Issued: February 28, 1991
                                                      Revised:
                                                      Page No:  6-2
              This calculation assumes that the measured emissions always
represent the actual emissions. This may not always be the case. Ideally, using a
continuous emission monitor to measure and record releases would provide the most
representative data and therefore a basis for calculating an average concentration.
              Gaseous concentrations also are frequently expressed in parts per
million (ppm) by volume (i.e.) a volume of the constituent in a million volumes  of vent
gas).  In this case, the vent gas volume must be multiplied by the concentration. The
resulting value is divided by the molar volume (adjusted to the vent gas temperature}
and multiplied by the compound's molecular weigh! to obtain the mass emission rate.
              Some vent streams contain large amounts  of water vapor (10 to 20
percent by volume), and the actual vent gas rate includes this volume of vapor.
Concentrations of chemicafs in the gas, however, are frequently  expressed on a dry
basis.  For an accurate release rate, the vent gas rate should be corrected for its
moisture content by multiplying by {1 minus the fraction of water vapor). The  resulting
dry volume can then be multiplied by the chemical's concentration,
         2.   Mass  Balance
              Mass  balance provides a means of accounting for all the inputs and
outputs of chemical in a process.  A mass balance is useful for estimating releases
when measured release data are not available or when other inlet and output  streams
are quantified.  The amounts entering or leaving a process are either measured  or
estimated.  A mass balance can be performed on the process as a whole or on a
subprocess.  Individual operations within the process usually must be evaluated.
         3.   Emission Factors
              A third technique for estimating air releases from  process vents involves
the use of emission factors. One type of emission factor relates a quantity of a
pollutant to some pro cess-related parameter or measurement The amount of
pollutant per quantity of product is frequently used.
              Many air emission factors are expressed in terms of total volatile
organic compounds (VOC)  or particulates rather than a single chemical  compound.

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                                                      Issued:  February 28, 1991
                                                      Revised:
                                                      Page No: 6-3
Emission factors for VOCs are available in "VOC Emission Factors for the NAPAP
Emission Inventory" (USE PA 1986c). These data can be used with actual process vent
measurements of volatile organscs or particuSates to estimate emissions of a specific
compound.  The "Volatile Organic Compound (VOC) Species Data Manual" (USEPA
1980} also provides information on many  air emission sources.  This allows the user to
estimate  releases of specific toxic compounds based on the total amount of VOC's
emitted from a particular source.  Similarly, the "Receptor Model Source Composition
Library" (Carl 1984) provides information relating rnefaSs emissions to total paniculate
emissions for different release sources. Another good source of information is 'Toxic
Air Pollutant Emission Factors - A Compilation for Selected Air Toxic Compounds and
Sources" (USEPA 1988a),
         4.   Engineering CBlculations
              When parameters related to emissions cannot be directly measured,
emissions can be estimated or inferred through engineering calculations or measure-
ment of other secondary parameters (i.e., physical/chemical properties of the  mate-
rials involved, design information on the unit  operation for which the estimate is being
made, or emission information from similar processes). Engineering calculations are
generally used to "fill in" information needed for other emission estimation methods.
              Information derived from equipment design, such as  fan curves, vessel
capacities, operating temperatures* and operating pressures, can be used to estimate
gaseous flow rates.  Physical/chemical information derived from the ideal gas law,
vapor pressure, and equilibrium relationships can frequently be applied when
estimating gaseous concentrations of a particular compound.
      B.   Tank Working and Breathing	Losses
          Releases of chemicals from material handling, storage, and loading  may
result from both breathing and working losses.  Breathing losses are due to vapor
expansion and contraction, which force vapor from a tank  or vessel. Expansion and
contraction are caused by temperature and atmospheric pressure fluctuations.
Working losses occur when the tank or vessel is filled or emptied.

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                                                       Issued;  February 28, 1991
                                                       Revised:
                                                       Page No:  6-4
         These types of releases are generally estimated by using emission factors
and engineering calculations.  The EPA publication AP-42 provides equations for
estimating air emissions from organic liquid storage and handling operations {USEPA
19B5b). These equations contain factors that depend on tank parameters and service
conditions, The CEB engineer should consult Section 4.3 of AP-42 for specific
equations and typical factors to use to calculate working and breathing losses.  More
specific information on  storage tank emissions including example calculations for
horizontal tanks and chemical mixtures can be found in "Estimating Air Toxics Emis-
sions From Organic Liquid Storage Tanks" {USEPA 1988c}.
     C.  Fugitive Releases
         Fugitive emissions are those emissions that are not released through a
stack, chimney, vent, or other confined vent stream. These releases include process
leaks, evaporation from open processes and spills,  and raw material and product
loading and unloading  losses.  Whenever  possible,  fugitive emissions should be
calculated by using data available from direct measurement,
         Fugitive emissions, however, often have to be estimated by using emission
factors or engineering calculations because they are too diffuse or dilute to be
measured directfy, or they are too small relative to the amounts of material processed
to permit the use of mass  balance, This is particularly true of hazardous or toxic air
pollutants.
         One basis for estimating process fugitive  releases is the use of plant air
measurement data or worker exposure estimates provided by the PMN submitter.
Health and safety regulations may require measurements or regulated air pollutant
concentrations on either an absolute or a not-to-exceed basis. These data could
provide a basts for determining fugitive emissions.   Occupational standards them-
selves,  however, should not be used to calculate emissions.  Only actual measure-
ments taken to ensure  compliance with the standards should be used.
         The accepted method of estimating releases from leaks in vessels, pipes,
and valves is to use emission factors.  Various factors are available to estimate

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                                                      Issued:  February 28, 1991
                                                      Revised:
                                                      Page No:  6-5
releases due to leaks in process streams carrying hydrocarbon vapors, light liquids
(more volatile than kerosene, i.e., a vapor pressure greater than 0.1  psia at 100'F), or
heavy liquids  (equal to or less volatile than kerosene).  These factors also can be used
to estimate fugitive emissions in other industries that process hydrocarbon streams.
Table 6-1 presents a summary of average fugitive emission factors in the synthetic
organic chemicals manufacturing  industry (SOCMI).  These data are based on
information from "Emission Factors for  Equipment Leaks of VOC and HAP" (USEPA
1986a). This  report addresses fugitive  emissions and reductions due to scheduled
operation and maintenance procedures.
             TABLE 6-1. AVERAGE FUGITIVE EMISSION FACTORS
                  FOR THE SYNTHETIC ORGANIC CHEMICALS
                   MANUFACTURING INDUSTRY (SQCMl)a'b
Emission factor
Fugitive emission source
Pump seals
Light liquids
Heavy liquids
Valves (in-line)
Gas
Light liquid
Heavy liquid
Gas safety-relief valves
Open-ended lines
Flanges
Sampling connections
Compressor seals
g/s
0.014
0.0059
0.0015
0.002
0.000064
0.029
0.0004?
0.00023
0.0028
0.063
                  These factors take into account a leak frequency determined
                  from field studies in the synthetic organic chemicals
                  manufacturing industry. Light liquids have a vapor pressure
                  greater than 0,1 psia at 10QT.
                 Factors have been converted from ib/h In the original
                source.
                Source; USEPA, 1986a

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                                                     issued:  February 28, 1991
                                                     Revised:
                                                     Page No:  6-6
    D.   Secondary Sources
         Secondary emissions of volatile compounds to the air can occur from the
on-site treatment of aqueous or solid waste. The bulk of secondary emissions are
estimated to result from the handling, pretreatment, and final treatment (primarily
biological treatment) of aqueous wastes,
         Other sources include surface impoundments, landfilling, and incineration of
liquid and solid waste.  Estimating releases of volatile compounds from disposal is
complex and requires detailed knowledge of the compound's parameters and the
disposal procedure.
         Analytical models have been developed by EPA's Office of Air Quality Plan-
ning and Standards (QAQPS) to estimate emissions of volatile organic compounds via
various pathways from emission sources at hazardous waste disposal sites. The
report entitled "Hazardous Waste Treatment, Storage, and Disposal Facilities (TSDF) -
Air Emission Models" (USEPA 1988b) discusses these models.  To make reasonable
estimates of volatile releases, one must know which pathways predominate for a given
chemical, type of waste site, and set of meteorological conditions.  Models have been
developed for the following emission sources:
         Nonaerated impoundments (which include quiescent surface impoundments
         and open-top tanks);
         Aerated impoundments (which include aerated surface impoundments and
         open-top tanks);
         Disposal impoundments (which include nonaerated disposal impoundments);
         Land treatment; and
         Landfills.
         Computerized methods for applying these emission rnodeis are being devel-
oped by EPA.   Models for aerated and nonaerated impoundments, lagoons, landfills,
wastepiies, and land treatment facilities have been installed in an integrated spread-
sheet program, CHEMDAT4, This program allows a user to calculate the partitioning
of volatile compounds among various pathways depending on the particular parame-
ters of the facility of interest.

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                                                      Issued: February 28, 1991
                                                      Revised:
                                                      Page No.:  7-1
VII.  EVALUATING RELEASE CONTROLS
     A.   Water Controls
         1.   Gravity Separation
              Gravity separation is widely used as a waste treatment process for the
removal of settle able solids, oils, grease and other material from water,  Ciarifiers, API
separators, and inclined plate settlers are commonly used for gravity separation.
              For this situation it is necessary to estimate the amount of water used
in cleaning to calculate the amount of chemical dissolved in the water and not readily
separated. The amount of water should be estimated as equivalent to 10 to 100
percent of batch volume ( all material in the batch, not just the chemical under study),
using the higher range for high viscosity materials in multi-component systems (i.e.,
several pieces of equipment). The amount of chemical lost in water is then the volume
of water times the water solubility of the material.  Material not dissolved (i.e., amount
available minus amount dissolved) should be assumed to be incinerated or landfilled
after separation. This estimation method ignores variation of chemical solubility in
water, which may vary with temperature, pH» and the presence of dissolved salts and
minerals.  In addition, the method is based on the assumption that 100 percent of the
suspended solids are removed during filtration or settling, resulting in a release of
dissolved solids only.  For liquid/liquid systems, the method does not consider
formation of emulsions, Although this method does not describe actual systems, it
provides an order of magnitude estimate in the absence of specific data.
              This approach should be used whenever immiscible materials are
washed from equipment and subsequently removed from rinsewater prior to waste-
water treatment or discharge (other than in a large holding pond in which dilution may
 be assumed sufficient to dissolve most of the chemical).
          2.   Carbon adsorption
              Carbon adsorption is a physical separation process in which organic
 and inorganic materials are removed from wastewater by the attraction and

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                                                       issued: February 28, 1991
                                                       Revised:
                                                       Page No.:  7-2
accumulation of impurities on the surface of activated carbon. This method is typically
used when a material that is present in concentrations of less than 10 percent is to be
removed from a water stream that is otherwise relatively clean and free of suspended
matter,  Activated carbon is either added directly to the wastewater stream and subse-
quently filtered out or it is placed in a column through which the wastewater passes.
Carbon  adsorption can be  used as a wastewater treatment  method or for recovering
valuable organics and inorganics from water streams.  In either case, a portion of the
chemicals is likely to remain in wastewater effluent that  may be released to a stream or
POTW.
              Organic chemicals differ widely in their treatability by carbon adsorption.
A survey performed by Troxfer, Parmlee, and Barton (CEB 1984a) resulted in carbon
adsorption removal efficiencies that varied from  42 to 99 percent for a variety of
organic  chemicals.  This report, which is included in Volume II, presents results of the
survey for chemicals that have  been treated on  an experimental level with carbon
adsorption and for chemicals removed in toll-scale treatment operations.  The efficien-
cies presented in the tabies may be used to estimate water releases of the chemicals
that are included in the tabies;  however, for chemicals not included in the survey (e.g.,
new chemicals),  a  different release estimation method must be used.
              To estimate water releases of chemicals not  included in the survey, the
chemical's treatability must first be estimated. Some properties used to assess a
chemical's treatability are molecular weight, structure, polarity, solubility, and water
conditions {pH and temperature). If adequate information is available, an assessment
of the effect of these properties and conditions on a chemical's treatability must be
made by the CEB  engineer.  CEB I984a discusses the effect these parameters have
on treatability. This document  may be used to make reasonable worst case release
estimates for new chemicals.  If a judgment about a new chemical's treatability cannot
be made from available information, data found in CEB 1984a for a similar existing
chemical should be used.

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                                                        Issued: February 28, 1991
                                                        Revised:
                                                        Page No.:  7-3
     8.   Air Controls
         Air pollutants entering an air control device can undergo one or more of the
following:  1) they can be transferred from the air stream to another medium, 2) they
can be modified to a less toxic state, 3} they can be destroyed through combustion or
dissociation, or 4) they can pass through untreated.  The physical characteristics  of
the pollutant to be removed generally determine which type of control device is used.
         Estimates of releases to air must consider the control equipment efficiency.
This efficiency should be based on the amount of pollutant removed from the air inlet
stream of the control device by destruction, modification, or transfer to another
medium.
                                         V     — X
                     Percent efficiency  =  inle!	^1 x  100         Equation 7-1
                                             ^inlet
where:   XinlB1      =   Total mass  of pollutant X flowing to  the air inlet  of the control
                       device in a  given year
         ^ouiiet     =   Totaf mass  °* pollutant X flowing from the air outlet of the
                       control device in a given year
The amount of pollutant transferred to and subsequently released in another medium
(solid or water) must be included in the releases of that particular pollutant in that
medium.
         The best basis for an efficiency estimate is a measurement or test, a mass
balance calculation, or a combination of measurement and mass balance calculations.
if such data are not available, comparison of "controlled" and "uncontrolled" emission
factors for the pollutant (chemical) of concern, engineering calculations, data on the
operation parameters of the control device, or vendor data or guarantees that reflect
actual operating conditions may be used. It is important to use data that reflect
efficiency obtained during typical operations, not the theoretical optimum efficiency.
          fn the absence of typical operating data, treatment efficiency data cited in
the open literature for a similar process may be used as an approximate guide.
Without actual source test data for a specific emission stream and control system, the

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                                                       Revised;
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removal efficiency can be assumed to equal total VOC removal efficiency if the
chemical is volatile organic compound (not a participate, metal, PCB, etc.),
         Typical types of asr release controls include incineration, adsorption,
absorption, condensation, cyclones/mechanical collectors, fabric filters, electrostatic
predpitators, and wet scrubbers.
         1.   Jrjcjn§ration
              Incineration is used to control air release of chemicals that can be
oxidized. Incineration is also used to reduce liquid and solid waste generated in a
process. A discussion of incineration as a control for both air streams and waste
streams is presented in Section VILC.1.
         2.   Adsorption
              In an adsorption process, a pollutant is adsorbed on the surface of the
adsorbent until its capacity is reached.  Common adsorbent materials used are activat-
ed carbon, resins, and molecular sieve  materials. The adsorbent can then be regener-
ated.  The pollutant is released in a more concentrated from, which is recovered or
treated by further processing.  The particular adsorption/regeneration process and the
pollutant and its associated process parameters  determine further processing steps.
These can  include incineration or condensation and decantation so the chemical can
be recovered for recycling or disposal.  Although adsorption is effective in the removal
of various toxic chemicals from air, the  regeneration and further processing steps may
transfer some toxic substance  to water or to solid waste streams, which must be
considered releases to these media.  Typically, the adsorption capacity increases with
the molecular weight of the VOC being adsorbed.  In addition, unsaturated com-
pounds are generally more completely  adsorbed than saturated compounds, and
cyclical compounds are more easily adsorbed than linearly structured materials.  Also,
the adsorption capacity is enhanced by lower operating temperatures and higher
concentrations.  The VOCs characterized by low vapor pressures are more easily
adsorbed than those with high vapor pressures.

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                                                      Revised:
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              In the absence of process specific data, carbon adsorption can be
assumed to have maximum DREs in excess of 50 percent for VOC inlet concentrations
over 200 ppmv, over 95 percent for VOC inlet concentrations over 1,000 ppm,  and
over 99 percent for VOC inlet concentrations over 5,000 ppnw (USEPA 1984).
Adsorption can be used for VOC recovery for relatively small industrial VOC sources.
Commercial adsorption systems are available for small flow rates (several hundred to
tens of thousands cfm) and low VOC concentrations (usuaily several hundred up to
several thousand ppm} (Spivey  1986).
         3,    Absorption
              Absorption as a  method of treating an emission is a physical or chemi-
cal  process that transfers a components from a gas stream to a liquid. Although often
used to recover products or raw materials, absorption also can serve as an emission
control device.  In this capacity, absorption has been used to control alcohols, acids,
chlorinated and fluorinated compounds,  aromatics, esters, and aldehydes (USEPA
1984).  Absorption devices can be used separately or with other air pollution control
equipment (e.g., to provide additional pollutant removal after incineration or condensa-
tion).  Liquids are used as  the absorbent; therefore, a media transfer of toxic pollutants
can occur. Liquid-to-gas ratios, liquid temperature,  and column height are also
important parameters affecting  efficiency.
              In the absence of process specific data, absorption can be assumed  to
have maximum DREs in excess of 90 percent for VOC inlet concentrations over 250
ppmv,  over 95 percent for  VOC inlet concentrations over 500 ppmv, and  over 98 per-
cent for VOC inlet concentrations over 5,000 pprnv  (USEPA 1984).
          4.    Condensation
              Condensation is used as a control technique for some organic
compounds.  It cools the gas stream and transforms the gaseous compound to a
liquid.  Like absorption, condensation is one of the primary techniques used for
product recovery; however, it is also used as an air-pollution control. Control of
storage and process emissions is a common application. Condensers are frequently

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                                                       Revised:
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used in series with other control equipment, including absorbers, incinerators, and
adsorbers.
              In the absence of process specific data, condensation can  be assumed
to have maximum. DREs in excess of 50 percent for VOC inlet concentrations over
500 ppnnv, over 80 percent for VOC inlet concentrations over 2,500 ppmv, and over
95 percent for VOC inlet concentrations over 5,000 ppmv (USEPA 1984),
          5.   Cjctones/'Mechanical Collectors
              Cyclones are seldom used as the sole or primary means of particulate
collection, but they often  serve as "first stage" air-cleaning devices that are followed by
other method of particle collection.  Cyclone collection efficiency is probably more
susceptible to changes in particulate characteristics (i.e., process variation) than are
other types of devices. Therefore, care should be taken in the use of design efficiency
to estimate actual operating  conditions.  Although very little compound-specific collec-
tion data are available, cyclone operation depends on physical parameters (particle
size, density, velocity) as opposed to the chemical nature or properties of the material
being collected.  Thus, within reason, it  may be  possible to obtain and transfer
efficiency data from known applications to unknown applications on processes with
physically similar particulate  and gas flows.
              Cyclones  are good as precieaners removing large particles because of
their inability to capture particles smaller than  5 microns. Removal efficiencies range
between 80 and 99 percent  in a conventional  cyclone for particles greater than
15 microns.  A high-efficiency cyclone will capture particles greater than 5 microns
(Stern 1977),
          6,   Fabric Filters
              When properly designed and operated, fabric filters or baghouses are
efficient collection devices, even for small particles. Vendor information is often a
good source of collection efficiency information, as most units are designed for
specific applications. As is true of cyclones, fabric filter performance is affected by
process variations that affect the gas stream and by other variables such  as

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                                                        Revised:
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temperature and gas dew point. The particle collection mechanisms of these filters
(like those of cyclones)  usually depend solely on physical as opposed to chemical
properties. Thus, data from known applications may be transferable.
              Baghouses can be  used with heavy grain loadings, but should not be
used for oily, hydrascopic, or explosive  dusts. Fabric filters can collect particle sizes
ranging from submicron to several hundred microns in diameter.  Removal efficiencies
are generally greater than 99 percent for particles greater than 1 micron  (Perry and
Green 1984).  Design parameters which affect the removal efficiency include the air-to-
cloth ratio, the inlet particulate concentration, the temperature of the air, and the
physical characteristics  of the  solids being removed,
          7.   Electrostatic Precipitators
              Electrostatic precipitators (ESPs) remove from gas streams particles
that have been electrically charged.  They are not used to collect organic solids
because of combustibility potential.  Efficiency data are limited except for ESPs applied
to combustion processes. The collection efficiency of an ESP depends on the
physical characteristics of the  particulate and the gas stream, and on the electrical
resistivity of the pollutant to be collected.  Electrical resistivity, in turn, can be affected
by temperature, which may vary in some processes.
              Theoretically, there is no minimum limit to the size of the particles that
can be collected by an  ESP.   High-efficiency ESPs have efficiencies greater than 90
percent for particles in the 0.1- to  10.0-micron range (Stern 1977),  However, the
collection plates must be periodically cleaned in order to maintain a high overall
efficiency, since the resistivity  of the dust cake affects the voltage and corona current,
and thereby the performance  of the precipltator.
          8,   Wet Scrubbers
              Wet scrubbers are  used to collect organic and inorganic particulate
matter and reactive gases. Scrubbers which often use water as the scrubbing medi-
um, have the inherent potential of creating releases in the liquid medium. Like some
other  particulate collection equipment devices, scrubber designs are based on

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                                                       issued:  February 28, 1991
                                                       Revised:
                                                       Page No.: 7-8
physical parameters, so available efficiency data may be transferable. The key factors
in scrubber performance are partide size and scrubber pressure drop.  As shown in
Figure 7-1 for a venturi-type scrubber, a high particle removal efficiency can be
achieved for larger particles and at higher pressure drops across the device (USEPA
1986d).  The removal efficiency of a scrubber in removing gases or vapors depends
on both the  solubility of the gas or vapor in the liquid and the degree of saturation.
Removal efficiency also depends on the contact time between the contaminate in the
gas phase and the surfaces of the liquid phase.
     C.    Liguid and Solid Waste Controls
          Liquid (nonaqueous) and solid waste (including sludges and slurries) may
be reduced  by incineration, chemical treatment, physical  treatment, recovery/reuse,
and solidification/stabilization.
          1.   incineration
              incineration is one of the most widely used technologies for  hazardous
waste disposal.  Industrial wastes consisting of a PMN chemical fraction are often
incinerated.  These wastes include solvent cleaning/degreasing wastes, distillation and
reactor  bottoms, separator/detergent sludges,  skimmer refuse, waste oils, polymer
wastes, paint/ink sludges, thinners, pesticides/herbicides/insecticides, filter cakes,
and contaminated fiber drums/boxes.
              The quantity of chemical or other chemical of interest released to  air
from  Incineration of waste (containing the chemica!) can  be estimated using the
Destruction  and Removal  Efficiency (ORE) of the incineration device.  The DRE
combines the efficiencies of both the destruction of the organic chemical of interest in
the combustion chamber and, if applicable, the efficiency of the subsequent removal  of
any residual material from the stack effluent using control devices.
              There are four types of incineration devices:  incinerators, flares,
industrial boilers, and process furnaces.  For each of these four types of incineration
there are many variations; however, ail incineration can be grouped into one of the
four types.

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                                                                    Issued:  February 28, 1991

                                                                    Revised:

                                                                    Page No,:  7-9
*
e



I
                         x;x" ^ v^   _v^_>^_^L^^^^	>*
                     0.2
                               0,3   0,4  0-6  0.6 0,7 0.8 0.9 1,0


                                Sin o< Pinicies iAefodynimic Mttn Oi«rn,J,
20     3.0   4.0  5.0
               Figure 7-1.  Venturi scrubber collection efficiencies (USEPA 1986d).

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                                                       Issued:  February 28, 1991
                                                       Revised:
                                                       Page No,: 7-10
              Incinerators are designed for the destruction of materials at high
temperatures.  Incinerators may be thermal or catalytic.  Thermal incinerators rely on
high temperatures, sufficient residence time, and adequate turbulence to insure high
destruction efficiencies.  Catalytic incinerators operate at somewhat lower tempera-
tures as a catalyst promotes the oxidation. Although most VOCs are rapidly oxidized
at temperatures over 1400'F,  some compounds (e.g., haiogenated hydrocarbons)
require higher temperatures.  While destroying one air pollutant, incineration may
create other pollutants that require further treatment for removal from flue gases.  For
example, an incinerator that effectively destroys trichloroethylene may create hydrogen
chloride that must then be removed by flue gas scrubbing.  Flares are used to destroy
purged gaseous organic compounds when it is not economical to recover the heat
value of the gases.  Industrial  boilers are designed to generate steam through
combustion of fossi! fuel and may use hazardous wastes as a supplementary fuel.
Process furnaces are integral components of a manufacturing process and are used
for the recovery of material or energy.
              Typically, the concentration of organics in the incinerator stack gas is
low, resulting in high DREs. The best basis for estimating efficiency is actual measure-
ment, which in PMN scenarios is unlikely, or the use of data that reflect typical
efficiency during similar operations.
              EPA compiled efficiency data for three of the four types of incineration
devices from trial burns and other performance tests (CEB 1989a). From these data,
well-operated full  scale incinerators  averaged between 99.994 and 99.99997 percent
ORE, Boiler data averaged between 99.98 to 99.999 percent ORE. Data compiled for
process kilns ranged from an  average of 99.2 to 99.998 percent ORE,  The ORE
averages are difficult to interpret for PMN chemicals since trial burns occur under
steady-state conditions and the actual ORE is dependent on the concentration and
chemical class. These averages may be used for well-operated incineration devices.
A ORE of 99 percent is suggested for release estimation to represent a worst case
estimate.

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                                                        Issued;  February 28, 1991
                                                        Revised:
                                                        Page No.: 7-11
              Although flaring is widely used, information on the ORE for flares is
limited .  A 98 percent ORE can be achieved for flares provided they operate under the
conditions listed in Table 7-1.

         TABLE 7-1.  OPTIMAL OPERATING CONDITIONS FOR  FLARES

                               Exit velocity, V     Heating value of HT of
              Type of flare _ (ft/sec) _ gas stream" (Btu/scf)
           Steam-assisted          V < 60              HT > 300
                               60 1000
           Non-assisted            V < 60              HT > 200
                               60 < V       b      200 <  HT < 1000
                                  V <  400            HT > 1000
           Air-assisted         V  < V max ^          HT > 300
            Heating value of total gas stream (not just listed chemical).
                             n n 1 n!"! I'M 11
                           T UlU1  ° {n^n or log Vma,fi; = 1424 + 0.0018 H-

           ° VhliK,:?, = 28.54  + 0..0087 HT

           Source: CEB 1989a, 40 CFR 50.18 (July 1966)
               HT should be calculated at conditions of 25 *C (77 *F) and 1
 atmosphere (14.7 psia).  For information on measurement and calculation of operating
 exit velocity and heating value of the gas stream, consult 40 CFR 60.18 (July 1986).
 Flares with values of less than 300 Btu/scf (steam- or air-assisted flares) or 200
 Btu/scf (nonassisted flares) may or may not achieve 98 percent destruction. For
 example, a steam-assisted flare burning a volatile organic compound could be
 considered to have a 98 percent efficiency for that compound rf its exit velocity and
 Btu value of the gas stream were within one of the three operating conditions listed in

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                                                      Issued:  February 28, 1991
                                                      Revised:
                                                      Page No.: 7-12
Table 7-1 for this type of flare.  This would allow an estimate of the control efficiency in
absence of other data for the compound.
              To estimate release from an incineration device, the volume of waste
containing the PMN chemical or chemical of interest must be determined.  Some
typical wastes include spent cleaning solvents, filter cakes, still bottoms, sludges,  and
drum residues. Estimates of waste volume of the material of interest  must be obtained
from the PMJM submitter or from manufacturers of existing chemicals.
              To estimate the  amount of chemical emitted to  air from incineration,
volume  of chemical fed to the incineration  device should be adjusted  with the expected
efficiency. This method provides an order of magnitude estimate only.

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                                                      Issued: February 28, 1991
                                                      Revised:
                                                      Page No.:  8-1
VIII.  REFERENCES
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A. D. Little.  1989. Personal communication with Rosemary Goydan of Arthur D. Little,
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Clement Associates, Inc. 1982.  Methods for Estimating Workplace Exposure to PMN
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Carl, J. E., et a!., 1984.  Receptor Mode! Source Composition Library. EPA-45Q/4-85--
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                                                     issued: February 28, 1991
                                                     Revised:
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CEB,  1987c. Chemical Engineering Branch, Generic Engineering Assessment *
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                                                      Issued:  February 28, 1991
                                                      Revised:
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Mitre, 1985.  The Mitre Corporation, Particulates in the Workplace. Washington, D.C.:
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                                                      Issued:  February 28, 1991
                                                      Revised:
                                                      Page No.: 8-4

PEl Associates, Inc. 1987.  Effectiveness of local Exhaust Ventilation for Drum-Filling
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                                                     Issued: February 28, 1991
                                                     Revised;
                                                     Page No.:  8-5

USEPA. 1980. U.S. Environmental Protection Agency. Volatile Organic Compound
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                                                      Issued:  February 28, 1991
                                                      Revised:
                                                      Page No.: 8-6

Van En et al. 1980, Worker Exposures to Chemical Agents in the Manufacture of
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Journal (41), March 1980, pp. 212-219,

Versar.  1984,  Versar, Inc.  Exposure Assessment for Retention of Chemical Liquids
on Hands.  Washington, D.C.:  Exposure Evaluation  Division,  U.S. Environmental Pro-
tection Agency. Contract 68-01-6271,

Wadden R. A., Franke, J, F,  1985.  Eddy Diffusivities Measured Inside a Ugh! Indus-
trial Building. Poster No. 10? presented at the American Industrial Hygiene Confer-
ence, Las Vegas,  NV.  May 23, 1985.

Wadden, R. A., and Berrafato, L P.  1988.  Predicted vs. Measured Air Emissions of
Volatile Organic From a Simulated  Hazardous Liquid Waste Lagoon. Paper to be pre-
sented at the 18th Annual Mid-Atlantic Industrial Waste Conference.

Walk.  (n.d,)a  Walk, Hayde!, & Associates,  inc.  Industrial Process  Profiles to Support
PMN Review:  Metal Treatment Chemicals.  Washington, D.C.: Office of Toxic Sub-
stances, U.S. Environmental Protection Agency. Contract 68-01-6065.

Walk.  {n,d)b Walk, Haydel, & Associates, Inc. Industrial Process Profiles to Support
PMN Review:  Waste Treatment Chemicals. Washington, D.C,: Office of Toxic Sub-
stances, U.S. Environmental Protection Agency. Contract 68-01-6065,

Williams, T. M.  1980.  Worker Exposures to Chemical Agents in the Manufacture of
Rubber Tires:  Particulates,  American Industrial Hygiene Association Journal (40),
March 1980, pp. 204-211,

Wong, K, F. 1988,  Memo from Kin F. Wong, OTS-ETD to CEB Staff titled  Interpreta-
tion of Nonisolated Intermediates.

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             APPENDIX A






SAMPLE INITIAL REVIEW ENGINEERING REPORT
                 A-l

-------
ENGINEERING REVIEW FORM                                      CBI    Y/N

c-1« , -, ,<-.,                         CE3' Focus Representative:
PMN; I ME.'I	.	                             _________	
PV fkQ'Vf''                    SUBMITTER'	—	—	

MSDS  ~     LABE_ H,              USE:
aloves/goggies/giasses/iocai exhaust ventilation/general mechanical ventilatiorVother.
respirator: air punfymg/arganic vapor/dust/paint mist/supplied air/other	
Health Effects: corrosive/flammable/other		
              irritant to skin/eyes/lungs/mucous membranes 	

TLV/PEL (PMN c-f raw materials)  ...	_	——	
 CRSS:
 Chemical Name/Category
 VP:	torr@25degC   S-H2O:	Phys State: .	
 MW:		 ^ < 500         	 % < 1000
SAT (concerns): Health:	_	—	——	
                 Eco:
 Assumptions:
 Poiution Prevention Considerations:
  EXPOSURE BASED REVIEW
     1) # workers exposed:	
     2) > 100 workers with > 10 mg/day inhalation exposure LJ
     3) (a) > 100 workers w/1-10mg/day for >100days/yr Q
       (b) Routine Dermal Contact: > 250 workers &. > 100 days/yr

  FOCUS
      Date:
      Decision/Comments:
                                        A-2

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 ENGINEERING REV;EW FORM
                                                      CBI   Y/N
 PMN/TME/I
MFG/P ROC/USE
 Site/Location	
 P'ocess Description
                                   Days/yr
 Occupational Exposure
 Total No. of Workers
                         days/yr
 Inhalation; negligible.'vapor/'mist/particulate
         # workers witfi inhalation exposure
Dermai: contact with liquids or solids	
Dermal: contact negligible r^~;
                   Basis
                                   mg/day over
                                           Basis
        _days/yr
                                         % concentration
 Environmental Releases;
 .	kg/site-day WATER over	days/yr from -
 	kg/si:e-day AIR over	days/yr from.
Total.
Total.
kg/yr INCINERATION from
kg/yr LANDFILL/DEEP WELL from
P ROC/USE
 Site/Location   	
 Process Description
                                  Days/yr
                                                   to
 Occupational Exposure
 Total No. of Workers
                         days/yr
 Inhalation: negligible/vapor/mist/particulate
         # workers with inhalation exposure
Dermai: contact with liquids or solids  	
Dermai: contact negligible I   I     Basis  	
                                   mg/day over
                                         Basis
 Environmental Releases:
 	kg/site-day WATER over,
 —          kg/site-day AIR over	
        jdays/yr
                                        % concentration
                         jjays/yr from .
                         . days/yr from.
Total.

Total,
kg/yr INCINERATION from
kg/yr LANDFILL/DEEP WELL from
 Consumer Use? Y/N
.to
                                          A-3

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           APPENDIX B
GUIDELINES FOR COORDINATED ETD PMN
         STANDARD REVIEW
                B-l

-------
Guidelines for Coordinated ETD
      PKN  Standard  Review
          March 1989
       fi-Z

-------
 E .   I n t rodLIC t, i on
      The  following  guidelines  have  been, designed  in response to
 the  increased  resource  constraints  on  ETD  PMN standard Review
 efforts.   Previously,  a member of each Branch prepared a separate
 Branch report  for each  PMH  that  was placed  in Standard Review.
 Consequently, there  was duplication of effort among the Branches.
 The  new review  process  eliminates duplication, draws upon the
 most appropriate expertise  from  each Branch and expedites the
 transfer  of relevant data to the target audience.  These
 guidelines outline not  only each Branch's responsibilities
 during Standard  Review  but  also  discusses Pre-Focus and Focus
 activities in which  the data being  collected for  PMNS can be used
 later  for those  cases that are designated for Standard Review.

 II.  Pre-Focus Activities
A.    ICB
     ICB's pre-Focus"activities  include providing information for
the Chemistry Review and Search  Strategy meeting  (CRSS), at which
all PKN submissions are  evaluated on a chemical basis for
completeness, consistency and accuracy.  The Chemistry Report
generated for CRSS contains the  following information when
available or obtainable:
     i-     Chemical identity, including chemical name, trade
            name, categorical name,  molecular formula, and CAS
            Registry Number;
     ii.     Physicai/chemical properties,  molecular weight,
            production volume and physical state;
     iii.    Associated substances;
                               B-3

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       ~"~7 •     Use  as  listed  in ?MT-r subr.iss i on ;  nn - u ^ t >•• e r --«=•• = - •
              necessary  for  CRSS             '          "


       v.      Chemical struct,;., re information :or ZMD's database
              r' F.., I. A ;


       ''' i .     Analogs ;


       vii.    Pertinent  chemical reactions;


       v i i i ..   Add i 11 or.a 1  i n format i on, i nc lud i ng other uses and


       ix.     References,


       For those* cases that go to focus the "Additional


 Information" section will contain information on possible other


 uses of the  ?l-!N chemical, based on chemical or technical


 feasibility.  The other uses information win be obtained from


 readily available sources,  such as CAS Online and the chemist's


 direct knowledge.  If no information Is available through such


 sources,  other  uses listed  win be based on expert judgement,


 This other  use  information  for the CRSS report is to be


 considered  preliminary information and should only consist of  a


 list of potential other uses that can be gathered relatively


 easily and  should constitute little additional time spent on any

 case,


 3.   CEB


      CEB  will prepare the Initial Engineering Report, addressing


 potential releases  and  exposures  associated with the


manufacturing, processing and  use of the compound.


      The  sections of the engineering report detail manufacturing,


process, and use.   Manufacture  is the method  by which the PMH


chemical  is  produced.   Process  specifies any  operations the PMN
                               B-4

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 chemical  win undergo in becoming  part  of  the end-product.  This

 section will  include to whom  or  to what  types of companies -ihe

 PKK substance will  be sold, concentration  of the PKN chemical in

 the product  and  application techniques.  Use win describe the

 various uses  of  the PMN chemical or the  FMN chemical based

 product including a percentage of  total  production volume

 allocated  to  each use if there will  be more than one use.  Any

 industrial use will also be described in this section.

 C,   RIB

     For all cases identified  at the  Structure Activity Team {SAT)

 meeting with  health and  ecological  concerns of greater than

 "l/l",  RIB win  assess  the reported  production volume to

 determine whether there  is potential for increased growth in the

 use(s)  listed and whether the volume submitted appears reasonable

 or valid.   Those cases that meet the criteria established for

 exposure based review will be evaluated  in accordance with that

 review.  Determination of valid volume will be through the use of

the RIB historical  PMN database, "Herman", and the RIB Volume-Use

Matrix.1
          This RIB^FMN database, "Herman", contains historical
          information, on a per case basis, on variables such as
          the use, substrate, industry and volume of the PMN
          substance.  This data is stored on hard disk (RIB,
          1989).  The RIB Volume-Use Matrix (RIB, 1988a) contains
          a percentage of total population for any given use and
          volume in each cell of the matrix.   Use of the RIB PMN
          Information Program (PIP) (RIB, I988b), a menu driven
          information retrieval system designed for use with
          Herman, in conjunction w;th the Volume Use Matrix will
          provide an accurate assessment of expected volume of a
          particular market.
                             B-5

-------
      The volume information win be collected and — P^.,,,^ ?n ,
                                                   £-- _ ..» O V_ * i -,„, ,w. ,_j, j. j | ,;3
 standardized format on the back of the FOCUS sheet that RIB
 currently draws up for each PHN the Agency receives.  In  case  of
 multiple uses,  the search win be performed on each use code,  at
 the appropriately prorated volume, and separately presented.  In
 cases of too little historical data,  professional judgement will
 determine volume reasonableness at the Focus Meetino.
  III.   FOCUS Meeting
       h,   ICB
       The  ICB representative win  present  the  chemical  identity,
physical/chemical  properties and associated  substances
information.   The  representative will  also present  the  potential
other  uses  listed  In  the  Chemistry Report, as  discussed in
Section II  A,  Pre-Focus Activities,  ICB,
B.  CEB
    The engineering representative win  report  the  initial
engineering assessment of the  PMN.
C.  RIB
    The RIB representative win  discuss  reasonableness  of
reported volume and potential  for  increased volume  of the
reported use, based on the information that has been collected as
discussed in Section XI,  B,  Pre-Focus Activities, RIB.
D.  Initial Review Report
     The chemistry initial review  and the engineering initial
review reports will comprise the ETD Initial Review Report,  The
                               B-6

-------
 Initial  Review will be collated  at  the  FOCUS  meetina  for cases
 placed into standard review.   The  integrated  ETD  Initial Review
 vi11  be  red-dotted and submitted to the  second  floor  CBic room
 for  immediate tracking arid filing.   if  the case is dropped or
 placed into a different review category  (ie.  Exposure-based
 review)  the initial assessments  will be  finalized in  accordance
 with  current procedures for those reviews.

 IV.   Standard Review -  Branch  Reports
      A.   ICB
      The  ICB Standard review report will be 1-2 pages and contain
 the most  pertinent  information to the case.   Standard Review
 information will  include  the PMM #, chemist,  submitter, chemical
 name,  categorical name, chemical structure, and other chemistry
 information that the  chemist deems  pertinent  to the case.
      Additional information on intended use and other use will
 also  be collected at  this  time.  "Intended Use" will  address
 chemical  functionality  (how the  PMH substance works from a
 chemical perspective) especially for those cases in which the
 functionality of the  molecule  is a unique, unusual or complex
 "Other Uses" will be  expanded  if other sources are located that
can enhance  the original  listing developed for CRSS.
      The standard review section of the chemistry report will be
completed no  later than a week before mid-course for  inclusion in
the ETD Standard Review report.
                              B-?

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 3.   CE3
      The CEB standard review will  be  tailored  to  the  specific
 engineering or exposure issues  that arise  as a  result of FOCUS.
 The  CEB standard review will contain  more  extensive information
 on  the particular points addressed in the  Initial Review,
 including intended use.   Information  on  intended  use  win  include
 function and application of  the chemical substance  (e.g.,  fiber-
 react ive dye on cotton)  and  tier distribution.
     The "Intended Use"  information win not reiterate the ICB
 input  but,  rather,  is intended  to  address  aspects of  use
 relevant to the engineering  assessment, which  shall include the
 production  volume of  the PMN chemical  and  formulation
 information.   Thus, while ICB win address the  chemical
 functionality  of  the  substance  in  its  intended  uses,  the
 engineering report  win  deal  with  the  more physical use oriented
 aspects  of  the substance.
     If  preliminary information on chemical substance, volume and
 related  subjects  is necessary for  managerial review of the draft
 CEB report,  the ICB initial  report can be given simultaneously
 for F'fi  purposes,
     The  engineering  report  should be completed and given to the
 ETD lead  branch for coordination no later than a week before mid-
course.   Although, the report win still be completed in the same
time frame  as  before, it  will not  be available  in report form
until the entire  ETD  report  is  submitted to the fourth floor HERD
CBIC room.  However,  exposure and  release estimates will be
                               8-8

-------
 available to other divisions,  as  it  is  assumed  that  the current
 policy of relaying this information  through  personal  contact will
 continue.
 C,   RIB
      The economics section of  each Division  standard  review win
 consist of benefits,  substitutes, and production volume
 verification.   Other  uses  will be dealt with almost  exclusively
 by  ICB.   Only  in rare cases where additional  other use
 information is  requested by HERD or  CCD, will RIB contribute
 additional input on other  uses, specifically  the market
 feasibility of  other  uses.   Production volume verification will
 be  available,  in the  majority  of cases  from  the RIB Focus sheets.
 In  those cases  where  no definitive Information was collected,
 additional RIB  input  Is necessary.
      It  is the  RIB  analyst's responsibility  to retrieve the Focus
 Sheet  (mentioned in II.c.)  from the  RIB files and pass this
 information  along with the  RIB report to orient RIB management
 for review purposes,


V.  Collation of Information for Division Report
    One of the  three  branches on any given case will be elected
as the lead branch,   Lead branch for any case would be determined
by the last number  of the PMH case in review.  If the case ends
with a zero, the  last non-zero digit in the case number, will
then be the determinant.  See the following chart.
                               B-9

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 1,2 or 3                                               JCB



 -' ,5 or 6
                                                        L.HJ3



 7'8 °r 9                                               T-n
                                                        RIB



 For example, for cases P-89-14G7,  P-89-100 arid P-89-6  RIB, ICB



 and CEB would be the lead branches,  respectively.   in  the  event



 of  a consolidated PW ,  or several  cases  that  have  been combined



 because of similar concerns,  the number  of the first case  In  the



 series win determine the lead branch,




      The  analyst from the lead branch win be the  coordinator for



 that particular  case who win collect and  collate  reports  from



 the branches.  The coordinator's job is  solely one of:   (1)



 assuring  consistency of  assumptions  and.  data  in the reports



 (e.g.,  are the intended  uses  listed  by ICB, for the initial



 report  that are  consequently  being used  for the final  report, the



 same  as those that CEB  is assessing  from an exposure




 perspective), most often this will mean  reading the consolidated



 report  for consistency only,  and (2)  physically assembling  (i.e.,



 stapling!)   all  three branch  reports  together  for  one  Division



 package.   The coordinator will not edit  or rearrange information,



 Each branch is responsible, as is currently the policy, for the



 technical  quality  of each report.




     it is  each  analyst's responsibility to insure that all



 information presented in  any  report  is in agreement with the




 information presented in  the  other reports.  Consequently, each



analyst must coordinate with  her/his  branch counterparts on any
                             B-10

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 particular  case  to  insure  that  the  information presented in each



 section  is'consistent  with the  other  two  sections.  One copy of



 each  branch report  will  be due  to the coordinator no later than



 one week before  mid-course.   It  is  expected  that the current



 scheduling  format produced by CCD win be revised to reflect the



 reporting changes proposed here.  The coordinator win submit .the



 collated report  to  the fourth floor CBI room  in HERD.







 VI.   ETD D i s po s i t i on



      ETD Disposition  (Dispo)  will be held according to the



 current  scheduling  routine.   At  Dispo, each analyst will be



 responsible  for  reporting  the salient points of their portion of



 the standard review.   ICB  can use charts prepared for CRSS while



CEB can  either create  overheads  of the process-flow diagrams



present  in  their report or draw  up separate charts.



      If  additional  factors arise as a result of ETD Dispo that



entail additional analysis from one or more branches, the new



information will be incorporated as an addendum by the branch



analyst  responsible for providing more data.

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                                 REFERENCES
Regulator Impacts Branch,  1988a.  Memorandum with Attachment  from  D.
Qzolins, Economics and Technology Division to Anna Coutlakis Chemical  Control
Division,  April,

Regulatory Impacts Branch,  1988b.  "PKN Information Programs  (PIP)  User's
Fanual".  Prepared for Office of Pesticide and Toxic Substances,  U.S.
Environmental Protection Agency.  Prepared by Mathtech,  Inc.   Contract No.
68-02-4240.  June,

Regulatory Impacts Branch,  1989.  Computerized Use Information  on  all  PHNs
Submitted to the Office of Toxic Substances up to FY89.
                                     B-12

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                            APPENDIX C




            SAMPLE PRODUCTION EXPOSURE PROFILE (PEP)
NOTE: Sections I through VIII of the PEP are completed by RIB and ICB
                                c-i

-------
ACRYLOHITRILE
IX.  PROCESS METHODS
A-   Manufacture
     The domestic production volume of acrylonitrile (CAS No. 107-13-1)  in
I98E was 1,170 mi 11 ion kilograms (2,580 million pounds){CMR, 89).  Imports of
acrylonitrile are very small {US. EPA, 89),  Nine companies manufacture
acrylonitrile and four import acrylonitrile, as reported in the TRI data
base.
     The entire production  of acrylonitrile in the United States is obtained
by the ammoxidation of propylene (Kirk-Qtteer, 78a; US, EPA 77a).  Figure 1
presents a  schematic diagram of  this  process.  The process  is based on the
vapor-phase  catalytic air oxidation of propylene and ammonia.   In  this pro-
cess, refinery propylene  (90+ percent),  fertilizer grade ammonia (99.5+
percent), and air are combined  in a fluidized  bed-reactor at a  temperature of
450°C and a  pressure of 2 atm (US EPA, 77a).   The reaction  is catalyzed by a
Sohio developed  catalyst  (50 to  60 percent  bismuth phosphonohydrate on A1203)
which increases  the yield of acrylonitrile  and decreases the production of
acetonitrile and  HCN.
     Owing  to the high  conversion of  propylene to acrylonitrile, a once
 through  process  with a  residence time of a  few seconds  is employed
 (Kirfc-Othmer, 78a).  The  heat of reaction is  recovered  in the form of steam.
 Commercially recoverable  quantities  of acetonitrile and hydrogen cyanide  are
 produced as by products.
      The reactor effluent is  cooled  and  scrubbed with  water in  a countercurrent
 absorber.   The absorber off-gas consisting  chiefly  of  nitrogen  is  vented
 while water, acrylonitrile, and byproducts  are removed from the bottom  of the
 absorber and sent to the  acrylonitrile recovery  column.  Crude  acrylonitrile
                                      C-2

-------
            Steam
             Water-
 Catalyst     f	:	=>
_J
Ammonls
    N-—-^
       ^ Re;
xyr	1
                                                ^Scrubbed vent gas
                                                   to atmosphere
                                                  Water
                            Reactor
                                    Absorber
T
 Water
                                                          Recovery
                                                           column
                                                                          Crude
                                                                        acQtonitrito
                                                                        A
                                                                                      Acetonitrile
                                                                                      fractionatar
                                                                                            __ Byproduct HCN to
                                                                                            Storage or disposal
                                                                                                                        Acrylonftrfte

*s

Lights
columr
i
>,
'

T
                                                                                                                       Product
                                                                                                                       column
                                                                                                                Heavy
                                                                                                               impurities
                                Figure 1. Simplified Schematic Diagram of the Production of Acrytonilrito by the
                                  Ammoxidalion of Propylana Using 
-------
and HCM are recovered overhead while water and acetonitrile are removed at
the column bottom.  The crude acrylonitrlle is then sent to the lights  column
for removal of the HCH.  It is then further purified in the product column  to
obtain fiber-grade acrylonitrile by fractionation at atmospheric pressure,
Aqueous wastes can be disposed of by a variety of means including
deep well disposal and incineration.
     Plants are assumed to operate with a 7-day work week, 50 weeks per year.
B.   Manufacture  of Acrylic and Modacrylic Fibers
     An acrylic fiber  is a manufactured fiber-forming long-chain synthetic
polymer composed  of at least  85 wt percent acrylonitrile units  (Kirk-Othmer,
78b).  Modacrylic fibers contain from 35  to 85 mass percent acrylonitrile.
Commercially, modacrylics  contain from 25 to  60 percent of monomers such as
vinyl  chloride or vinylidene  chloride and thus possess a high  degree of flame
resistance.
     Acrylic  copolymers are  generally made by either heterogeneous or  solution
polymerization  (Kirk-Othmer,  78b).   Modacrylics  are made by these  two  methods
plus emulsion polymerization.  Both  batch and continuous processes are used.
Acrylonitrile is  moderately  water  soluble, but the polymer  is  insoluble in
both acrylonitrile  and water.
      In a typical continuous process monomer, comonoroer, water, and initiator
 are fed to a continuously-stirred,  overflow  reactor at atmosphere  pressure
 and a  temperature from 30 to 70°C.   Figure 2  is  a schematic diagram of this
 process.  For modacrylic fibers, a halogen-containing  monomer is usually also
 added to increase the flame  resistance of the polymer.   The  slurry of  polymer,
 water, and unreacted monomer is filtered.  The  polymer is  washed and dried
 while the monomer is recovered from the filtrate and  returned to the reactor.
                                      C-4

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                                 Recovered monomer
  Acrytonitrite
 Gomanomer
       Water
     Catalyst
Chilled water—^
                Polymerization
                   reactor
  Filter/
Monomer
recovery
Washer/
 dryer
Polymer
storage
                                        (water and catalyst)
               Figure 2, Simplified Schematic Diagram of the Production of Acrytte/Modacrylic Fibers
                               by the Continuous Process (Kirk-Othmer, 78b).

-------
Use of monomers containing halogen (modacrylic) introduces certain polymeri-
zation complexities not generally encountered in preparing acrylic polymers.
Their low boiling point (-12CC for vinyl chloride and 38CC for vinylidene
chloride) Riay require pressurized polymerization vessels, and their lower
reactivity requires that an excess be added necessitating that a higher
percentage be recovered for reuse.
     Solution polymerization  is used to prepare acrylic polymers directly in
a form suitable for wet or dry spinning.  Solvents include dimethyl sulfoxide,
dimethylformanide, and aqueous solutions of zinc chloride or various thio-
cyanates.
     Assuming the plants operate  a 7-day work week, 50 weeks per year, acrylic
fibers are manufactured 350 days  per year.
C.   Manufacture of ABS and SAN Resins
     The domestic production  volume of  acrylonitrile-butadiene-styrene (ABS)
copolyrners  (CAS No. 9003-56-9} in 1987  was  572  million kilograms  (1,261
million  pounds)  (USITC-SOC, 88).   The  domestic  production volume  of styrene-
acrylonitrile  (SAN) copolymers (CAS No. 9003-54-7) in  1987 was  95 million
kilograms  (209  million  pounds)  (US1TC-SOC,  88).
      Commercially,  SAN  copolymers are  manufactured by  three  processes:
emulsion,  suspension,  and  continuous mass,  ABS resins are also produced by
three processes:   emulsion, suspension, and bulk.
C.I.   Emulsion Process
      The production of ABS resin  by  the emulsion process  will be  used  at the
 example since  it involves  one more step than  SAN resin.   Figure 3 is a
 schematic  diagram of  the process, which consists of  three distinct poly-
 merizations.  A polybutadiene substrate latex is prepared,  styrene and

-------
Butadfam,
Emulsifiers.
 Initiators,
  Water
n
i
Polybufidten*
 lalnx reactor
                                          Emulsfftors,
                                            Initiators
                                                               Steam
                                      ABS
                                      latex
n

o

>
K
r-JC

O
r**^












\
I

Go
                                       Goagulator
                                                                                                     Water
                                                                                                     wasft
                                                                                                Hof air
Dry main
                                  Figure 3. Schematic Diagram ol (he Production of ABS Resin by Ihe Emultion Process (Kirk-Olhrntr, 78c),

-------
acrylonitrile are grafted onto the polybutadiene substrate, and the styrene-
acrylonltrile copclymer is formed (Kirk-Othmer, 78c).  The latter two
reactions may take place simultaneously in the safne vessel, followed by
blending of the latex.
     The emulsion process usually takes place in a batch reactor at between
5° and  70°C depending on the desired structure of the polymer.  The initiator,
activator, and emulsifier solutions are prepared in separate vessels ar.d
added to the reactor which has been purged of oxygen.  The dimineralized
water and butadiene are then added, the temperature is increased, and the
reaction cycle begins.  Heat of polymerization is removed by use of a water
circulating jacket and the reaction vessel is designed to withstand pressures
up to 145 psi.  Reactors range in capacity from 13 to 30 m3 (3,400-7,900 gal)
and reaction times range from  12  to 24 hours  (Kirk-Qthmer, 78c).
     Styrene and  acrylonitrile are  then grafted on the polybutadiene sub-
strate.  This can be done by  the  addition of  SAN copolymers or with the
formation of the  SAN copolymer in situ.  These reactions are run from 55° to
75°C at atmospheric  pressure  in vessels of up to 20 m3 (5,300  gal)  (Kirk-
Qthmer, 78c),  The reactor  is  heated  and reaction times  range  from  1 to 6
hours.   The  resins are  then  coagulated at elevated temperatures  (80° to
100°C)  to  promote agglomeration of  the resin  particles.  The slurry is then
dewatered  and  dried  in  a  hot air  dryer such as a rotary  fluid-bed  or flash
dryer.   The  dry  resin may  then be pneumatically conveyed to silos.
      The emulsion copolymerization  of SAN  is  similar  to  that described for
ABS except  that  it can  be either  a  batch or continuous process.  The copoly-
merization is  carried out between 70° and  10Q°C.  The copolymer  later may  be
                                     C-8

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used to make ABS or it may be coagulated, washed, and dried to recover the
SAN copolyrners,  Cycle time is about 1 to 3 hours (Kirk-Othmer, 78c).
C.2.  Suspension Process
     Figure 4 presents a schematic diagram of the suspension process.   In
contrast to the emulsion process, the suspension process begins with a poly-
butadiene rubber which is so lightly trosslinked that it is soluble in the
monomers.  It is then heated to 8Q~12Q°C for a period of 2-3 hours with
shearing agitation sufficient to prevent cross!inking and maintain the desired
polymer particle size.  This prepolymer syrup is then transferred to a suspen-
sion reactor where it is dispersed in water with agitation.  The reactor is
heated to 100° to 170°C depending on the initiator used until polymerization
is essentially complete (6 to 8 hours) in a reactor of up to 40 m3 (10,600)
gal and pressures up to 3.5 atm.
     When the batch has reached the desired conversion, it is cooled,  dewatered,
and dried.  This part of the process may be continuous.  Dry beads are stored
in silos prior to compounding.
     The suspension process to produce SAN is similar with copolymerization
carried out at temperatures between 60° and 15CTC.  The polymer spheres
formed are much larger than with the emulsion process which makes dewatering  and
drying easier.
     Plants are assumed to operate with t 7-day work week, 52 weeks per year.

X.   OCCUPATIONAL EXPOSURE AND ENVIRONMENTAL RELEASE
A.   Occupatl..o.naj Exposure
     Acrylonitrile is a colorless liquid in the pure state with a characteristic
odor of  peach  seeds.  Acrylonitrile has a molecular weight of 53, a vapor
pressure of 109 ran Hg at 25°C» and a water solubility of 7.4 percent at 25°C.
                                   C-9

-------
o
 I

o
s
r
Rub
dtssi
tymm
vbbei
C
tor
liver
»(
r
Z>



Pr«j
trw
>
(^ —
C2

1
O
*^^_ .-?
soly^
'iztr




>
r^"
c

1
O
k^__ 	 ^>





\

^Neu

traliza
20^30% Suspensbn
conversion reactor
Hc?f a/r
1 Exhaust
t Cenirffuge X i
x^"^ ^"V 	 	 	 	 	 _,, 1
/ \ ^ inifinfi __^. i
^ J UUuUU ^^ J
~~~~ ^^S,VJJ''

T 	 Dryar -^P
Efftimt
                                                                                                                                    Dry rwsto
                               Figure 4.  Sdwmatfc Diagram of the Production of ABS Resin by the Suspensbn Process (Kirk-Othmor, 78c).

-------
The OSHA Permissible Exposure Limit (PEL)'s 2 ppm (10 ppm ceiling,  15 min),
arsd the N10SH Recommended Exposure Limit (REL) are 1 ppm (8 hr TWA}  and 1C
ppm (15 minute ceiling).  KIOSH recommends that acrylonitn'le be handled as  a
suspected human carcinogen.  The exposure level determined to be Immediately
Dangerous to Life or Health (IDLH) is 4,000 ppm.  The ACGIH Threshold Limit
Value (TLV) is 2 ppm with a skin notation.  According to the NOES Survey
(1981-1983), 61,534 workers were exposed to acrylonitrile.  A breakout of the
number of workers by SIC code from the HOES Survey is given in Table 1.
A.I, Manufacture
     During acrylonitrile manufacture, workers may be exposed to acrylo-
nitrile during sampling, maintenance activities, cleanup of spills,  drumming,
and bulk loading of the final product, transfer of waste off-site for in-
cineration or landfill, and disposal of waste on-site by underground injec-
tion or to land.
     P£I estimates  that approximately 45 workers per plant may be exposed to
acrylonitrile during acrylonitrile manufacture based on the total employees
and total  number of plants reported for SIC 28 in the NOES survey for acrylo-
nitrle.  Due  to the closed nature of the manufacturing process, inhalation
exposures  are expected  to  be  controllable at  or below the OSHA PEL of 2 ppm
although the  use of respirators may be required for some job activities.
Dermal  exposures are expected to  be low,  since the workers are expected to
wear gloves while  handling acrylonitrile  containing products or waste.  It is
also expected  that workers will wear safety glasses or goggles.
A.2. Production of Acrylic/Modacrylic  Fibers  and ABS/SAM Resins
     During  the manufacture  of  acrylic and modacrylic fibers and ABS/SAN
 resins, workers may be  exposed  to acrylonitrile during receipt of the acrylo-
 nitrile in bulk, during transfer  of the acrylonitrile, during maintenance
                                     C-11

-------
TABLE 1.  WORKERS EXPOSED TO ACRYLONITRILE ACCORDING TO THE NOES SURVEY
SIC
15
17
20
22
23
28
30
3?
49
73
75
80
Total
Description
General building contractors
Special trade contractors
Food and kindred products
Textile mill products
Apparel and other textile products
Chemicals and allied products
Rubber and misc. plastics products
Transportation equipment
Electric, gas, and sanitary services
Business services
Auto repair, services, and garages
Health services

Plants
303
282
23
16
47
151
89
7
47
24
485
17

Total
employees
3,233
5,131
1,174
6,265
27,720
6,806
4,991
50
372
2,451
971
	 2^371
61,534
                                C-12

-------
activities on. the acryloni trile storage or transfer lines and during clear- up
of spills of acrylonitrile.  No information was found estimating residual
acrylonitrile monomer in acrylic or modacrylic fibers or ABS/SAN resins.
     PEI estimates that approximately 45 workers per plant may be exposed to
acrylonitrile during the manufacture of acrylic and modacrylic fibers or
ABS/SAN  resins based on the total employees and total number of plants
reported for SIC 28  in the NOES survey for acrylontrile.  Due to the closed
nature of the manufacturing processes, inhalation exposures are expected to
be controllable at or below the OSHA PEL of 2  ppm, although the use of res-
pirators may be required  for some job activities.  Dermal exposures are
expected to be low,  since workers are expected to wear  gloves while handling
acrylontrile.  It  is also expected  that workers will wear safety glasses or
goggles.
A.3  0 S HA Expo sure_Measureren t s
     Table  2 presents a  summary  of  OSHA monitoring data for acrylonitrile.
There was only one  facility where OSHA  took  a  personal  sample for acryloni-
trile.   This was  at  SIC  2283,  yarn  mills-wool, and the  measured values were
0.31 and 0.33 mg/m3. There were  no measurements  by  OSHA at any of  the facil-
 ities  identified  as  acrylonitrile manufacturers  or producers of acrylic and
modacrylic  fibers.   Two  facilities  identifed as  ABS/SAN resin producers,
American Cyanamid and  Sybron  Chemical  had  screen  values reported by OSHA,
 The American Cyanamid  facility had  a screen  value reported of
 0.0 mg/m3 while  the screen measurement for Sybron Chemical was  260  mg/m3  (120
 ppm}.   All  other OSHA measurements  were screen values  and all were  0.0 mg/m1,
 B.    E rs v i ronmenta 1 Release
      Acrylonitrile is a RCRA priority pollutant.   The RCRA waste  number for
 acrylonitrile is U009.   Acrylonitrile is  also regulated under  the  Clean Hater
                                      C-13

-------
   TABLE 2,  OSHA MONITORING DATA FOR ACRYLQNITRILE EXPOSURE VALUE,  fig/m3
   SIC                   JOB TITLE           PERSONAL TWA        SCREEN

Manufacture:                                                None
Production of acrylic and modacrylie fibers;                None
Production of ABS/SAN resins:
     2821                  ---                    —               0
     2821                  —                    ---             260
Other:
     1721                  —                    ---               0
     2263                Spinner                  0,33
                         Spinner                  0,31            - —
     3069                  ---                    —               0
     3079                  -—                    —               0
                                                                    0
     3674                  —                    —               0
                                                                    0
                                                                    0
      6531                   —                    —               0
                                     C-14

-------
Act (307{a/» 311 (bjI, CERCLA (100 Ib reportable quantity) anc the Toxic
Substances Control Act (TSCA, 8s, 8e).  Acrylonitrile Is not regulated at
present by the following EPA Acts:  Clean Air Act, Safe Drinking Water Act,
and FIFRA.  Acrylonitrile is reportable under SARA Title III, Section 313.
The environmental releases for 1987 reported under SARA, Title III, Section
313 are presented in Table 3,
B.I.  HajTijfac_ture of Acryloim'trile
     In Table 3, the companies identified in this PEP as manufacturers in
Section I were separated in the  1987 TRI data base and the reported informa-
tion for  these facilities is presented in Table 3 as acrylonitrile
manufacturers.  All  reported manufacturers were located in the 1987 TR! data
base for  the acrylonitrile manufacture category.  All acrylonitrile
manufacturers identified in the  SRI Directory as manufacturers reported
sizeable  release of  acrylonitrile to air (both fugitive and stack) and to
underground injection.
6.2.  Production of  Aerylie/Nodacrylic Fibers
     SIC  2824 (Synthetic Organic Fibers, except Cellulosic - acrylic fibers)
was used  to define the production of acrylic and roodacrylic fibers.  While
there may be some overlap with other uses, this SIC  seems to be primarily
concentrated in  this use.  Comparison with the SRI Directory of Chemical
Producers (SRI,  86)  resulted  in  the transfer of one  facility from SIC 2821 to
this category.   These  facilities are presented in Table 3 as producers of
acrylic and modacrylic fibers.   All facilities that  produce acrylic and
uiodacrylic  fibers  reported sizeable release of acrylonitrile to air (both
fugitive  and  stack).  Only one  facility  reported a sizeable release or
off-site  transfer to another  media  (underground  injection).
                                    C-15

-------
Table 3. TR! Data for Acrytenitrile.
Cwnpwjy
Manufacturing sites:
AMERICAN CYANAM
BORG WARNER CHE (a*)
BP CHEMICALS -
BP CHEMICALS AM
DUPQNTBEAUMON
GENERAL ELECTRI fab)
MON5ANTQCOMPAN
STAR-GLO«0USTfb)
STERLING CHEMC
Stale

IA
MS
TX
OH
TX
NY
TX
W
TX
SfCoxte

2819
2821
sees
2873
2822
2821
2869
3069
2865
FWM&es, tofy
_F^ta_

i?,ooo
58,439
24,000
K.ooo
8,100

91,000
499
65,000
PrwfcKtfort of actytic a«7 modsraj^fe Jtoers,1
AMERICAN CYANAM
BASFCORPQRATO
OU PONT MAY PIA
QypQNTWAY1«S8
MONSANTOCQMPAN
a
VA
sc
VA
AL
Prt*dt*ftart of MBS/SAN iws/rtt:
AKRON POLYMER P
AKBQN POLYMER P
AMERICAN CYANAM
AMQGQ PERPQfiMAN
BFQQQ0WCHAVQ
BF GOODRICH. LO
BOflS-WARNiRCHE
BQRG-WARNERCHE
DOCK RESWS OOfl
DOWCHEMOL
OOWWOuHCAL
oa«OlEMK*i
ICt RESINS US.
MONSAffTOCOMPAN
MORTON CHEMICAL
MOfiTON THWKOL
OH
OH
CT
X
OH
KY
WV
1
Ml
OH
CA
CT
MA
OH
SC
IL
2824
2824
2824
2821
2824

2821
2821
MM
2821
2821
2821
2821
2821
2821
2821
2821
2821
2821
2821
2821
2821
51,920
25,810
75,000
S.MO
07,000

4,832
25,870
4,509
4,189
1,788
1,700
270,000
13,000

40
10
1,300
10
16,000
499
999
Start

132,000
27,643
11,000
110,000
29.000

160,000
499
39,000

55,971
482,722
249,000
120,000
170,000

68,900

1,387
5,214
49
100,000
870,000
581,000
6
1,700
580
510
22
110,000
499
499
Water

499


499







4»
240





4.138










499


Uwtef.lnj.

1,100,000

730,000
1.900.000
210,000

200,000

41,000

35,712





















Land

499

1,498
499

9,983





499
S
TO








11









Cd-site iransta , b^
POTW

















45,231


4
499
130.000






48

499

Lareflill

9M


1,497
750



499


3.B8Q
24

49i

86

9W
1

3,200







499


irrarwration


61,206
















499
§0,588
499
3?
9,800
5,800

9,083
700
32,000

38,000
499

Water




12,000




























OHwf

























14







Wasfs
Sreatmwt


L
AW
AW
A
AL
AW

A

W

w
W
WL



AW
WL

AW
AW
AW
A
AL
AL
AL
A
AW
AW
AW

-------
Table 3.  TR! Data for Acrylonitrile.
Company
Production of ABS/SAN r
NATIONAL STARCH
NATIONAL STARCH
PARA-CHEW SOUTH
PPG INDUSTRIES,
RECHHOLQ CHEW
ROHM AND HAAS,
AOHM AND HAAS.
mm AND HAAS,
ROHM AND HAAS,
SYBRON CHEMICAL
THESfQQQORlCB
THE DERBY CGMPA
THEDQWCHEMICA
UCAR EMULSION S
LICAR EMULSKJN S
UNION CARBIDE C
UNION CARBIDE C
UNION CARBIDE C
UNIROWLCH£M»C
UNDCAL CHEMICAL
VALCHEM POLYMER
WALSH CHEMICAL
Other:
3M COMPANY
ABCG INDUSTRIES
AIR PRODUCTS &
AIGQ CHEMICALS
ALOO CHEMICAL C
AMERICAN CYANAM
AMERICAN CYANAM
AMERICAN SYNTHE
BASFCORPORATIO
BASFOOHPORATO
BENKBER ELECTS
Stale
sslns (co
SC
It
SC
OH
Oi
KY
CA
TN
PA
NJ
W
MA
Ml
TX
1L
HI
CA
QA
OH
NC
SG
NC

KY
^
KS
IL
TN
WV
NJ
KY
Ml
NC
CA
SIC code
nTj:
2®1
2^1
2821
^
2821
2821
2821
2821
2821
2821
2821
2821
2821
2821
2821
2821
2821
2821
2821
2821
2821
2121

2641
2899
2865
2869
2199
2819
2669
2822
2989
2989
3629
Releases, toyr
ZBjgWws__,

1,339
149
250
499
28.439
270
220
800
1,104
330
530
499
18,198
2
1
2
22
10
24,400
499
499
499


499
4,100
499
999
3,700
108

4,000
4M

Sack

499
71
100
1,100
12,117
160
6
90
499

2
499
9,786
2
8


9
25,000
999
999
499

499

999
499

999
2,238
4
3,700
499

Warer


14
1





499

2

499















499


499


UfKter. Inf.


























499








Land


12





























499


GK-siie irareief, b«Yr
POTW





6
320
5
700



499






10,000
499
499






12






Landfl





230

6





499
f
1



















Inciwralion




499



30






155








499










Waist



































Ottwf











7




114
1
1



499









1.400


Wastfl
troalmwil

AW
W
AW
AL
AW
AW
AW
AW
AW


AW
AW
AS
A
A

A

A

A


A

AW

WS






-------
                                                   Table 3,  TRI Data for Acrytonitriie.
	 Qjmyny
Other (oont,}:
BFQQQORICHCQM
BUCKMANLABORAT
CHEM-FOUR FIRST
COPOLYMER RLBBE
DIXIE CHEMICAL
OU FONT FRONT R
DU PONT PARL1N
DUPQNTSASINE
DUPONTVICTOR1
EXXON CHEMICAL
E»ON CHEMICAL
FAIRPRENE WDUS
GOODYEAR TIRE*
GRAIN PROCESSIN
JETCQCHEMtCALS
LAUREL RUBBER D
LUBRBOL PETROL
MERCK* CO., W
MONSANTQCQMPAN
NALCOCRiMICAL
MATKDMAL STARCH
ORGANIC PIGMENT
PETfiOUTECQHPQ
PPQ MOUSTRES.
QUANTUM CHEM1CA
RHQNE-PQULENC!
ROHM TEC 1C.
SHEREX CHEMICAL
SIGMA CHEMICAL
TEXACO CHEMICAL
TEXAS PETROCHEM
THE DOWCKEM1CA
THE SHERWIN-W1
TRWOLWELLCAB
UNION CARBIDE C
W.R. GRACE ICO
W.RGfiACE/EVAN
Slate

OH
TN
AL
LA
TX
VA
W
TX
TX
W!
NJ
CT
TX
1A
TX
NJ
TX
VA
1A
LA
m
NC
TX
OH
PA
WV
MA
IL
MO
TX
TX
TX
KY
KS
WV
KY
NY
SlCoxte

2868
2899
2869
2822
2S13
2851
3861
2989
20E9
?m
2869
3068
2822
SJOffi
?869
3069
2869
2834
2871
y$f)
2869
2815
2899
2»1
2965
28S9
2851
2643
2868
?869
2S6i
2812
2851
3351
2969
mz
2980
Rflteases, Mf
fu^l'iVH

5,000
1.226
499
2.20)
999
499
1.262
6

1.600
2,000
499
7,600


499
499
410
9.BOO
200
756

499
1,900
499
33,230
499
499
499
3,500
499
49
3,664

26,000
1,900
920
Stack

1,600
499
499
400
3,156

1,985

2
310
380
499
15,890

21
499
1,570
MQ
730,000
200
7,067


1,900
1,540
3.059
499
499
499
550

2
3,664

3,800
3.200
530
Watw













450




2
26





6W









18
8
Under, hij.









92,000





21,000





















Land













499



















2,589

28

Off-silo Irarrstw, to/yr .
POTW

91.000
499


499

5


473





1,304



25

999

9.079

499

495





400,000


LandW


















3.600
310







1.6(30





2.589


1
Indnefalnn







1,648




499



1,996
497,836

394









3,428








Walef






































Ollw














4 AA
100
6,392




















trealmwH

AW

AW
f^. *T
AW










A
lit g>
ws
A W
W
W L



Jt t*J
A W
W




L
L

A
W

(•) Tl»» soytef**! manufaefurefi «re abo in SK 2821 (ABS/SAN mdns),
(b) Thssa fadltes ire not feled as aoytonltrfi mamlatfiiraR In th* SRI Dtoawy d OwmW Produews,

-------
B.3.   Production of ABS/SAJvJRes|ns
     SIC 2821 (Plastics Materials, Synthetic Resins, and Nonvu I can-liable
Elastomers - ABS resins, S.AN resins) was used to define the production of SAN*
and ABS resins.   Two facilities listed in this SIC in the 1987 TRI data base
were also acrylonitrile manufacturers.  These facilities were deleted from
the SAN/ABS resin list and so footnoted in Table 3.  While there may be some
overlap with other uses, the SIC seems to be primarily concentrated in this
use.   Comparison with other information provided by EPA resulted in the
identification of several facilities in SIC 2821 as actually nitrile rubber
producers (US EPA, 88),  These facilities were not deleted as PEI did not
have a complete list of nitrite rubber producers.
     Some release to acrylonitrile to air (both fugitive and stack) was
reported by all  ABS/SAN resin producers but the release estimate is highly
variable between facilities.  Reported air release ranged from 1 pound to
over 1 million pounds per facility.  Release to other media and off-site
transfers is generally low with a few specific exceptions.
8.4.   Other Uses
     Release of acrylonitrile from other facilities follow the same pattern
as for ABS/SAN resin production with almost all reporting release to air but
with the estimate highly variable.  Release to other media and off-site
transfer was generally  low with a few specific exceptions.
     At one  acrylic polymer facility studied for EPA, OAQPS, sources of
acrylonitrile release  included acrylonftrile storage tanks, monomer blend
tanks, monomer feed tanks, monomer recovery strippers, recovered monomer feed
tanks, recovered monomer weight tanks, the equalization basin, filter
emissions and fugitive  emissions  (US EPA, 87).
                                      C-19

-------
     Industrial Process Profiles for Environmental  Use (US  EPA,  77a)  esti-
mated release of 5,0 kg/mg of acrylonitrile product released to  air  from  the
manufacture of acrylonitrile.

XI,  RECOMMENDATIONS FOR ADDITIONAL INFORMATION
     It is likely that additional investigation into both occupational  expo-
sure and environmental release would produce better estimates.   SpecificaHy^
further investigation of the one high screen value at Sybron Chemical may
identify what  the purpose of the screen measurement was and if this  screen
measurement means that there may be exposure of workers to levels of acrylon
itrile above the PEL.
     Categorization of acrylonitrile manufactures by  size and control types
or other factors could help  to  explain differences in releases in the TRI
data base.  Additional investigation into which facilities in SIC's 2821 and
2624 actually  produce  the SAN/ABS  resins and acrylic  fibers would improve
estimates  made in these  categories.  Contact of exceptionally high or low
release estimates could  also help  to identify  the reasons for the variant
estimates.
                                     C-20

-------
                                 REFERENCES
CMR.  1989.  Chemical Profile:  Acrylonitrile.  Chemical Marketing Reporter,
p. 50.  March 6, 1989.

Kirk-Othrner» 78a.  Encyclopedia of Chemical Technology.  Volume 1.
Acrylonitrile.  Wi ley-Interseience.  1978.

Kirk-Qthmer.  78b.  Encyclopedia of Chemical Technology.  Volume i.  Acrylic
and Modacrylic Fibers,  Hiley-Interscience.  1978.

Kirk-Othmer, 78c.  Encyclopedia of Chemical Technology,  Volume 1.
Acrylonitrile Polymers (SAN and A8S}.  Wiley Interscierice.  1978.

SRI.  1988 Directory of Chemical Producers, United Stated.  SRI International
1988.

US EPA,  1977a.  Industrial Process Profiles for Environmental Use:  Chapter
6.  The Industrial Organic Chemicals Industry.  Prepared for the U.S.
Environmental Protection Agency.  Cincinnati, Ohio.  February 1977.

US EPA.  1987,  Assessment of Acrylonitrile Emissions From American Cyanamid
Company, Hilton, Florida.  Prepared for the U.S. Environmental Protection
Agency, Office of Air Quality Planning and Standards, Research Triange Park,
H.C.  Karen  1987.

US EPA.  1988.  A Review of the Acrylonitrile Pilot Program.  Prepared for
the U.S. Environmental Protection AGency, Office of Air Quality Planning and
Standards, Research Triangle  Park, N.C.  February 1988.

US EPA,  1989.  U.S. Environmental Protection Agency, Toxic Chemical Release
Inventory  (TRJ) Data Base.  Washington. D.C.

US ITC-SOC,  88.  U.S. International Trade Commission, Synthetic Organic
Chemicals, United States Production and Sales,  1987.  Washington, D.C.
USITC pub. 2118.
                                   C-21

-------
  APPENDIX D



SAMPLE TR1 DATA
       D-l

-------
               UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                                TOS DC 2O6C
MEMORANDUM

SUBJECT:  Engineering Assessments of ?RI Petiti
                                                           TOXIC suss
                                                ons
FROM:
TO:
           Larry E. Longanecker, Section cfiief
           Chemical Engineering Branch

           CEBStaff
      EB
          is required to prepare a preliminary release assessment
  «,fi?nS.t? deUSt SeCtl°n 313 <*emicals within ab"t 3
 weeks of the initiation of the review period.  Sufficient data
 must De provided to EAB to allow them to complete a orel Jnarv
 exposure assessment one week later.  This memo lays out the tasks
 the  engineer _ should complete with respect to the database for
 1987 suomissions to prepare this report.
 ,h  .          dev^loPed a ^nned database search and report format
 that  should  expeditiously give the engineer the most important
 information  to quickly evaluate before transmittal to EAB
 Essentially,  a table will be printed for releases from the
 facility  (fugitive air,  stack air, water to receiving streams,
 underground  infection,  and on~site land disposal)  and one for
 of, -site  transfers (to POTK, landfill,  incineration,  other water
 treatment, and other treatment).                            water

      o water  to POTW
      o other  off-site transfers

 Each  table will  present:
    O DCN
    o facility name
    o SIC Code  (reports
    o quantity .released
                          listed  in  ascending  SIC  Code  order)
At the end of each table, data on  *  of  sites,  total  release,  and
average release per site will be presented.

   ^  The_engineer will review these  tables to  determine, based on
engineering judgment, whether release numbers  are  reasonable,  A
                             D-2

-------
 column will be provided on the table for the enaineer t
 questionable data such as:                     '

      o low air releases of a volatile;
      o lack of water releases for some facilities in
        where water release is expected;
      o 46,0i0,000 pounds of A12Q3 to POTW.
    l          f nf1based on f««her review of the entire  form,
 calls _ to the facility,  engineering judgement/calculations,  or
 data  in the petition,  enter a reasonable estimate if  necessary
 lhandwriting it on the  table).   A column will  also be included
 for  the engineer to estimate days of release,  if necessary  for
 tne  assessment.                                          J

  _    The engineer will  highlight the largest (or otherwise  most
 nrr^i^f3  rel"s«s  in  each media for  EAB  attention.   since the
 DCN wiK be provided,  it  should  not be  necessary for  CEB to
 provide additional data from the database to EAB (e g^ name of
 POTK,  lat/long).   HoweverT^hoqjIdTKr^hHose ?o  use one  or
 several  of  the  reported values  in a site-specific assessment of
 exposure, the engineer  may be required  to do further  work to
 confirm  the release amount or establish  the  release scenario.

      The printouts will also indicate whether, for example  a
 uty reP°rted on-site  wastewater  treatment.   The  engineer
 should  look  at  these forms in evaluating  whether releases are
 reasonably  reported and,  in  the  case  of water  treatment, whether
    s-hould  evaluate reported efficiencies.
     It should be possible  to search  the database within a couple
of days of assignment.  Work with  the EAB assessor to determine
early which numbers warrant further evaluation on your part.

     Finally, the written report  (not due until a month after the
preliminary assessment} should rely heavily on these tables
Process descriptions, conclusions  about the data, and alternative
estimates made by CEB should be the focus of text.


cc;  William Burch                 Susan Hazen
     Liz En* an                     Bob israei
     Lynn H^lpire                  CEB File; Petitions 300080
                            D-3

-------
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-------
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COLE OISTfJIBUTl 499
CAPITOL CASTING 8510ft
THE ELECTRON CO 51
ITEM INDUSTRIES 999
CERTAIN TEED CO tt<)Q
ECC AMERICA AHS 1455
APEX CHEH1CAL C I® IS
80ROEN, IMC. - £026
MILK SPECIALTIE 2040 499
AMERICAN CRtSTA 2063 499
HOLLY SUGAfi COS 2043 499
AMERICAN CR¥STA 2SJ65 499
AHfRICAN CTtSTA 20&3 499
rtlHH-DAK FARMER 2063
AMERICAM CBYSTA 20*3 499
FfIC CORPOfiATlON 2099
1, MAMRICK IMC. 2211
WEST POIMT PEPP 2211
BCALTH-TEX IMC. 2257 499
HCALTH-TEX INC. 2257 499
THE BIBB CQMPAM 2261
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                     WATER       U IHJ
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                                                                         A

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-------
                      APPENDIX E




INDUSTRIAL PROCESS PROFILES AND OTHER COMPLETED STUDIES
                          E-1

-------
                                                      Issued:  February 28, 1991
                                                      Revised:
 Office of Research and Development (ORD)
Battelte, 1988. Final Report on Biosafety in Large-scale rDNA Processing Facilities.
Volumes 1,2,3,4, Cincinnati, OH: Office of Research and Development, U.S. Environ-
mental Protection Agency, Contract 68-03-3248.

Moskowitz PD, Kalb PD, Lee JC, and Fthenakis VM. 1987. Brookhaven  National
Laboratory, An Environmental Source Book on the Photovollaics Industry. Final
Report. Washington, DC: Office of Research and Development, U.S. Environmental
Protection Agency. Interagency agreement 89931812-01-0.

Brown A, et al. 1985. Southern  Research Institute. Predicting the Effectivenessof
Chemical Protective Clothing: Model and Test Method Development. Draft Report.
Washington, DC: Office of Research and Development, U.S.  Environmental Protection
Agency, Contract 68-03-3113.

JACA Corp/ MITRE Corp, 1985. Preliminary Assessment of Predictive Techniques for
Unit Operations.
      1, Filtration, drying, size reduction, mixing, sampling
      2. Maintenance, cleanup, centrifugation, unloading
      3. Extraction, flaking, agglomeration
      4. Distillation, absorption, flotation, solids transfer
      5. Decantaiion, adsorption
Draft report, Washington, DC: Office of Research and Development. U.S. Environ-
mental Protection Agency. Contracts 68-03-3186 and 68-01-6610.

JACA Corp/ MITRE Corp. 1985. Preliminary Assessment of Predictive Techniques for
Unit Operations.
            1. Alkylation, halogenation, hydrohalogenation,  polymerization
                  diazotization, and cleaning
            2. Arnination, phosgenation, and nitration.
Draft report. Washington, DC: Office of Research and Development. U.S. Environ-
mental Protection Agency.  Contracts 68-03-3186 and 68-01-6610.

Soklow R. 1984. S-Cubed. Paper Productionand Processing-Occupational Exposure
and_Enyjrpnmental	Reje_a_se_Stud_y. Final report. Cincinnati, OH: Office of Research and
Development, U.S. Environmental Protection Agency.   Contract 68-03-3015.

Blackwel! CD, Blackard Al, Stackhouse CW, and Alexander MW. 1983. TRW Energy
Development Group. JJMc^cieJly.^^jl J^^                       Studv. Final
report. Washington, DC: Office of Research and Development, U.S. Environmental
Protection Agency. Contract 88-02-3174.
                                      E-2

-------
                                                     Issued: February 28, 1991
                                                     Revised:
The following series of Industrial Process Profiles for Environmental JUjse has been
issued by ORD:
Chapter                      Title

   1        Introduction
   2        Oil and Gas Production
   3        Petroleum Refining Industry
   4        Carbon Black Industry
   5        Basic Petrochemicals Industry
   6        The Industrial Organic Chemicals Industry
   7        Organic Dyes and Pigments Industry
   8        Pesticides Industry
   9        The Synthetic Rubber Industry
   10       The Plastics and Resins Production Industry
  10a       The Plastics and Resins Processing Industry
  I0b       Plastic Additives
   11        The Synthetic Fiber Industry
   12       The Explosives Industry
   13       Plasticizers Industry
   14       (Not published)
   15       Brine and  Evaporate Chemicals Industry
   16       The Fluorocarbon-Hydrogen Fluoride Industry
   17       The Gypsum and Wallboard Industry
   18       The Lime Industry
   19       The Ctay  Industry
   20       The Mica Industry
   21        The Cement Industry
   22       The Phosphate Rock and Basic Fertilizer
              Materials Industry
   23       Sulfur, Sulfur Oxides and Sulfuric Acids
   24       The Iron and Steel Industry
   25       Primary Aluminum industry
   26       Titanium Industry
   27       The Primary Lead Industry
   28       The Primary Zinc Industry
   29       The Primary Copper Industry
   30       The Electronic Component Manufacturing
              Industry
    Report Number
EPA/600/2-
EPA/600/2-
EPA/600/2-
EPA/600/2-
EPA/600/2-
EPA/600/2-
EPA/600/2-
EPA/600/2-
EPA/600/2-
EPA/600/2-
EPA/600/2-
EPA/600/2-
EPA/600/2-
EPA/600/2-
EPA/600/2-
77/023a
77/023b
77/023C
77/023CJ
77/0236
•77/023f
77/023g
77/023h
77/023I
85/085
85/086
85/087
77/Q23K
77/023!
77/023m
EPA/600/2-77/0230
EPA/600/2-77/023p
EPA/6QQ/2-77/Q23q
EPA/600/2-77/023r
EPA/600/2-77/023S
EPA/600/2-77/023t
EPA/600/2-77/023U
EPA/600/2-77/023V

EPA/600/2-77/023W
EPA/600/2-77/023X
EPA/600/2-77/023y
EPA/600/2-77/023Z
EPA/600/2-80-168
EPA/600/2-80-169
EPA/600/2-80-170
EPA/600/2-83-033
                                     E-3

-------
                                                     Issued: February 28, 1991
                                                     Revised:
Office of Air Quality Planning and Standards

1.  Locating and Estimat^Q:Air::,.ErnjssjQQ§ fr.Q.mjSpurces
    Acrytonitrile
    Carbon Tetrachlorsde
    Chloroform
    Ethyiene Dichforide
    Formaldehyde
    Nickel
    Chromium
    Manganese
    Phosgene
    Epichlorohydrin
    Vinylidene chloride
    Ethylene oxide
    Chlorobenzenes
    Polychbrinated
      Biphenyl's (RGB's)
    Polycyctic Organic
      Matter (ROM's)
    Benzene
    Perchloroethytene and
      Tricloroethylene
    Chromium (Supplement)
    1,3 Butadiene
                       EPA 450/4-
                       EPA 450/4-
                       EPA 450/4-
                       EPA 450/4'
                       EPA 450/4.
                       EPA 450/4-
                       EPA 450/4'
                       EPA 450/4
                       EPA 450/4
                       EPA 450/4
                       EPA 450/4
                       EPA 450/4
                       EPA 450/4
                       EPA 450/4
•84-007a
•84-GQ7b
•84-007C
•84-007d
•84-0076
•84-007f
•84-007g
•84-OG7h
-84-007i
•84-QG7J
-84-007K
•84-007!
-84-007m
-84-QQ7n
                       EPA 450/4-84-007p

                       EPA 450/4-84-007q
                       EPA 450/2-89-013

                       EPA 450/2-89-002
                       EPA 450/2-89-021
Mar 1984
Mar 1984
Mar 1984
Mar 1984
Mar 1984
Mar 1984
July 1984
Sept 1985
Sept 1985
Sept 1985
Sept 1985
Sept 1986
Sept 1986
May 1987

Sept 1987

Mar 1988
Mar 1988

Aug 1989
Dec 1989
      These reports may be useful for estimating releases for existing chemicals.
They contain information concerning chemical/physical properties, overview of
production and uses, amount consumed per end use, major industrial source
categories, process descriptions and flow diagrams, potential emission points,
emission factors, number of sites and facility names, and references for source
sampling and analysis procedures.
 2.
QraanicChernical Manufacturing Vol. 6 through 10: Selected Processes:
.Organic.	Chemical Manufacturing Vol. 6: Selected Processes
PB 81-220550     EPA 450/3-80-0283       Dec 1980

Cyclohexane
Ctorabenzenes
Styrene
                                      E-4

-------
                                                      Issued:  February 28, 1991
                                                      Revised:
Cyclohexanol
Cyciohexanone
Maleic anhydride
Ethytbenzene
Capralacton
Adipic acid

.Organic Chemical Manufacturing VskJLJiiteMgQ' Processes
PB 81-220568     EPA 450/3-80-028b      Dec 1980

Nitrobenzene
Toluene dissocyanate
Dimethyl terephthalate
Phenol
Aniline
Cumene
Crude terephthalic acid
Purified terephthalic acid
Acetone
Linear alkylbenzenes

Organic Chemical Manufacturing Vol. 8: Selected Processes
PB 81-220576     EPA 45Q/3-8Q-Q28C      Dec 1980

Ethylene dichloride
Perchloroethylene by hydrocarbon chlorinolysis process
Fluorocarbons
Trichloroethylene
Chloromethanes by methane chlorination process
ChIoromethanes by methane! hydrochlorination and methyl chloride
       chlorination process
Carbon tetrachloride
1,1,1-Trichloroethane
Perchloroethylene
Vinylidene chloride

Organic Chemical Manufacturing Vol. 9: Selected Processes
PB 81-220584     EPA 450/3-80-028d      Dec 1980

Formaldehyde
Ethylene
Acetaldehyde
Methanol
Ethanol amines
                                      E-5

-------
                                                       Issued:  February 28, 1991
                                                       Revised:

Ethylene oxide
Vinyl acetate
Ethylene glycol

Organic Chemical Manufacturing Vol.10: Selected Processes
PB 81-220592      EPA 450/3-80-028e       Dec 1980

Propyiene oxide
Glycerin and  intermediates (ally! chloride, epichiorohydrin,   acrolein, allyl alcohol)
Chloroprene
Formic acid
Waste sulfuric acid treatment for acid recovery
Acrylonitrile
Acetic anhydride
Acetic acid
Ethyl acetate
Methyl ethyl ketone

      These reports contain industry and process descriptions, process flow
diagrams, emissions data, applicable control systems and impact analysis.


3.    AjMg^Compilation of Air Pollutant Emission	Factors

industries;   External Conbustion Sources,  Solid Waste Disposal, Internal Combustion
             Engine Sources, Evaporative Loss Sources, Chemical Process  Industry,
             Food and Agricultural Industry, Metallurgical Industry, Mineral Products
             industry, Petroleum Industry, Wood Products Industry, Miscellaneous
             Sources.

The futl table of contents appears in AP-42.  The chapters most useful to CEB are:

Chapter 4         Evaporation Loss Sources

      4.1    Dry Cleaning
      4.2   Surface Coating
                   Nonindustria! Surface Coating
                   General Industrial Surface Coating
                   Can  Coating
                   Magnet Wire Coating
                   Other Metal Coating
                   Flat Wood Interior Panel Coating
                   Paper Coating
                   Fabric Coating

                                       E-6

-------
                                                       Issued;  February 28, 1991
                                                       Revised;
                  Automotive and Light-Duty Truck
                        Surface Coating
                  Pressure Sensitive Tape and Label Industry
                  Meta! Coil Surface Coating
                  Large Appliance Surface Coating
                  Metal Furniture Surface Coating
      4.3   Storage of Organic Liquids
      4.4   Transportation and marketing of Petroleum Liquids
      4.5   Cutback Asphalt, Emulsified Asphalt, and Asphalt Cement
      4.6   Solvent Degreasing
      4.7   Waste Solvent Recovery
      4.8   Tank and Drum Cleaning
      4,9   Graphic Arts
      4.10  Commercial/Consumer Solvent Use
      4.11  Textile Fabric Printing
Chapter 5   Chemical Process Industry

      5,1   Adipic Acid
      5.2   Synthetic Ammonia
      5,3   Carbon Black
      5.4   Charcoal
      5.5   Chior-Alkaii
      5.6   Explosives
      5.7   Hydrochloric Acid
      5.8   Hydrofluoric Acid
      5.9   Nitric Acid
      5,10  Paint and Varnish
      5.11  Phosphoric Acid
      5.12  Phthatic Anhydride
      5.13  Plastics
      5.14  Printing Ink
      5.15  Soap and Detergents
      5.16  Sodium Carbonate
      5.17  SuIfuricAcid
      5.18  Sulfur Recovery
      5.19  Synthetic Fibers
      5,20  Synthetic Rubber
      5.21  Terephthalic Acid
      5.22  Lead Atkyl
      5.23  Pharmaceuticals Production
      5.24  Maleic Anhydride
                                      E-7

-------
                                                      Issued:  February 28, 1991
                                                      Revised:

4,     New Source Performance Standard (40 CFR 601

Subpart                       Standards of Performance for -

  D         Fossil-Fuel Fired Steam Generators for Which Construction is
            Commenced After August 17, 1971
  Da        Electric Utility Steam Generating Units for Which Construction is
            Commenced After September 18, 1978
  Db '       Industrial-Commerical-lnstitutional Steam Generating Units
  DC        Small Industrial-Commercial-institutional Steam  Generating Units
  E         incinerators
  F         Portland Cement Plants
  G         Nitric Acid Plants
  H         Sulfuric Acid Plants
  I         Asphalt Concrete Plants
  J         Petroleum Refineries
  K         Storage Vessels for Petroleum Liquids for Which Construction, Recon-
            struction, or Modification Commenced after June 11, 1973 and prior to
            May 19, 1978
  Ka        Storage Vessels for Petroleum Liquids for Which Construction, Recon-
            struction, or Modification
  Kb        Volatile Organic Liquid Storage Vessels (including  Petroleum Liquid
            Storage Vessels) for which Construction, Reconstruction, or Modification
            Commenced after July 23, 1984
  L         Secondary Lead Smelters
  M         Secondary Brass and Bronze Ingot Production Plants
  N         Primary Emissions from Basic Oyxgen Process Furnaces for Which
            Construction is Commenced After June  11, 1973
  Na        Secondary Emissions From Basic Oxygen Process Steetmaking Facilities
            for Which Construction Commenced After January 20, 1983
  O        Sewage Treatment Plants
  P         Primary Copper Smelters
  Q        Primary Zinc Smelters
  R         Primary Lead Smelters
  S         Primary Aluminium Reduction Plants
  J        Phosphate Fertilizer Industry: Wet-Process Phosphoric Acid Plants
  U        Phosphate Fertilizer Industry: Superphosphoric Acid Plants
  V        Phosphate Fertilizer Industry:  Diammonium Phosphate Plants
  W        Phosphate Fertilizer Industry: Triple Superphosphate Plants
  X        Phosphate Fertilizer Industry: Granular Triple Superphosphate Storage
            Facilities
  Y        Coal Preparation Plants
  Z        Ferroalloy Production Facilities
  AA        Steel Plants: Electric Arc Furnaces

                                       E-8

-------
                                                     Issued: February 28, 1991
                                                     Revised;

AAa       Steel Plants:  Electric Arc Furnaces and Argon-Oxygen Decarburization
           Vessels Constructed After August 17, 1983
 BB        Kraft Pufp Mills
 CC        Glass Manufacturing Plants
 DD        Grain Elevators
 EE        Surface Coating of Metal Furniture
 FF        (Reserved)
 GG        Stationary Gas Turbines
 HH        Lime Manufacturing Plants
 KK        Lead-Acid Battery Manufacturing Plants
 LL        Metallic Mineral Processing Plants
 MM       Automobile and Light-Duty Truck Surface Coating Operations
 NN        Phosphate Rock Plants
 PP        Ammonium Sulfale Manufacture
 OO       (Reserved)
 QQ       Graphic Arts Industry: Publication Rotogravure Printing
 RR        Pressure Sensitive Tape and Label Surface Coating Operations
 SS        Industrial Surface Coating:  Large Applicances
 TT        Metal Coil Surface Coating
 UU        Asphalt Processing and Asphalt Roofing Manufacture
 W        Equipment Leaks of VOC in Synthetic Organic Chemicals Manufacturing
           Industry
WW       Beverage Can Surface Coating Industry
 XX        Bulk Gasoline Terminals
AAA       New Residential Wood Heaters
B8B       Rubber Tire Manufacturing Industry
CCC       (Reserved)
ODD       (Reserved)
EEE       (Reserved)
 FFF       Flexible Vinyl and Urethane Coating and Printing
GGG       Equipment Leaks of VOC in Petroleum Refineries
HHH       Synthetic Fiber Production Facilities
  Sit        Volatile Organic Compound Emissions from the Synthetic Organic
           Chemical Manufacturing Industry (SOCMi) Air Oxidation Unit Processes
 JJJ       Petroleum Dry Cleaners
 KKK       Equipment Leaks of VOC From Onshore Natural Gas Processing Plants
 LLL       Onshore Natural Gas Processing: S02 Emissions
MMM      (Revised)
NNN       Volatile Organic Compound Emissions from Synthetic Organic Chemical
           Manufacturing Industry Distillation Operations
OOO      Nonmetallic Mineral Processing Plants
 PPP       Wool Fiberglass Insulation Manufacturing Plants
QQQ      VOC Emissions from Petroleum Refinery Wastewater Systems
 RRR       (Reserved)

                                     E-9

-------
                                                      Issued: February 28, 1991
                                                      Revised:

SSS        Magnetic Tape Coating Facilities
TTT        Industrial Surface Coating:  Surface Coating of Ptastic Parts for Business
            Machines
UUU        (Reserved)
VW        Polymeric Coating of Supporting Substrates Facilities
                                     E-10

-------
                                                      Issued:  February 28, 1991
                                                      Revised:
Office of Toxic Substances (Contractor Reports)
Pace Laboratories. 1989, Evaporation Rates, of Voiatile Liquids. Final Report. Second
Edition. Washington, DC: Office of Toxic Substanes, U.S.Environmental Protecton
Agency. Contract 6S-D8-0112.

PEl Associates.  1939.  .Respirator and Engineering Control Costs.  Washington, D.C.:
Office of Toxic Substances, US EPA.  Contract 68-02-4248.

PEl Associates.  1988.  Effectiveness of Local Exhaust Ventilation for Drum-filling
Operations.  Washington, D.C.:  Office of Toxic Substances, U.S. Environmental
Protection Agency. Contract 68-02-4248.

PEl Associates.  1988.  Releases During.CJejning of Equipment.  Washington, D.C.:
Office of Toxic Substances, U.S. Environmental Protection Agency.  Contract 68-02-
4248.

PEl Associates,  1987.  Exposure Assessment of Acrylates/Methacrylates in Radiation-
cured Applications. Washington, D.C.: Office of Toxic Substances, U.S. Environ-
mental Protection Agency.  Contract 68-02-4248.

MRI. 1986. Occupational Exposures from Bagging and Drumming. Finaf Report. (2
volumes).  Washington,  DC: Office of Toxic Substances, U.S. Environmental Protection
Agency. Contract 68-02-3938.

Myers  WR. 1986. NIOSH. Strategy for Recommending Respirators for_C_o_ntroj_oJ
Exposures to Substances Undergoing Premanufacturjng	Notice Review.  Washington,
DC: Office of Toxic Substances, U.S. Environmental Protection Agency. Contract EPA
DW 75932235.

PEl Associates. 1986. Occupational Exposure andJ-nyjronmental Release Assessment
joLAcryjates / M eth aery I ate s. Washington, DC:  Office of Toxic Substances, U.S.
Environmental Protection Agency. Contract 68-02-4248.

PEl Associates. 1986. Occupational Exposure and Environmental Reiease Assessment
of Diisocvanates. Washington, DC: Office of Toxic Substances, U.S.  Environmental
Protection Agency. Contract 68-02-4248.

PEl Associates. 1986. _CQsLoi Selected Engineering Controls. Washington, DC: Office
of Toxic Substances,  U.S. Environmental  Protection Agency. Contract 68-02-4248.
                                     E-11

-------
                                                      Issued: February 28, 1991
                                                      Revised:

PEI Associates. 1986. Use of Oil Separators in Drum Reconditioning and
TransQOrtation Vessel Cleaning Facilities. Washington, DC: Office of Toxic Substances,
U.S. Environmental Protection Agency. Contract 68-02-4248,

PEI Associates, 1990.  Process Flow Diagram	Users Manual.  Washington B.C.:
Office of Toxic Substances, U.S. Environmental Protection Agency, Contract No. 69-
D8-0112.

Development Planning & Research Associates,Inc. 1985, Generic Assessment of the
Electronics. Industry. Washington, DC: Office of Toxic Substances, U.S. Environmental
Protection Agency. Contract 68-02-3952.

Versar,  1985. An_Oyeryjew of Carbon Adsorption. Washington, DC: Office of Toxic
Substances, U.S. Environmental Protection Agency. Contract 68-02-3968.

Bomberger DC, Brauman SK, and Podoil RT. 1984. Southern  Research institute.
Studies to Support PMN Review: Effectiveness of Protective Gloves. Washington,
DC:Office of Toxic Substances, U.S. Environmental Protection Agency. Contract 68-01-
6016.

MITRE, 1984. information on the Loading and Unloading  of Chemicals Under Nitrogen
Blanketing. Washington, DC: Office of Toxic Substances,  U.S. Environmental Protec-
tion Agency. Contract 68-01-6610.

Versar. 1984. _Bcp_osjjre_Assessment for Retention of CheroMaLyg^uids^n^Handg.
Washington, DC: Office of Toxic Substances, U.S. Environmental Protection Agency,
Contract 68-01-6271,

Dryden FE and Keifer LC. 1983. Walk, Haydel & Associates, Inc. Industriai Process
Profiles to Support PMN Review: Oil Fields Chemicals.  Final report. Washington, DC:
Office of Toxic Substances, U.S. Environmental Protection Agency. Contract 68-01-
6065.

Zak FJ, Melton R, Byeriy J, and Keifer LC. 1983. Walk, Haydel & Associates, Inc.
industrial Process Profiles to Support PMN Review: Lube and Fuel Additives. Final
report. Washington, DC: Office of Toxic Substances, U.S. Environmental Protection
Agency. Contract 68-01-6065.

Gikis B, Fowler, Strauss E, and Boughton R. 1983. SRI Int. Industrial Process Profiles
to Support PMN Review: Printing Inks. Final  report. Washington, DC: Office of Toxic
Substances, U.S. Environmental Protection  Agency. Contract 68-01-6010.
                                      E-12

-------
                                                      issued: February 28, 1991
                                                      Revised:

Westbrook EJ, Schneider P, and Keifer LC,  1983. Walk, Hayde! & Associates, Inc.
.Industrial Process Profiles to Support PMN	Review^MjM Treatment ChemicgSs. Final
report. Washington, DC: Office of Toxic Substances, U.S. Environmental Protection
Agency. Contract 68-01-6065,

Gikis B, Fowler, Connolly E, and Boughton R. 1983. SRI Int. industrial Process Profiles
to Support PMNReyJewi Paints. Varnishes,  and Coatings. Final report. Washington,
DC: Office of Toxic Substances, U.S. Environmental Protection Agency. Contract 68-
01-6016.

Bomberger D,  Ferguson A, Fowler D, et al.  1983. SRI Int. Profile of Release and
Exposure  for Chemicals Used in Processing Qrgs_ajrj^_MiQgrgi£.  Final  report.
Washington, DC: Office of Toxic Substances, U.S. Environmental Protection Agency.
Contract 68-01-6016.

Bomberger D,  Boughton R, Endiich R, et a!. 1983, SRI Int. !ndustrial Process PfofilejQ
Support PMN Review: Filling of Drums and Bags. Draft Report. Washington, DC: Office
of Toxic Substances, U.S. Environmental Protection Agency. Contract 68-01-6016.

Rand J and Dennis R. 1984. GCA Corporation. Textiie and Leather pyejng_gnoM3ye
Manufactyring, and Processing: Occupational Exposures and Environmental Releases
.of Dyestuffs. Finai report (in three volumes). Washington, DC: Office of Toxic
Substances, U.S. Environmental Protection Agency. Contract 68-02-3165.

Keifer L, Dryden FE and Seifert M. 1983. Walk, Haydel & Associates, Inc. Industrial
£ro_£ess_P_rofiles to Support PMN  Review: Water IregimenjJ^ejTTigaJs. Final report.
Washington, DC: Office of Toxic Substances, U.S. Environmental Protection Agency.
Contract 68-01-6065.

Berman DW. 1982. Walk, Clement Associates. Methods for  Estimating Workplace
Exposure  to PMN Substances. Washington, DC: Office of Toxic Substances, U.S.
Environmental Protection Agency. Contract  68-01-6065.

Waik, Haydel & Associates.  1981. .generLc Polymer Study. Final report. Washington,
DC: Office of Toxic Substances, U.S. Environmental Protection Agency. Contract 68-
01-6065.

Clement Associates,  1981. Exposure^najy5isj3fJbe_Fla^           Industry. Rnal
report. Washington, DC: Office of Toxic  Substances, U.S. Environmental Protection
Agency. Contract 68-01-6065.

Clement Associates.  1981. Mathematical Models fQiJEstimating Workplace
Concentration LeveJsLA Literature Review.  Washington, DC:  Office of Toxic
Substances, U.S. Environmental Protection Agency. Contract 68-01-6065.

                                     E-13

-------
                                                      Issued; February 28, 1991
                                                      Revised:
Office of Toxic Substances (In-house Reports)
Vorbach J. Undated. CEB Rejejrcli Project^ Effluent Guideline I.QfQrmatj,QnL__P^rtjt\-
Tank Truck Cleafrir^J3perations. Washington, DC: Office of Toxic Substances, U.S.
Environmental Protection Agency.

Vorbach J. Undated. CEB Research PjQJegLJEffluent .Guideline Information: PartJk
Content of Development Documents Produced by US EPA Office of Water. Industrial
Technology Division. Washington, DC: Office of Toxic Substances, U.S. Environmental
Protection Agency.

Vorbach J. Undated, .CJEB_Research. Project: Effluent Guideline Information: Part C-
Abstract of Final Development Document for Effluent Urnitations, Guidelines, and
Standards for LeatherJLaoning & Finishing Point Source Category. Washington, DC:
Office of Toxic Substances, U.S. Environmental Protection Agency.

Netson, 1990.  Prgcess Flow Diagrams.

Jackson E. 1989.  Polyetectrolytes- Their Application and Estimation of Releases.
Washington, DC: Office of Toxic Substances, U.S. Environmental Protection Agency.
Reilfy B. 1989. Industrial .H^3.nd^us_^Va^teJn^inM3tiQji. Washington, DC: Office of
Toxic Substances, U.S. Environmental Protection Agency.

Franklin K. 1988. Memorandum to CEB Staff from Kathy Franklin concerning Office of
                             ..... Reference List.  Dated April 1, 1988.
Heath G. 1988. Memorandum to CEB Staff from George Heath concerning Textile
Drug Room Monitoring Study (TDRMS). Assessment of Workplace Dust Inhalation
Exposures. Dated February 17, 1988.

Wong K. 1988, Memorandum to CEB Staff from Kin Wong concerning interpretation of
jsSon-lsplated Intermediates.  Dated October 4, 1988.

Reilly B. 1988. Catalogue of Databases. Washington, DC: Office of Toxic Substances,
U.S. Environmental Protection Agency.

Kumar V.  1987. Drilling Fluids: Environmental Release Analysis. Washington, DC:
Office of Toxic Substances, U.S. Environmental Protection Agency.

Macek G. 1987. CEB Research Project: Engineering Standards. Washington, DC:
Office of Toxic Substances, U.S. Environmental Protection Agency.
                                      E-14

-------
                                                     Issued:  February 28, 1991
                                                     Revised:

Rodriguez V, 1987. Generic Engineering Assessment: Spray Coating - Occupational
Exposure and Environmentai Release (Revised October , 1987), Washington, DC:
Office of Toxic Substances, U.S. Environmental Protection Agency.
Vorbach J, 1987, Generic Engineering Assessment: Leather Dyeing-
Exposure and Environmental Release. Washington, DC: Office of Toxic Substances,
U.S. Environmental Protection Agency.

Heath G. 1986. Memorandum to Craig Matthiessen and Larry Longanecker from
George Heath concerning Generic Exposure Assessment- The Dying and Printing of
Textile  Fibers.  Dated November 17, 1986.

Franklin K.  1986. Memorandum to CEB Staff from Kathy Franklin concerning Air
ErQQram Information - CEB Research Project. Dated March 28, 1986.

Wong K. 1985. Disposal of Metalworking Fluids. Washington, DC: Office of Toxic
Substances, U.S. Environmental Protection Agency.

Chafmon M. 1984. Carbon Adsorption Report. Washington, DC: Office of Toxic
Substances, U.S. Environmental Protection Agency.

Heath G, 1984. The Dyeing and Printing of Textile Fibers Relative to Worker Exposure
and Environmental Release. Washington, DC: Office of Toxic Substances, U.S.
Environmental Protection Agency.

Wong K. 1984. Exposure to N-nitrosodiethanolamin_ajQjMa.chine Shops. Washington,
DC: Office of Toxic Substances, U.S. Environmental  Protection Agency.
Wong K. 1984. Exposure to N-nitrosodiethanolamine in
          . Washington, DC: Office of Toxic Substances, U.S. Environmental
Protection Agency.

Wong K, 1983. Zjnc_DiaJkyldrthiophosphates- Industrial Exposure ..... andRele.ase
            Washington, DC: Office of Toxic Substances, U.S. Environmental
Protection Agency.
                                     E-15

-------
                                                     Issued: February 28, 1991
                                                     Revised;
Title III Section 313 Release Reporting Guidance Estimating Releases from:
   Monofiiament Fiber
      Manufacture
   Printing Operations
   Electrodeposition of
      Organic Coatings
   Spray Application of
      Organic Coatings
   Semiconductor Manufacture
   Formulating Aqueous Solutions
   Electroplating Operations
   Textile Dyeing
   Presswood and Laminated
      Wood Products
   Roller, Knife, and Gravure
      Coating Operations
   Paper and Paperboard
      Production
   Leather Tanning and
      Finishing Processes
   Wood Preserving
   Rubber Production and
      Compounding
  Food Processers
EPA 560/4-88-0043   Jan 1988
EPA 560/4-88-004b
EPA 56Q/4-88-004C
EPA 560/4-88-0046
EPA 560/4-88-004!
EPA 56Q/4-88-Q04g
EPA 560/4-88-004h
EPA 560/4-88-004i

EPA 560/4-88-004J

EPA 560/4-88-004k

EPA 56Q/4-88-0Q4I

EPA 560/4-88-004p
EPA 56Q/4-88-OQ4q
Jan 1988
Jan 1988
EPA 560/4-88-004d   Jan 1988
Jan 1988
Mar 1988
Jan 1988
Feb 1988
Mar 1988

Feb 1988

Feb 1988

Feb 1988

Feb 1988
Mar 1988
EPA 560/4-90-014     June 1990
      These reports contain brief descriptions of the industry, identify potential release
points, and model calcualtions for estimating releases.
                                     E-16

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                  APPENDIX F

SUMMARY OF GUIDELINES FOR STATISTICAL ANALYSIS OF
           OCCUPATIONAL EXPOSURE DATA

-------
     The following guidelines are a summary of the report,  "Guidelines  for
Statistical Analysis of Occupational Exposure Data (CEB 1989)".   This
reference should be consulted for the detailed procedure before  any
occupational exposure monitoring data is analyzed.
     The procedure is designed to be used by CEB engineers  with  the assis-
tance of industrial hygienists and statisticians.  The procedures provide a
systematic methodology for performing an occupational exposure assessment
based on the types of data which are most commonly available for such analysis,
Figures 1, 2 and 3 provide a flow diagram of the procedure.
     The methodology is based en dividing the data into three broad types of
occupational exposure data:
     0    Type 1 data consist, of measurements For which all important
          variables are known.  The data consist of studies that contain
          individual measurements and include all backup and ancillary
          information.
     0    Type 2 data consist of measurements where important variables are
          not known but for which assumptions can be made for their estimation.
          The data consist of individual monitoring measurements, but backup
          and ancillary information is  inconsistent,
     0    Type 3 data consist of measurement summaries, anecdotal data, or
          other data for which the  important variables are not known and
          cannot be estimated.  Individual monitoring measurements are
          typically not available.
     Once the data has been classified  into one  of these three types, the
data types are only combined as specifically described in the procedure.
Within  each data type, the variables that are potentially important to worker
exposure  are identified and the data categorized  by three variables.  The
traditional categorization of data  by the industrial hygienist or engineer is
supplemented by statistical analysis of the categorizations.  The goal of the
procedure  to the combination of similar categories producing larger data sets
for  analysis.  Because the size of  the  data set  being analyzed has a large
effect  or  the confidence  that can  be placed in the analysis, this procedure
                                      F-l

-------
 t
ro
                                  NJOSH
                                  Other fodtrml *g#nd#&fofKc#
                                  ST»f» •flienetoj
                                  Trade nmoflaftan.i
                                  ffaws Jn Jruteffy
                                                                                         ©
t ®
Oflftiadala
rveeds
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ktenlly
exposure
variaWas
®
Wartly
uncBrtBWies
and biases




Rank variables
In wiporrjiiri€$
©
S»pof»*9 Typ*
3 data
^
Treal
d.

r ®
TypeS
iia




— >•


C?)
Croala
preliminary
B>tp(55ure malri*



-^


PreKminwy
exposure
malnx
Non-stafe(lc8l
rcp
-------
                                                                                               Definition of
                                                                                               data needs
                                                                                               from Step 3
Preliminary
 exposure
  matrix
   Check for
oonstelency and
reasonabten ess
  Collect
 addilionat
  missing
information
 Estimate
additional
 rrtisstmg
Informaliort
Assess ability to
   m««rt oset
    needs
                                                                                                                                            Yes
Can data
m«e! user
 needs?
                     con»l»l«Tf untta
                                               Treat non-
                                             detected valuo*
                                                     Tfeat
                                                  unoBrtairrtles,
                                                assurr^Mions and
                                                     biases
                                                Sepwala Into
                                              Typa 1 ctafa and
                                                Type ? data
                                     Figure 2. Ftaw diagram for creation of a compteted exposure matrix.

-------
Calculate
descriptive
statistics lor each
primary category
•*^
• 	 ^"
Combtna primary
categories
*te

Present results
Figure 3, Ftow diagram for the statistical analysis of Type 1 and Type 2 data.

-------
allov.s e higher confidence to he placed in the descriptive statistics  produced
by the analysis,
     When analyzing occupational exposure data, the CEB engineer should be
aware of the variability in most monitoring data.  Studies of occupational
exposure are rarely found which are developed based on a statistical  approach
to providing representative information for an individual  facility;  it is
even less likely to find a study which represents a particular industry
subsecto*- or group of facilities.  While random sampling is preferred, "worst-
case sampling" during a 1- to 3- day sampling campaign is common industrial
hygiene practice for compliance with regulatory standards.
     Even in statistically-selected well-done studies, there may be high
variability in the characterization of worker exposure.  Measurements at a
plant made over a period of no more than a few days may be all that are
available to characterize exposures over an entire year or a period of years.
Seasonal variability, interday and intraday variability, and changes in the
process or worker activities can cause the exposure to vary from that measured
on a single day.  Temperature changes can affect evaporation rates, and
seasonal changes in natural ventilation affect exposure.  Sampling methods
and time periods can also vary.  Seldom can all these variables be measured
and accounted  for.  However, if  important variables are identified and quant-
ified,  it is hoped the  influence of less  important variables on the
overall measure of central tendency will  be minimized.  Variables that may
not be  obvious may also arise between plants  in  the same  industry category.
Variables such  as the age of the plant, the age  of the control equipment,
whether the plant, is in e volatile organic compound (VOC) non-attainment
area, and operation and maintenance (O&M) practices at the plant should be
investigated.
      When analyzing sample data, it is  important to understand the sources of
variation in  exposure  sample results  that combine  to  create  the observed
variability  (Patty  1981).  The  size of  the variations  is  a function of both
the  exposure  levels and the  measurement method.  Both  random and systematic
errors  should  be  considered.
      Random  variations  in workplace exposure  levels can  result in intraday
variations,  interday variations, or variations  in  exposures  of different
workers within a  job group or  occupational category (Patty  1981),  Variability

                                      F-5

-------
in the measurement procedure can be caused by random changes In pump flow
rate, collection efficiency, or desorption efficiency.  It is important to
realize that random variation in real workplace exposure levels will usually
exceed measurement procedure variation by a substantial amount, often by
factors of 10 or 20 (Patty 1981),
     Systematic variations in the determinant variables affecting workplace
exposure levels will lead to systematic shifts in the exposure results.
Variability in worker exposure levels include changes in worker job opera-
tions during a work shift or over several days, production process changes,
or control system changes.  Systematic errors in the measurement procedure
can result form mistakes in pump calibration, use of sampling devices at
temperature or altitude substantially different from calibration
conditions, physical or chemical interferences, samples degradation during
storage, internal laboratory errors, and interlaboratory errors (Patty 1981).
These errors may be identified and their effects minimized with use of
quality assurance programs.
     It is also important to ascertain the objectives of the monitoring study
to identify potential biases in the data.  For example, if the objective was
to sample only we!1-controlled facilities, then the results would probably
not represent the exposure in the industry as a whole.  If the monitoring
resulted from worker complaints, then exposures may not represent typical
exposures.  If the monitoring was conducted tc evaluate engineering controls
or as a preliminary screening of exposure, the results may not represent
actual employee exposure.  It is important that all potential variables be
identified and evaluated.
     Once the data have been analyzed, the results must be presented clearly
to allow the user to properly interpret the results.  All  assumptions and
uncertainties associated with the data must be clearly identified.  The
descriptive statistics should be accompanied by graphic presentation of the
data such as probability plots or box-and-whisker plots, where possible.
Finally, the original data used in the analysis should be presented in tabu-
lar form to allow the user to calculate additional statistics when necessary.
                                     F-6

-------
                                 REFERENCES


CER 1989.  Guidelines for Statistical  Analysis of Occupational  Exposure  Data,
Draft Final.  Prepared for the U.S. Environmental Protection Agency,  Chemical
Engineering Branch,  August 19, 1989,

Patty 1981.  Patty, F. A,  Patty's Industrial  Hygiene and Toxicology, 3rd
Edition.  Volumes 1 through 3, General Principles, Statistical  Design and
Data Analysis Requirements.  John Wiley and Sons, New York,  NY, 1981.
                                      F-?

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              APPENDIX G

DERIVATION OF FORMULAS FOR CALCULATION OF
    WORKPLACE AIRBORNE CONCENTRATION
                  S-l

-------
                                 APPENDIX 6

          FORKiiLAS DrRnfED BY, CLEMENT ASSOCIATES FOP CALCULATION OF
     1.   Derivation of Genejra__tipn Rate:

     The simplest form for describing evaporation of a liquid into stagnant

air is (Thibodeaux 1979) ;

                                 M K A (Pc - P)
                             G =
                                      R
where:
     G = vapor generation rate, g/sec
     M = molecular weight, g/g role
     K = mass transfer coefficient, cm/sec
     A = surface area of the liquid, cm2
     Pc= equilibrium vapor pressure, atm
     P = actual partial pressure in the gas phase, atrr
     R = universal gas constant, 82.05 ere3 atm/mol K
    T(  = liquid temperature, °K

For most cases Pc (equilibrium vapor pressure) is much greater than P (actual

partial pressure in the gas phase^ and the equation reduces to:
                                G =  l                  Equation 6-1
                                      R TL
This form is used for determining the vapor generation rate for sampling,

cleaning and maintenance.

     When liquids are transferred, vapors are also generated from the

displacement of saturated vapors in the vessel while the liquid is filling

it.  The volumetric  rate at which saturated air is displaced may be expressed

as V r.  If this is  put into  the same form as above to describe the rate at

which material enters the gas phase during filling, then:

                               H V P° r   M K A P°
                               3600  R TL     R TL        Equation G-?
where:
      V      •  fill  volume,  cm3
      r  =  duration  of  filling operation
                                      G-2

-------
The equation accounts for both evaporation and displacement generation.
Usu?.Tly evaporation is much lower than displacement end can be ignored  during
filling.
     The amount of vapors generated by saturation can be affected by the
method In which the material is loaded.  Some vessels are loaded by allowing
the liquid to drop or splash into the vessel and some are loaded by pumping
the liquid in under the surface of the liquid present in the tank.   To  adjust
the generation rate depending on the method of filling, a factor, f is  added
to the equation:
                                    f v v r P
                                G = .LJ_L_r_I               Equation G-3
                                    3600 R TL
where f = 1.0 for splash and 0.5 for subsurface,

     2.  Derivation of Airborne Concentration Formula:
     The most common model for workplace contaminant calculation describes an
overall mass balance of contaminant as it is generated end removed from an
enclosed space:

                               V ~ = G - kCQ           Equation 6-4

where:
         C = airborne contamination,
     dC/dt = the change in concentration over time,
         G = generation rate of the chemical,
         V = room volume,
         K = mixing factor,
         Q = ventilation rate.
If the  generation rate  (G) and ventilation  rate  (Q) are assumed to be
constant, this  equation may be integrated and reduced by assuming that  the
concentration  remains the  same over long periods of time (steady state):

                                  C = G/kQ              Equation G-5
To obtain C  in  ppm, from Q  in cubic feet per minute, and Gin grains per
second, multiply through by R, M, and T:
                                     fi-3

-------
   -    G fg/s} x 82 .OS f a tin-cm3/g-mole Kelvin)  x T  (Kelvin)  x  106

    k x q (ft3/min)  x (min/60 s)  x 2.832  x  ID4  fee/ft3)  x  M  (g/g-mole)

C - U x 105 T G                                  Equation  3
                                                   iRi Section  IV A)
                                  R-4

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                 APPENDIX H




CHART OF BODY AREAS AND ESTIMATION OF SKfN AREA
                     H-l

-------
    TABLE H-1. ESTIMATION OF THE DISTRIBUTION OF SKIN AREA ON AN
              EXPOSED BODY {ASSUMED 1,9 m2 TOTAL AREA}
Body Part
                           Anatomic Model
Area
Head
Neck
Upper arms
Forearms
Hands
Shoulder
Chest
Back
Hips
Thighs
Calves
Feet
Fingers
5.7
1,2
9,7
6,7
6,9
6,8
8.0
8.0
9.1
18.0
13.5
6,4
3.3
0.11
0.023
0.18
0.13
0.13(includes fingers)
0,13
0.15
0.15
0.17
0,34
0.26
0,12
0.083
Source: Anatomic Model - 1976,
                             r^
                l  F°f«- • '-'SP*? !
               ,
              *'*
                  8J% '  97%
             X p*TG*niU« enufi

               fct - (73 ew
               S* - T.S3 ml

N«* ',2%
~N I
4 I i
N r
• t N»J
,' *
/, - A
|'i •(')
\( li
i
ShauJsw 4.IX
JL
              FIGURE H-1, HUMAN DERMAL SURFACE AREA MODELS

3 Derived from mensuration formula and anatomic dimensions. Each percentage
corresponds to the proportion of the total surface area(SA) for each location.

Source: Popendorff and Letting well, 1982.
                                  H-2

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                     APPENDIX I




OTHER FACTORS TO BE CONSIDERED IN RESPIRATOR SELECTION
                         1-1

-------
                            APPENDIX
     OTHER  FACTORS TO  BE  CONSIDERED IK RESPIRATOR
    In the assessment of workplace exposure  for  ail  new  chemicals




ana often fot existing chemicals,  no OSHA  Permissible  Exposure




Limits (PEL's) or ACGIH Threshold  Limit Values  (TLV's)  have  been




established.  Since  information  about  the  workplace  is limited,




the presence of other contaminants,  such  as  dusts,  solvents,




etc., is  taiely known and  questions  of oxygen deficiency and




confined  spaces cannot be  addressed.   Similarily,  sufficient




information  on  then workers'  activities  and workplace




environment  is  not  available  to  fully  consider  the worker's




ability  to wear  a  device,  its comfort, wear  time,  and other  site-




specific  factors.   These  are  all important factors in selecting a




specific  respirator{s)  for the situation of  concern.  Thus,  the




review of respiratory  protection alternatives by CEB should  not




focus on individual respirators  but  rather on the degree of



protection assigned to various classes ot respirators, judgements




about  likely conditions  of use of the respirator, an estimated




potential workplace concentration and, the physical and chemical




properties of the contaminant.




Conditions_j:>f Respirator Use_



     Conditions of use may be  categorized  as  routine ot  non-




 routine.  Non-routine conditions  include  potential  escape or




 emergency situations, confined  space  entry,  oxygen  deficient




 atmospheres, and immediately  dangerous to life  and  health (IDLH}






                              T-Z

-------
atsmosphtit es .   Routine  conditions  include no trial ever, ycay tasks




white there  is  a  potential  foi  inhalation exposure, such as




sampling, mate i3.il  tt a listers  and  first b teaks into closed




equipment for  maintenance.  Alt no ugh CEB engineers generally




focus on  toutine  exposures, potential contact in non-toutine




situations should  be  kept  in  mind.




Allboi ne  Concentration




    For all  new chemicals  and often tot existing chemicals, no




actual measurements of  airborne concentrations of the specific




contaminant  in the  workplace  ate  available.   Thus, estimated




workplace concentrations  are  usually based on data for simiiat




compounas in  similar  uses  01  are  calculated  based on methods




described elsewhere  in  this Manual.




    When  a PEL  has  been established Cor chemical ot concetn, a




surrogate chemical, ot  a  chemical  used in the same workplace




setting,  it  is  often  usea  as  the  reasonable  worst case estimate




unless information  is available demonstrating exposure levels to




De typically  higher 01  lower.  When considering the application




of a  respirator,  credit _c a_n nojt be  given for  reducing exposure




levels below  the  PEL  unless  it is  demonstrated that the PEL can




be met without the  use  of  a  respirator on a  continuous basis.  If




exposure  levels are predicted below the PEL  (with or without a




respirator),  the  assessment must  indicate that without additional




regulatory controls,  the  enforcsble level of exposure is the PEL.




Respirator Per fotrm
    Research  has  shown that the degree of protection afforded by



a particular  respiratoiy protective device depends primarily upon



the type of device  and its fit.  Many types of respiratory
                                1-3

-------
protective devices a:e available  ranging  from  inexpensive  filter




masks to Lather costly seif-cor.ta i ned  breathing  apparatus





-------
Ft opei SeJectiQ_n_ ana	Use	ofJ




    Respirators must,  be properly maintained and properly used in




QLciei to provide  the  protection associated with the respirator.




CE3 has  no control  over whether a respirator  is properly used,




environmental conditions,  etc.   The industrial hygienist (or




other person) in  charge of the  respirator progiam at the site




must consider these  factors  and others in selecting the




appropriate  respirator  for an individual.  OSHA requites that a




comprehensive respiratory  protection program be implemented when




iespiia tots  ate worn.   The respirator  that is least disruptive to




the task but  provides  the  best  protection should be selected  to




enhance  the  probability  that 1) the respirator will be worn and




that 2)  it will be  worn properly.  in selecting a respirator, in




addition to  limitations  imposed by the tespirator itself, one




must consider the operation or  process, environmental conditions




and work area characteristics,  the materials used and the




worker's duties and  actions.   Distress associated with the work




environment  is  accentuated by wearing a respirator:  vision is




restricted,  breathing is  mote difficult, equipment may be




cumbersome and  restrict movement, and wearing the respirator  may




add  to the adverse  effects of temperature extremes.




Er\ v i r o nm e n t a 1 _Coj>d_i^t_ic>_r)s_




    High temperature environments are stressful and wearing a




respirator applies  additional stress on the worker.  In selecting




a respirator  to be  used  in a high temperature environment,, it is




important  to reduce the volume of expired air near the worker's




breathing  zone.   In addition, the respitator should be light-




weight and have & low resistance to breathing.  A supplied-air






                                1-5

-------
lespiratoi may be equipped with a vo: tex  tube  to  cool  the  air-




supplied to the facepiece.  A powered  air-purifying  respirator  or




half mask negative-pressure respirator  can  also  be  used  in hot




env i torments .



    Cool tempeiatutes may cause fogging  on  full  facepiece




respirators/ valve sticking and rubber  stiffness  that  prevents  a




good faceseal .  A nose-cup installed  in  a full facepiece




respirator will eliminate facepiece  fogging.   Coating  the  inside




surface of the lens may  prevent fogging  as  well.   A vortex tube




may be used with some respirators to  warm the  air-supplied to the




facepiece.




Human Facto t s C o n s _i oe r _a_tIP n s




    Powered air-pur ifying respirators (PAPRs)  have  good




application in many industries  because the  worker has  total




mobility and is provided  with  a stream of air  to the breathing




zone.  PAPRs are lighter  in weight  (less than 10 Ibs)  than




supplled-air respirators  or  self  contained  breathing apparatus




(SCBA).  The battery pack roust  be fully charged  to  provide the




protection afforded by  the  respirators associated with the




respirator.  With  higher  work  rates,  the protection may  be




reduced, depending on  the type  of PAPR worn.   These respirators




are  advertised  to  be positive  pressure devices.   Recent  studies




have found  that  two helmet  PAPRs  could not maintain positive




pressure  inside  the faceraask  all  or even part of the time.




However,  the  half-mask  device  tested came close  to being a




positive  pressure  device, and  was able to maintain a positive




pressure  for  100%  of  the time  at  7cfm as opposed to 50%  of the



time at  3cfm.   It  has  good  applicability to abrasive blasting,





                                1-6

-------
tound:. it?s, grinding, pesticide  spraying,  etc.   OS HA nas spc-citieci




that PAPRs rnuBL be given  to  asbestos  wot nets if requested (29 CFR




1910.1001) although  the EPA  ana  M1OS1I do  not recommend PAPRs in




abatement woik due to  the  protection  factors associated with




them.  PAPRs may  be  equipped with  a facepiece,  hood, or helmet.




    Negative pressure  ait-putifying respirators generally weigh




less  than 2  IDs,  and also  ofte:  enhanced  mobility.  However,




because these operate  under  negative  pressure,  the wearer must




overcome  the  negative  pressure  in  the device while bteathing in,




which may cause some d iscornf ot t,   These respirators ate simple




devices and  Can be  readily used  by workers that have been




pic3pei.lv  trained  and tit-tested.



    Suppiied-air  respirators enable longer work periods than




SCBAs and are  less  .bulky.   Supplied air respirators weigh less




than  5 Ibs.   However,  tne airline   impairs worker mobility and




tequites  that  a worker retrace  his steps when leaving  an area,




The  airline  is  vulnerable to being punctured.  Airlines should  be




kept  as  short  as  possible when in  use.  The longest length  of




airline  approved  is  300 feet.  With increasing length  of the




airline,  the approved  airflow to the facepiece may  be  decreased.




     SCBAs are  probably the most cumbersome  respirator  to wear.




The  SCBA  with tank  can weigh up to 35 Ibs and  is  limited to a




maximum  of  30  minutes  of breathing air per  tank.  Of  course,




under heavy work  rates, a full tank of ait will  be  used  at  a much




faster  rate.  SCBAs are approved for escape only  and  for entry




 into and  escape from  a hazaidous atmosphere.  All  breathing gas




cylinders must meet DOT requirements and  supply  Grade  D  breathing-




ait  or  better.   SCBAs  are the most complex  respirator  in use
                               1-7

-------
today,  Ttaining  in  respirator  use is essential
                                1-8

-------
                APPENDIX J




STANDARD LANGUAGE FOR 5{e) ORDERS AND SNURS

-------
                             MAR  -3 !983
                ''• ( e ) Orders and SNUBS

Fro~:           Cathy Fehrenbacher, Industrial Hygier.ist
                Chemical Engineering Branch  (TS-779)

To;             Paul Matthai, Section Chief
                Fremanufacture Notification  Branch  (TS-794)


     Attached is a revised guideline for using the respiratory
protection standard language when writing 5{e} Orders and SN'JRs.
This revision should replace the earlier version as it
incorporates the numbering system used in the revised 5{e)
language and the SWUR proposal.  In addition, I have included a
statement that  a CEB Industrial Hygienist (nyself} should review
all 5(e) Orders and SNURs, as a means of verifying that the
proper respiratory protection language is used.  1 have given
this guideline  to CEB Engineers for their use as well,  I do not
anticipate another revision unless the standard language  is
revised.

     As always,  I am available to answer any questions regarding
respiratory protection or other industrial  hygiene concerns,


cc:        Paul  Quillen
          Roy Seidenstein
          Crate Spears
                            0-2

-------
                                                               th-
                                                               the
            STANDARD LANGUAGE FOR 5(e)BORDERS ..AJ?D SKURS

    ^  EFA  generally  has  insufficient  information  to  focus
 inaividusl respirators for a particular scenario, but can f.^cus
 the  degree   of   protection  assigned   to  various   clac
 respirators,   judgments  about  likely conditions  of  us/*
 respirator,  an estimated potential workplace  concentration
 physical  and  chemical  properties  of the  contaminant.  ' A  "ore
 detailed ciscussion can be found in the  CEB  Engineering Manual.

      The standard language presented  below reflects the use of the
 NIOSH Assigned Protection  Factor (APF)  values and  describes th«
 general   class(es)   of  respiratory  protection  that   should  be
 recommended  m 5(e)  or other Orders and in SNURs.   Mcre pr^tec-< "e
 respirators   are   included  in  each of   the   lesser   protect*
 categories.    For   example,   for  particulate  exposure  where   a
 protection factor of 50 or  greater  is needed,  three  {3 \  types  ~*
 respirators have  APF values of 50 or greater, and will fu'l *i 11 "~h^s
 requirement.   The Order or SNTR would  list  these three Yve*s" o*
 respirators and the  Company would have the option of  selecting thp
 most  appropriate  individual respirator from  these three tyces,"""

      The  standard  language  is  also based  on  consideration  c*
 information  on respiratory  protection developed  at  the  Kc^'sh-p
 (held  February 12 and  13,   1936} , by experts  in  this  fie1^" and
 professional   judgement.     Special  circumstances  nay   recui-e
 modification of the standard  language.  A CEB Industrial  HygieVst
 should  review  all 5  (e)  Orders and  SNURs to determine  that "he-
 appropriate  respirator   classes  have   been  selected   fcr  the
 individual  substance.     Any  questions  regarding   respiratory
 protection should be  referred to  a  CEB industrial  hygienist,

 (Note:  Roman  numerals  in  parenthesis   refer  to  the  list  of
 respirator types  in the regulatory language of the Significant New
 Use Rule,  Section 721.63(a)(5) and  the 5(e)  Order language).


 I.    STANDARD  LANGUAGE  FOR A  2000-FOLD  REDUCTION  IN  EXPOSURE:
Select respirator type  (i)  only.

      (i)  Category 19C Type C  supplied-air respirator  operated  - ~.
pressure demand or other positive pressure node and
a full facepiece.
II.  STANDARD LANGUAGE FOR A 50-FOLD REDUCTION IN EXPOSURE  (APF of
50 or greater):
                           J-3

-------
      A.  Fart ic-j late Exposure:  Select; respirator types (i
 and  (v)  only.
                         ype C supplier-air respirator crserEteci  iri
 pressure  der.and  cr continue..,^ flow node and equipped with a  tigr.r-
 fitting  facepiece.

      (iv)   Category 2 1C air-purifying respirator equipped  with  a
 full  facepiece and  high  efficiency particulate  filters,

      (v)   Category 21C powered air-purifying respirator  equipped
 with  a tiqht-f itting  facepiece and  high  efficiency  particulate
 filters,


      B.   Pa_lnt_S pray ...... M i s t ...... Expos ure:   Select respirator types (ii}r
 (viii), and  (ix)  only.

      (ii)  Category 19C Type C supplied-air respirator operated  in
 pressure  demand or continuous flow mode and equipped with a  tight-
 fitting facepiece,

      (viii)   Category 23C air-purifying respirator  equipped  with
 a  full  facepiece and combination cartridges approved  for paints,
 lacquers  and  enamels.   (Approval label may preclude  use  for  some
 paints, lacquers  or enamels).

      (ix)  Category 2JC  powered  air-purifying respirator equipped
 with a tight-fitting facepiece and combination cartridges approved
 for paints, lacquers and enamels.  (Approval label may preclude use
 for some  paints,  lacquers  or  enamels).


     C .   CjT^a;vi.c_G_as_/ya_gor_ Exposure

           If .no data on cartridge ......... p_e_rf_o_rTTia.nce is available:  Select
 respirator type  (ii)  only.

      (ii)  Category 19C Type C supplied-air respirator operated  in
 pressure demand or continuous flow mode and equipped with a  tight-
 fitting facepiece.

     The  preamble to  the order should state that the company can
 petition EPA to modify the order to allow the use of air-purifying
 respirators which will  give  the same reduction  in  exposure,  The
 company should consider the warning properties of the substance and
must  demonstrate the effectiveness  of the respirator cartridge;
 this  information should  be  submitted  for EPA  evaluation.  The
 company should  consult EPA for  guidance on test methodology and
protocol.   In addition,  if the  PMN  chemical has poor or unknown
warning properties, the company must develop a change-out schedule
 for cartridges based  on  service  life  data.

-------
            If  data  c-  cartridge  per for-ance  IE  accer.*^r_^& •  •--. - • .- - -
 resriratcr types  -e
 filters.                                  '           *   " "~  *""


     B.  Paint 5_B.ray Mist_Exposurg :  Select respirator tvces ' i ; -' '•
 (viiij,  (ix),  and  (x)  only,

      (iii)   Category  ISC Type C supplied-air respirator  operated
 in pressure demand or continuous flow mode and equipped  with a  per--5
 or helmet,  or  tight-fitting facepiece.

      (viii)  ^Category 23C air-purifying respirator  equipped  with
a  full  facepiece  and  combination cartridges  approved for caz~tsr
 lacquers and enamels.   (Approval label  may  preclude  use  for'so-s
paints, lacquers or enamels).
                             J-5

-------
      (ix)   Category  23C  powered  air-purifying  respirator  equipped
 with a tight-fitting facepiece and combination  cartridges  approved
 fcr paints, lacquers and enamels.   (Approval label nay preclude use
 for some  paints,  lacquers  cr  enamels).

      (x)   Category  23C powered air-purifying  respirator  equipped
 with  a loO'Se  fitting  hood or helmet  and combination cartridges
 approved  for paints, lacquers and  enamels,    (Approval label may
 preclude  use  for  some  paints,  lacquers  or enamels).


     C.   Organic  Gas/Va_p_gr Exposure

           .If ..no .datia	_on_ c_artrLldae__Ee_r_f.Q_£Tnance is a\/a_ij^a_b!le_ :  Select
     respirator type  (iii)  only.

      (Hi)   Category 19C Type C supplied-air  respirator  operated
 in pressure demand or continuous  flow mode and equipped with a hood
 or helmet,  cr  tight-fitting facepiece.

     The  preamble to the order should state that the  company can
 petition EPA to ir.odify the order to allow the use of  air-purifying
 respirators which will  give the  same reduction  in exposure.  The
 company should consider the warning properties  of the substance and
 must demonstrate  the effectiveness  of  the respirator cartridge;
 this  information  should  be submitted  for EPA  evaluation.   The
 company should consult EPA for  guidance on test methodology and
protocol.   In addition,  if the  PMN  chemical has poor or  unknown
warning properties, the company must develop a  change-out  schedule
 for cartridges based on  service  life data.

           If dataoncartridge performance is  acceptable:   Select
 respirator types  (iii),  (xii),  (xiii),  and (xiv)  only.

     (iii)   Category 19C Type C supplied-air  respirator  operated
 in pressure demand or continuous  flow mode and  equipped with a hood
or helmet, or  tight-fitting facepiece.

     (xii)  Category 23C air-purifying  respirator equipped with a
 full facepiece and organic gas/vapor cartridges,

     (xiii)  Category 23C powered air-purifying respirator equipped
with a tight-fitting facepiece and  organic gas/vapor cartridges.

     (xiv)  Category 23C powered air-purifying  respirator equipped
with  a  loose  fitting  hood  or  helmet  and   organic  gas/vapor
cartridges.
IV.  STANDARD LANGUAGE FOR A 10-FOLD REDUCTION IN EXPOSURE (APF of
10 or greater):
                             5-6

-------
     (vi)
v i t h a  1 o o s e
filters.
      A.  Farticulate  Exposure:  Select respirator tv-^
  <-±i),  (iv) ,  (v),  (vi), and  (vii) only,

       'ill)   Category  19C  Type C supplied-air resr.ir2trr ±r-^-----
  in £r-= = £-ure aera^a cr  continuous flow -r.ode and ecru itcad w-^-  ^ •--,-.;
 cr he.-e", cr tight-fitting  facepiece.

      (iv;  Category 21C air-purifying  respirator equipped  with a
 full facepiec-e and high efficiency particulate filters.

      (v)  Category 21C powered  air-purifying respirator equ^peed
 v:th a  tight-fitting   facepiece  and high  efficiencv  ^,ar-i'c,.iA*c
 f 1 1 t P r c; .                                            '

            Category 21C powered air-purifying respirator equipped
            2  fitting hood or helmet and  high efficiency particulate


      (vii)   Category 2IC air-purifying respirator equipped -,.••-'- 3
 high efficiency particulate filter"]  including disposables!


      B*   EaJ-^t Spray Mist Exposure;  Select  respirator  i-vc<=s  M-M
 (vni),  fix), (x), and (xi} only.                      "    '"* ''

      (iii)   Category  ISC Type  C  supplied-air respirator ccerated
 in pressure demand or continuous flow mode and equipped with  a heed
 or hel~et,  cr tight-fitting facepiece.

     Jviii)   category 23C  air-purifying  respirator  equipped with
 a  full  facepiece  and  combination  cartridges  approved  'for' pair.te
 lacquers and enamels.   (Approval  label may preclude use "for so-te
 paints,  lacquers  or enamels).

      (ix)   Category 23C powered air-purifying respirator ecuipped
 with a_tight-fitting facepiece and combination cartridges approved
 for paints, lacquers and enanels.   (Approval label nav creclude use
 for sore  paints,  lacquers  or enamels).

      •;x)  Category 23C powered air-purifying respirator equipped
 with  a  loose  fitting  hood or  helmet  and  combination cartridaes
 approved  for paints,   lacquers  and enamels.   (Approval  label ray-
 preclude  use  for  sorae  paints,  lacquers  or enaroels),

      (xi)   Category  23C air-purifying  respirator  equipped with
 conbination_cartridges approved  for  paints,  lacquers and "enanels,
 including disposables.   (Approval  label may preclude use for sore
paints,  lacquers  or enamels),


     C.  Organic  Gas/Vapor  Expos_u_re_
                            J-7

-------
           Lf_no data_ on Cartridge perf crnajicg^jis ava_i 1 s 11 r: ;
 respirator type  (iii)  only.

      fill)   Category 19C Type  C  sur::!ied-air  respirator
 ir. pressure demand cr continuous flow node  and equipped vi:
 cr helr.et,  cr tight-fitting  facepiece.

      The  preamble to the order should state that  the  cor.pany  car,
 petition  EPA  to modify the order to allow the use of air-purifying
 respirators  which will give the same reduction  in  exposure.   The
 company should consider the warning properties of the substance and
 nust  demonstrate the  effectiveness  of the respirator  cartridae;
 this  information should  be submitted  for EPA  evaluation.    The
 company  should consult EPA  for guidance on test  methodology  and
 protocol.   In addition,  if  the PMN chemical has  poor  or  unknown
 warning properties,  the company must develop a change-out  schedule
 for cartridges based on  service life data.

           I f_ d a t a o r	c_a r t r idge  p e r f o rr> a n c e_ig_ accept a b_Ie :   Select
 respirator types  (111} ,  (xnl,  (xiii) ,  (xivj ,  and (xv)  only.

      fiii)   Category I9C Type  C  supplied-air  respirator  operated
 ir. pressure demand cr continuous flow mode  and equipped with a hood
 or  helmet, cr  tight-fitting  facepiece.

      (xii)  Category 23C  air-purifying  respirator equipped with a
 full  facepiece and organic gas/vapor cartridges.

      {xiii)  Category 23C  powered air-purifying respirator equipped
with  a tight-fitting facepiece  and organic gas/vapor  cartridges.

      (xiv)  Category 23C powered air-purifying respirator equipped
with  a  loose  fitting  hood  or  helmet  and  organic  gas/vapor
cartridges.

      (xv)    Category  23C  air-purifying  respirator equipped  with
organic gas/vapor cartridges,  including  disposables.


V,  OTHER COMBINATIONS OF CONTAHINAHTS:

      Consult a CEB Industrial Hygienist.
                            J-8

-------
           APPENDIX K

   DERIVATION OF EQUATION FOR
EVAPORATION FROM OPEN SURFACES
           (REVISED)
               K-1

-------
                   Evaporation of a Liquid in a Flowing Air Stream

      Evaporation  can be defined as the change of state of a liquid  into a gas at the
cost of a specific amount of energy. Evaporation of a liquid in a flowing air stream can
be idealized as in Figure I, in which the air flow direction is defined  to be along the z
axis, and the flow is always parallel to the liquid surface,
                     air flow
Figure 1
       Once the evaporation system reaches equilibrium, namely, the surface
temperature of a sufficiently large pool is constant and the heat of evaporation is
provided by the surroundings, the evaporation rate will also be a constant.  In this case,
we can establish a mass balance on a differential element above the liquid  pool (normal
to the liquid surface, or in the x direction) and along the air flow (z direction). A similar
system has been considered in a standard text of Transport  Phenomena by  Bird Stewart
and Lightfoot (Section 17.5).

       Along a volume element, the following equation applies:
                                          6W,
= 0
                                                                              (1)
where NA^ and N^ are the molar fluxes of chemical A in the z or x direction
(moles/unit time/unit area).
                                        K-2

-------
      For NA7, the flux in the z direction, we assume no changes in concentration
CA(X,Z) as a function of time (equilibrium), and neglect the contribution from diffusion of
A in the z direction (small compared to the  air velocity).  In addition, diffusion at the
edges of the pool in the y direction is neglected.  Geometry of the surroundings may
influence these assumptions (such  as physical barriers above and to the side of the pool),
but may be neglected if the concentration of the vapor is relatively low at that boundary'.
In order to simplify the analysis  for the overall evaporation rale, the air velocity is also
assumed constant as a function of x and flow only in the 2  direction. Thus,


                                     NK - 0AV2                                (2)
       For NAili, the flux above the pool in the x direction, we neglect convective
transport (no net flow in that  direction). This essentially means that CA is small, and that
there is essentially no mixing in the area above the pool where the greatest portion of
the concentration gradient exists. Thus,

where DAB is the diffusion coefficient of chemical A in B (air). To be rigorous, the
diffusion coefficient should be defined at the local temperature of the flowing air,
However, this temperature will vary between the liquid surface temperature and the
source air temperature.  In this analysis, the liquid temperature is used,

      Thus, equation (1) becomes:

                                    &r*        z.2r.
                                                                                (4)
       The boundary conditions are .as follows:

             at z = 0                  CA = 0
                x  = 0                  CA = CAO
                x  = »                  CA = 0

CAO is assumed to be the concentration represented by the vapor pressure of the liquid at
the liquid surface  temperature.  In reality, a temperature gradient will usually exist
between the  liquid surface and the air temperature some distance away.  Using the liquid.
vapor pressure neglects the effect of this gradient on the evaporation.
                                        K-3

-------
      The solution to this partial differential equation is:
                                 " 1 "T3    /   e^c
CAO      V«    o                                 (5)
                                      	x

                                      I  ""''
The complementary error function (erfc) is well known as shorthand for the integral in
equation (5) above.

      This equation gives the vapor concentration as a function of z and x. The
evaporation rate at any point on the liquid surface is given by;
       The total evaporation rale is therefore the sum of all these points over the entire
liquid surface, given by:
                       Evap.Rate = i)(Breaofpooty f JN^zdy
       Solving the partial derivative in equation (7) by differentiating equation (5) yields:

                                         (7  2D^^~dzd¥
                                       zJ4«D^Kz
                                                                            (8)
       This equation is in units of moles per unit time and area.  In units of weight, we
multiply by the molecular weight  of the evaporating substance:
                                        K-4

-------
Eva.p.Rate(mass/time*area) - 2 MW CAO
                                                                                (9)
                                                            n Az
      The concentration of the evaporating solute at the interface is given by c^, which
can be approximated by:
                                           R T
      where "vapor pressure" refers to the saturated vapor pressure above a liquid at
temperature 'T' in  Kelvin, and "R" is the gas constant (39.381 in. Hg * ft* / { Ib moles *
Kelvin }.
       Equation (9) can therefore be written in the following dimensions:
                   Evap.Rate(lbfkr j^2) =
                                        13.3792 M.W. V.P.
                                                          \
                                                           (11)
                                          Az
      where:
                    M.W. =  molecular weight of evaporating liquid
                    V.P.   =  vapor pressure (in. Hg)
                    T     =  temperature (Kelvin)
                    DAB   =  diffusion coefficient of liquid vapor in air, ft2/sec
                    vz     -  air velocity, ft/mi n
                    Az    =  poo!  length along  flow direction, ft.
       Equation (11) is completely general for a dilute evaporating substance in a
flowing air stream.
                                        K-5

-------
      The diffusion coefficient may noi be available for many cases. According to
Chapman-Enskog kinetic theory (Bird, Stewart and Light fool section 16,4), the diffusion
coefficient is ejven bv:
                           O0018583.j'Fo/W41"+  1/A/j)

                                   P ® AB  AS
                                                                             (12)
where:
             T     = temperature, Kelvin
             MA   = chemical A molecular weight
             MB   = chemical B (air) molecular weight (= 29)
             p     = pressure (atmospheres)
             aAB   = Lennard-Jones distance, angstroms
             n.AB   = function of Leonard-Jones potential

      The Lennard-Jones parameters are  tabulated (appendix B, Bkd.Stewart and
Lightfooi) and can be roughly fit against temperature  and molecular weight.  This is
shown in Figures 2,3 and 4.
        QUO
        70C -
     OJ
     V
     E
     o
     tn
     ci
     us
403


30C


SOD


1DQ


  D
                     30        100        150        EDO        25O
                              molecular  w&lght

                ©ps r lon/k  dets      __eps! lon/k  predTcT.ec!
                                                                       3OD
 Figure 2
       Figures 2 and 3 show the fit of the function Omega against molecular weight
 (Figure 2) and temperature (Figure 3). In Figure 2, the Lennard-Jones potential
 epsiSon/k for a variety of compounds is shown versus their molecular weight.  A simple
 exponential regression was fit against this graph with the results shown,  Figure 3 shows
                                       K-6

-------
       O)
       o
           1 . S
           Q  3
                    V"
                    y
     Omega  A3 dat.o
                                           eps I  I on

                                            _ Omega  AB predicted
Figure 3


the plot of the Omega function against the Lennard-Jones potential divided by
temperature, and a simple exponential fit of this function,  Combining these two fits
gives an approximation of the fl function in Equation 12,
         5. 5
      1
      tfj
      O>
      c
     CD
      ra
      E  3.5
     LO
                               1DO        ISO

                              moJe-cular w
                                                  200
                                                            Z3D
                                                      300
:.: Sigma  AB dana
                                          Sfgma  AB predicted
Figure 4

-------
       Similarly, Figure 4 shows the relationship and fit of data for the a function in
Equation 12, The exponential fits of these functions versus molecular weight and
temperature are:
                                     (M.W.)
                                           ™1
                              _
                                    I
       Substituting into equation 12, this gives;


                                     5 Fw 71/29 + \}M.W.t
                                           ^	
where:
             p      =• pressure (atmospheres)
             T      = temperature (Kelvin)
             M.W.A = molecular weight of evaporating liquid

       Converting DAB to ft2/sec, and then inserting into equation (11), an approximate
expression for the evaporation rate of a liquid in a flowing air stream is given by:
Evap.Rate(lb}hr
                            2.79jdCT3  (M.W.fm  (F.P.)  IJM.W.A +  1/29
                                              jO.05
                                                                   v
*_  (IS)
where:

             M.W.  = molecular weight of evaporating liquid A
             p      = overall pressure, atmospheres
             Az    = length of pool along air flow, feet
             T      = surface temperature of pool, Kelvin
             V.P.   = vapor pressure of substance A (in. Hg)
             vz      = velocity of air, ft/min

       Equation 15 is a completely general equation that can be used to predict the
evaporation rate of a liquid in a flowing air stream. In addition, it lakes into account the
effect of changes in temperature, pressure, pool size and air velocity.   Since it is rare to
                                        K-8

-------
find completely stagnant air conditions in most spill situations, an approximation of the
air speed, spill size can  be made, and this equation will work well for esiimating the
evaporation rate. Although many assumptions were made to arrive at Equation 15, they
are not at all unreasonable for a variety of situations.  In general, the equation assumes
low concentrations of the evaporating solvent, as compared to the air concentration in
the room.  As a result, this equation may begin to show errors for strongly evaporating
solvents,  long pool lengths or slow air wind velocities.

       This equation can be tested by comparing it to  experimental data provided by
Pace Laboratories.  In an extensive study using a specially-built apparatus, Pace
measured the evaporation rate of 15 different compounds at several different
temperatures and air velocities, and fit the data against "power law" regression against
molecular weight, vapor pressure and air velocity, with generally good results.   They
performed an overall  regression  analysts for all chemicals except the "low vapor pressure"
alcohols  (1-hexanol, 1-hepianoi and 2-ocunol) and obtained the following equation:

                                      = 0.000237XMW)(KP)(F,0-625)               U6)
      where:

                    MW   = molecular weight of evaporating substance
                    VP    = vapor pressure at liquid temperature, In. Hg
                    Vz    = air velocity, ft/min

      The EPA. equation, based on work by Mackay is:

                                                        *3                   ,.~
                                                                              (17)
       In some cases, the wind velocity' term has been assumed to be 10 mph, which
corresponds to 880 feet/min. For the comparison below, however, the velocity term was
included.

       Figures 5, 6 and 7 compare Equations 15, 16 and 17 as applied to the Pace data,
including the low boiling alcohols. The only differences between the figures are the
scales, showing the experimentally measured evaporation rates from 0 to 0.06, 0 to 0.7
and 0  to 6 Ibs/hr fr.
                                        K-9

-------
r
                       ,' \
                       CM
                        t-1
                        (0
                        o
                        o/
                        t-'
                        (J-
                        0.)

                        Q_
                                      D 01      D 02      D C3      Q 0*     Q 05
                                     Experimental Evsp Rate  CId/fir/fta}

                                  • Pace  Equation      0 Theory/Frtied Dab
                                  x EPA Equatlen
                                                                                  0.06
             Figure 5
                                     D,1      0.2      0.3     0.4      O.S      0.6
                                     Experimental  Evop Rate Clb/hr/ft23

                                  m Pace Equat ion
                                  x EPA  Eauatlon
                                                                                   0,7
o Theory/ Fitied Dab
              Figure 6

                    A perfect fit of experiment and equation would be on the straight line along the
              diagonal. As can be seen in the three figures, both the Pace equation and the
              theoretical Equation 15 does a good job over a large range of evaporation rates.  Since
              the Pace equation was a regression fit, it should naturally fit the closest.  Remarkably,
              the theoretical  equation is almost as good, and seems to be more accurate at the  lower
              evaporation rates, which would  correspond to normally encountered situations in EPA
              PMN analysis.  The MacKay equation, however, is extremely poor, universally
              underestimating the actual evaporation rate by an order of magnitude for many measurements.
                                                     K-10

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                         1         2        3
                       Experimental  Evep Rste Clb

                     m Pace  Equation     o  Theory/Fitted  Dab

                     x Ep-A  Equal i on
Figure 7

      Closer inspection of ihe data shows that the theoretical equation 15 does the best
job of the three equations at the low velocity gas rates of 100 feet/minute, but like the
other two equations, it underestimates the experimentally measured evaporation rate for
all of the low flow rate data. It is not -clear whether this is from a deficiency in the
equations or in the experiment. However, since these low rates would be more
frequently encountered when judging evaporation rates inside ventilated buildings, the
theoretical equation may be the best choice of the three. In addition, the assumptions
are clear in the theoretical development, and cases where they may be violated can be
easily identified.  The agreement  between the Pace results and the theory shows that
these assumptions also apply to the Pace experiment.
                                                  Dr. Albert A, Hummel
                                                  Himont Research & Development
                                                  800 Greeobank Rd.
                                                  Wilmington, DE  19808

                                                  August 18, 1990

                                                  (Formerly of the Chemical
                                                  Engineering Branch)
                                       K-n

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