PMN: 03-0624 ENGINEER: Jon/JB 

PV (kg/yr): 425,000 SUBMITTER: INVISTA 

USE: Chemical intermediate, product not disclosed. 

OTHER USES: 

MSDS: Yes Label: No 

General Eqp.: Use only with adequate ventilation. Wear 

coverall chemical splash goggles and wear 

face shield where the possibility exists for 

face contact due to splashing or spraying of 

materials. Wear impervious gloves, apron, 

pants , jacket, hood and boots. 

Respirator: Use only with adequate ventilation. 

Health Effects: Based on similar compound, significant 

skin permeation and systemic toxicity, 

after contact appears unlikely. This 

compound may also cause eye irritation 

with tearing, pain, or blurred vision. 

TLV/PEL (PMN or raw materials): None established 

CRSS: 

Chemical Category: Dodecanedioic acid, dimethyl ester 

VP: 0.00084 torr @25ΕC 

S-H2O: 0.012 g/L 

MW: 258.36 

Phys State: Neat: Solid; Mfg: solid; Proc/Form: NA; 

End Use: destroyed. 

Consumer Use: No 

SAT (concerns): 

Migration to Groundwater = moderate 

PBT Potential = P1B1T1 

Health: 1 (no exposures to humans) XB: testing desired 

Eco: 3 (all release to water) XB: testing desired 

OCCUPATIONAL EXPOSURE RATING: 1 
INITIAL REVIEW ENGINEERING REPORT Page # 2 

PMN: 03-0624 

ASSUMPTIONS: The submitter was contacted to answer questions, see 

contact report. The number of batches for the manufacturing 

process was increased to accommodate the PV of 500,000 kg/yr. 

POLLUTION PREVENTION CONSIDERATIONS: None listed 

EXPOSURE-BASED REVIEW Yes (0 criteria met) 

1) # of workers exposed: >1,000 3 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 Page # 3 

PMN: 03-0624 

MFG 

Site/Location: 1 site: Pasadena, TX 77507 

Days/yr: Site : 17 

Process Description: Raw materials are charged to reactor -> 

sampling -> filter -> intermediate storage -> distillation -

> final storage tank B> next reaction 

ENVIRONMENTAL RELEASES (Eqpt. cleaning, container residue, etc.): 

WATER: 0.042 kg/site-day over 17 days/year 

from decanter to off-site waste water treatment 

based on water solubility of 0.012 grams/liter and 

3,488 kg of water (waste steam #4) 

3,488 kg of water * 0.012/1000 = 0.042 kg/site-day 

(submission estimates 0.012 kg/day and estimates 90% 

removal at the off-site biotreatment) 

Gulf coast Waste Disposal Authority, Bayport facility, 

NPDES# TX0005380 

AIR: Negligible (liquid PMN, VP < 0.01 torr) 

INCINERATION: 1,070 kg/yr 

from: sampling, cleanout waste from reactor, tank. 

Basis: Submission estimates 816 kg/year. Add 1% of 

daily batch for storage tank clean up. 

816 + 250 = 1066 kg/year 

LANDFILL: Not expected, all waste is sent to 

incineration (submission) 

OCCUPATIONAL EXPOSURE 

 Tot. # of workers: 5 (submission) 

 Days/yr: 17 

INHALATION: Negligible (liquid PMN, VP < 0.001 torr) 

 

DERMAL: contact with liquids: 1,800 mg/day 

 98% concentration 

 Basis: Routine contact, 2 hands, liquids (sampling, 

equipment cleaning, transferring liquids) 
INITIAL REVIEW ENGINEERING REPORT Page # 4 

PMN: 03-0624 

USE: This PMN chemical is used to make . Case 

was referenced for process description. 

Site/Location: 1 sites (same as the mfg site) 

Days/yr: 156 

Process Description: Catalyst and raw materials (PMN liquid 98%) 

are charged to H2 reactor -> flash tank (85% liquid PMN) -> 

crystallizer -> filtration -> PMN destroyed (submitter, see 

contact report) 

ENVIRONMENTAL RELEASES (Eqpt. cleaning, container residue, etc.): 

WATER: not expected kg/site-day over Days/year 

Basis: used at the same site as mfg site, expected 

to fully react during the use 

INCINERATION: not expected kg/yr 

LANDFILL: not expected kg/yr 

AIR: Negligible (liquid PMN, VP < 0.01 torr) 

OCCUPATIONAL EXPOSURE 

 Tot. # of workers: 3 (CEB std. est.) 

 Days/yr: 156 

INHALATION: Negligible (liquid PMN, VP < 0.001 torr) 

 

DERMAL: contact with liquids: 1,800 mg/day 

 98% concentration 

 Basis: Incidental contact, 2 hands, liquids 

(transferring liquids) 
CONTACT REPORT

(Telephone Log)

PMN: 03-0624

CALL BY: Jennifer Biancuzzo (ERG) for EPA/OPPT/CEB

CALL TO: Kathleen E O=keefe 

SUBMITTER: Dupont Textiles and Interiors

DATE: 6/30/03

TIME: 2:45 pm

Q1: The number of batches and batch size do not match up to the 

maximum 3-yr production volume. What would be the best way 

to scale up the process to meet this PV?

A1: Increase the number of batches.

Q2: Could you provide a process description for the use of the 

chemical as an intermediate (e.g., # sites, # workers, 

disposal/cleaning of isotainers, use rate)?

A2: The PMN chemical is completely destroyed to manufacture a 

new chemical. The chemical will be used at one site (either 

our site or a toll manufacturer). See , this PMN is 

used to make , process description is available in 

this IRER. Isotainers are sent off-site to be cleaned. 

Little residual is expected to remain in the containers.