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 @25 **Ε** C

S-H 2 O: 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: 1INITIAL 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: NoINITIAL 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.