p060370.ce1.txt INITIAL REVIEW ENGINEERING REPORT PMN: 06-0370 SR Draft - Revision 1 12/9/2010 ENGINEER: Macek \ MAD \ DGR PV (kg/yr): 100,000 Import Only YX Revision Notes / Assessment Overview: The previous version of the engineering report dated 10/19/06 has been revised based on additional information provided by the submitter (10/3/06 fax from Flora Gashi of Degussa Corporation and in a letter from Tiana Rosamilia of Degussa. dated 12/1/10.

SUBMITTER: Degussa Corporation USE: Softener for PVC. OTHER USES:

MSDS: Yes Label: No Gen Eqpt: chemical-resistant protective gloves (nitrile-butadiene rubber). NBR gloves are used Page 1p060370.ce1.txt

Health Effects: No specific hazards are known TLV/PEL: None established

CRSS (03/23/2006): Chemical Name: Benzoic acid, nonyl ester, branched and linear S-H20: 0.000298 g/L @ VP: 1.8E-4 torr @ MW: 248.37 %<500 %<1000 Physical State and Misc CRSS Info: Neat: Liquid Mfg: NK: Import Proc/Form: NK End Use: Solid: Submitted Data: Pour Point < -60 °C; BP > 300 °C; VP = 2.4E-4 hPa (1. 8E-4 torr); WS < 0.001 g/L; logP = 6.1-6.4; Ignition Temperature = 370 °C; Dynamic Viscosity = 8.4 mPas. Estimated Data: BP = 303 °C (EPI); WS = 0.00028 g/L (EPI). Consumer Use: SAT (concerns) (03/24/2006): Migration to groundwater: negligible due to strong sorption, and negligible from surface soils due to biodegradation and sorption PBT rating: P1B1T2 Health: 1-2 Dermal, Drinking Water, Inhalation, Ingestion, XB Testing (No testing because already done) Eco: 3 Water (All releases to water with CC = 1 ppb), XB Testing (Testing desired) OCCUPATIONAL EXPOSURE RATING: 1C NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER. PMN is imported; therefore, manufacturing operations are no assessed.// The submitter was contacted to determine the number of end-use sites and waste handling information of 4/3/2006. The submitter responded on 5/10/2006 that there are less than end-use sites but did not provide waste ahndling information.

Page 2p060370.ce1.txt assessed the releases to uncertain media. POLLUTION PREVENTION CONSIDERATIONS:

EXPOSURE-BASED REVIEW: 1) # of workers exposed: >1000? 2) >100 workers with >10 mg/day inhalation exposure: 3) (a) >100 workers w/1-10 mg/day inh. exp. & >100 days/yr: (b) Routine Dermal Cont: >250 workers & >100 days/yr:

INITIAL REVIEW ENGINEERING REPORT PMN: 06-0370 Use: Number of Sites/ Location: Days/yr Basis:

Process Description:

Page 3p060370.ce1.txt

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

Conservative:

to: from: basis

RELEASE TOTAL kg/yr -

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Page 4p060370.ce1.txt Tot. # of workers exposed via assessed routes: Basis: Inhalation:

Dermal:

Exposure to at concentration High End: Number of workers (all sites) with dermal exposure: Basis:

MEMORANDUM of TELEPHONE CONVERSATION CALL BY: Dan Roper Organization: ERG, for EPA/OPPT/CEB CALL TO: Kisha Pippins Organization: Degussa Corporation Date: 04/03/2006 Time: 8:45 am Phone: Concerning what TSCA ? PMN: 06-0370

Page 5p060370.ce1.txt

MEMORANDUM of TELEPHONE CONVERSATION CALL BY: Greg Macek Organization: USEA/OPPT/OPPT CALL TO: Flora Gasher Organization: Degussa Corporation Date: 08/23/2006 Time: Phone: 9 Concerning what TSCA ? PMN: 06-0370

MEMORANDUM of TELEPHONE CONVERSATION CALL BY: Greg Macek Organization: USEPA/OPPT/EETD CALL TO: Tiana Rosamilia Organization: Evonik Degussa Date: 12/09/2010 Time: 3 pm Phone: Page 6p060370.ce1.txt Concerning what TSCA ? PMN: 06-0370

Page 7