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;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: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: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? NoDermal: 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 SUMMARYIRER 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? NoOR 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.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: 13-0049Q1

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