INITIAL REVIEW ENGINEERING REPORT No 

SNUN: 13-0049 

Focus Ready Draft 9/19/2013 

ENGINEER: Arnold \ EV \ AH \ REC 

PV (kg/yr): 

SUBMITTER: Morimura Bros. USA Inc. 

USE: 

OTHER USES: 

MSDS: Yes Label: No 

Gen Eqpt: Provide adequate ventilation. If enclosed handling cannot be 

guaranteed, ventilation, an adequate dust mask and protective clothing must 

be used. Use approved safety goggles or face shield. Wear chemical-resistant 

gloves. Full protective clothing should be worn when handling this product. 

Respirator: Use respiratory equipment with combination filter, type P3. A 

NIOSH-approved, particulate respirator with a minimum of APF 10. 

Health Effects: Contains a small amount of respirable fibers which may become 

airborne during handling. Prolonged inhalation of excessive concentration of 

respirable fibers may cause deposition of quantities of fibers in lungs 

sufficient to cause a tissue response which could be associated with injury. 

Risk of damage to eyes. Can cause corneal opacity. Exposure may cause eye 

tearing, redness, and discomfort. May cause skin irritation 

TLV/PEL: 

Titanium Dioxide 10 mg/m3 TWA ACGIH 

CRSS (09/05/2013): 

Chemical Name: Potassium titanium oxide (K2Ti6O13) 

S-H20: 0.000001 g/L @ 

VP: 1.0E-6 torr @ 

MW: 574.00 %<500 %<1000 

Physical State and Misc CRSS Info: 

Neat: Solid Mfg: NK: Import Proc/Form: NA End Use: Solid: 15% or 5% SNUN 

material entrained in a polymer matrix. The molecular weight and molecular 

formula shown above are for the empirical formula. The molecular weight of 

the bulk material would depend on the particle size and is estimated to be 

>100,000 g/mole. Submitted Properties: MP = 1300-1350 °C; WS < 1 g/L, 

Insoluble; pH = 9.5-12; Density = 3.6 g/cc; Bulk Density = 0.7-1.3 g/cc; 

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Median Particle Size = 3-15 μm (Laser light diffraction); Specific Surface 

Area = 1.8-2.8 m^2/g (BET). Estimated Properties: VP < 0.000001 torr 

(Inorganic salt); WS < 0.000001 g/L (Metal oxide). 

Consumer Use: No 

SAT (concerns) (07/26/2013): 

Related Cases and Misc SAT Info: 

Ecotox Related Cases: Same as S-09-4, S-08-6, P-96-1408, P-96-249, P-95-1241, 

P-90-226. Analogs: P-06-149, P-02-214, P-13-373, P-11-150, P-06-173, L-96-73, 

 P-96-288, P-92-836. Human Health Related Cases: P96-1408 (SAME), P96-0249 

(SAME), P95-1241 (SAME), P90-226 (SAME), S08-0006 (SAME), S09-0004 (SAME), 

P01-0764, P02-0214, P06-0149 

Migration to groundwater: Negligible 

PBT rating: P3B1T1 . 

Health: 1-2 Inhalation 

Eco: 1 No releases to Water 

OCCUPATIONAL EXPOSURE RATING: 2-3B 

NOTES & KEY ASSUMPTIONS: 

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POLLUTION PREVENTION CONSIDERATIONS: 

P2 Claim 

EXPOSURE-BASED REVIEW: Yes (0 criteria met) 

1) # of workers exposed: 33 >1000? No 

2) >100 workers with >10 mg/day inhalation exposure: No 

3) (a) >100 workers w/1-10 mg/day inh. exp. & >100 days/yr: No 

 (b) Routine Dermal Cont: >250 workers & >100 days/yr: No 

 

INITIAL REVIEW ENGINEERING REPORT No 

SNUN: 13-0049 

Number of Sites/ Location: 3 

unknown site Novi MI 

unknown site Sidney OH 

unknown site Hollsopple (Benson) PA 

Basis: Per amendment: 3 sites and 200 exposure day/yr 

Process Description: SNUN imported in 20-kg bags (powder, 100%) --> customer 

sites --> unloaded from bag --> incorporated with other raw materials into 

mold --> pressing of mixed materials in mold (solid, 5%) --> heat --> article 

(submission; SNUN entrained per CRSS) 

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY 

IRER Note: 

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Landfill 

Output 2: 2.5E+0 kg/site-day over 200 days/yr from 3 sites 

or 5.0E+2 kg/site-yr from 3 sites or 1.5E+3 kg/yr-all sites 

to: Landfill (per amendment 8/28/2013) 

from: Cleaning Solid/ Powder Residuals from Containers Used to Transport the 

Raw Material 

basis: EPA/OPPT Solid Residuals in Transport Containers Model, CEB standard 

1% residual. Per amendment 8/28/2013, submitter estimates 0.005 kg SNUN 

disposed as bag residual (regular waste) per 20 kg PMN bag (loss fraction of 

0.025%). As conservative, CEB assesses this release using the standard CEB 

model for solid residuals, 1%, to landfill. 

RELEASE TOTAL 

1.5E+3 kg/yr - all sites 

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY 

Tot. # of workers exposed via assessed routes: 3 

Basis: 

Inhalation: 

The OSHA Total PNOR PEL model estimates 150 mg/day exposure. Submission 

estimates that 0.00005 kg (50 mg) SNUN per bag could become airborne during 

unloading, and assumes that workers could be exposed to all of the airborne 

material. Based on 200 day/site-yr and 12.5 bags unloaded per site-day, this 

translates to 50 mg SNUN/bag x 12.5 bag/site-day = 625 mg/site-day exposure 

for 2 workers, or 312.5 mg/site-day/worker . 

Exposure to Particulate (non-volatile) (Class I) 

Upper Bound: 1.5E+2 mg/day over 200 days/yr 

Number of workers (all sites) with inhalation exposure: 3 

Basis: Cleaning Solid/ Powder Residuals from Containers Used to Transport the 

Raw Material; OSHA PNOR PEL-Limiting Model. 

NOTE: The respirator class is: I. Particulate (including solid or liquid 

droplets). 

INHALATION MONITORING DATA REVIEW 

1) Uncertainty (estimate based on model, regulatory limit, 

 or data not specific to industry): Yes 

2)a) Exposure level > 1 mg/day? No 

 OR 

 b) Hazard Rating for health of 2 or greater? 1-2 No 

Inhalation Monitoring Data Desired? No 

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Dermal: 

Not required per SAT. Note some dermal exopsure to solid powder is expected 

from unloading of bags. 

Exposure to Solid at 100.00% concentration 

High End: 3.1E+3 mg/day over 200 days/yr 

Number of workers (all sites) with dermal exposure: 3 

Basis: Cleaning Solid/ Powder Residuals from Containers Used to Transport the 

Raw Material; EPA/OPPT Direct 2-Hand Dermal Contact with Solids Model. 

INITIAL REVIEW ENGINEERING REPORT No 

SNUN: 13-0049 

Number of Sites/ Location: 8 

unknown site Prattville AL 

unknown site Covington GA 

unknown site LaGrange GA 

unknown site Elizabethtown KY 

unknown site Plymouth MI 

unknown site Sterling Heights MI 

unknown site Orangeburg SC 

unknown site Smithville TN 

Basis: 

Process Description: 

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY 

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IRER Note: The daily releases listed for any source below may coincide with 

daily releases from the other sources to the same medium. Potential air 

release assessed due to SAT concern for inhalation. //// In addition to 

these releases, submission estimates 0.005 kg SNUN disposed as bag residual 

(regular waste) and <1 kg SNUN/site-yr disposed as residue in molded article. 

 

Landfill 

Output 2: 3.0E+1 kg/site-day over 200 days/yr from 8 sites 

or 6.1E+3 kg/site-yr from 8 sites or 4.8E+4 kg/yr-all sites 

to: Landfill (per amendment 8/28/2013) 

from: Cleaning Solid/ Powder Residuals from Containers Used to Transport the 

Raw Material 

basis: EPA/OPPT Solid Residuals in Transport Containers Model, CEB standard 

1% residual. Per amendment 8/28/2013, submitter estimates 0.005 kg SNUN 

disposed as bag residual (regular waste) per 20 kg PMN bag (loss fraction of 

0.025%). As conservative, CEB assesses this release using the standard CEB 

model for solid residuals, 1%, to landfill. 

RELEASE TOTAL 

4.8E+4 kg/yr - all sites 

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY 

Tot. # of workers exposed via assessed routes: 8 

Basis: 

Inhalation: 

The OSHA Total PNOR PEL model estimates 150 mg/day exposure. Submission 

estimates that 0.00005 kg (50 mg) SNUN per bag could become airborne during 

unloading, and assumes that workers could be exposed to all of the airborne 

material. 

Exposure to Particulate (non-volatile) (Class I) 

Upper Bound: 1.5E+2 mg/day over 200 days/yr 

Number of workers (all sites) with inhalation exposure: 8 

Basis: Cleaning Solid/ Powder Residuals from Containers Used to Transport the 

Raw Material; OSHA PNOR PEL-Limiting Model. 

NOTE: The respirator class is: I. Particulate (including solid or liquid 

droplets). 

INHALATION MONITORING DATA REVIEW 

1) Uncertainty (estimate based on model, regulatory limit, 

 or data not specific to industry): Yes 

2)a) Exposure level > 1 mg/day? No 

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 OR 

 b) Hazard Rating for health of 2 or greater? 1-2 No 

Inhalation Monitoring Data Desired? No 

Dermal: 

Not required per SAT. 

Exposure to Solid at 100.00% concentration 

High End: 3.1E+3 mg/day over 200 days/yr 

Number of workers (all sites) with dermal exposure: 8 

Basis: Cleaning Solid/ Powder Residuals from Containers Used to Transport the 

Raw Material; EPA/OPPT Direct 2-Hand Dermal Contact with Solids Model. 

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 No 

MEMORANDUM of TELEPHONE CONVERSATION 

CALL BY: Edward Viveiros 

Organization: ERG for EPA 

CALL TO: Gavin Thompson 

Organization: ENVIRON International Corp 

Date: 07/29/2013 

Time: 

Phone: 602-734-7704 

Concerning what TSCA 

SNUN: 13-0049 

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Q1 

 No 

MEMORANDUM of TELEPHONE CONVERSATION 

CALL BY: Ariel Hou 

Organization: ERG for CEB 

CALL TO: Gavin Thompson 

Organization: 

Date: 07/31/2013 

Time: 10AM 

Phone: 602-734-7704 

Concerning what TSCA 

SNUN: 13-0049 

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