STANDARD REVIEW ENGINEERING REPORT SNUN:05-0003 Standard Review Draft 5/4/2005

ENGINEER: Macek \ PRH \ DGR PV (kg/yr): 200,000 Import Only NX

SUBMITTER: Kuraray America, Inc.

USE: Organic solvent of polyurethane plastic coating (50%), solvent used in paint thinner (37.5%), organic solvent of polyurethane resin (6.5%), solvent used in cleaning agent, especially for commercial use (3%), organic solvent for screen ink (3%).

SUMMARY: S-05-0003 was placed into limited standard review based on human health concerns. The Initial Review Engineering Report has been updated to incorporate additional information provided by the submitter which indicated that the percentage of the new chemical substance in the final products is 7% (FAX from Toshihiro Omatsu, Kuraray America, Inc. to Greg Macek of USEPA dated 4/21/05).

A summary of estimates of potential exposure is provided in
the table below

**Scenario No.**  **of Sites**  **No. of**
**Workers Days** 

**per**

**yr Inhalation** 

**- vapor**  **mg/day Inhalation** 

**- mist**  **(mg/day) Dermal**  **(mg/day )** 

Processing 4 12 250 0.33 to
20 - 1800

Use #1: Wood Furniture Coating 143 1000's 250 0.017 to
0.99 10 120 to
610

Use #2: Auto

OEM 1 17 237 0.31 to
18 6.4 120 to
610

Use #3: Cleaning Agent 189 567 250 0.002 to
0.09 - 120**Scenario No.**  **of Sites**  **No. of**
**Workers Days** 

**per**

**yr Inhalation** 

**- vapor**  **mg/day Inhalation** 

**- mist**  **(mg/day) Dermal**  **(mg/day )** 

Use #4:

Screen Printing Ink 27 222 250 0.008 to
0.49 0.3 to
4.3 120

OTHER USES: Same as cases are used as a wetting additive fo ng press fountain solutions. Same as case is a solvent for polyurethane paint for w as replacement for butyl cellosolve analogues. Analog is a resin solvent in paints/coatings (90%); resin solvent in printing and screen inks (10%).

MSDS: Yes Label: No

Gen Eqpt: Use in a totally enclosed system, or with local exhaust ventilation / use chemical goggles (if vapor exposure causes eye discomfort, use a full-face respirator). Respirator: When respiratory protection is required, use an approved air-purifying or positive-pressure supplied-air respirator depending on the potential airborne concentration. Health Effects: may cause moderate eye irritation / prolonged or repeated exposure may cause slight skin irritation. TLV/PEL:

CRSS (03/31/2005): Chemical Name: 1-Butanol, 3-methoxy-3-methyl-, acetate S-H20: 68 g/L @
VP: 4.0E-1 torr @
MW: 160.21 %<500 %<1000 Physical State and Misc CRSS Info: NEAT: Liquid; PROC/FORM: NA; MANUFACTURE: NK (Imported); END USE: SolutioConsumer Use: Yes

SAT (concerns) (04/01/2005): Related Cases and Related Cases and Misc SAT Info:

RELATED CASES:

Migration to groundwater: Moderate PBT rating: P1B1T2 - Health: 1-2 Dermal, Drinking Water, Inhalation, ingestion Eco: 2 Water (All releases to surface waters with CC = 900 ppb.)

OCCUPATIONAL EXPOSURE RATING: 2-3

NOTES & KEY ASSUMPTIONS: Generated by the 05/27/2004 version of ChemSTEER. Consumer use of cleaning agent (3% of PV) could be commercial or consumer per telecon. See telecon for additional information. Found 3 cases: was an inkjet ink and was a D14 drop, was a monomer for polyurethane resin, and ( was a solvent for polyurethane paint). Other similiar cases referenced in the SAT report include

were printing press fountain solutions. Processing to the various end uses used (additive in manufacture of wood panels (65%); solvent in paint formulation (35%)) to determine the number of processing sites; standard CEB assumptions were used for processing. Use #1: Polyurethane plastic coating (50% PV) used the CEB Furniture spray coating scenario based on same use case . Use #2 combines paint thinner use (37.5%) and polyurethane resin use (6.5%) and assessed the combined use as auto OEM painting. Use 3 (cleaning agent -3% of PV) is based on same use case , which references the CEB generic scenario for metal cleaning and degreasing. Use 4 (screen printing ink - 3% of PV) uses same use case and the CEB printing ink generic scenario.

POLLUTION PREVENTION CONSIDERATIONS:P2 Claim: The PMN material is an alternative to butyl cellosolve acetate. The parent compound of the PMN material, 3-methoxy-3-methyl-1-butanol, has been investigated for its toxicity and it has been found to have no indication of reproductive toxicity. In Japan, the PMN material is found to be the best alternative to butyl cellosolve acetate. In Japan, both the parent compound and the PMN material are commonly used as solvents with strong solvency, moderately high boiling point and good volatility rate and is suitable for use in polyurethane paints.

EXPOSURE-BASED REVIEW: NoSTANDARD REVIEW ENGINEERING REPORT SNUN:05-0003

Processing: Formulation

Number of Sites/ Location: 4

Days/yr: 250 Basis: Submission d se sites. based on past case , 250 days/yr (default) - a minimum of 1 processing site per use -> 4 formulation sites. Yrm = 1. Yprod is unknown and will vary by end use.

Process Description: PMN and other starting materials charged to mixing vessel => Formulation blended (7% PMN) => Formulation drummed. (Engineering judgement, past cases)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources to the same medium.

Water or Incineration or Landfill High End: 6.2E+0 kg/site-day over 240 days/yr from 4 sites or 6.0E+3 kg/yr to: On-site WWT or POTW from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. CEB assesses release to water as worst case, media of release is uncertain.

Water or Incineration or Landfill Conservative: 4.0E+0 kg/site-day over 250 days/yr from 4 sites or 4.0E+3 kg/yr to: On-site WWT or POTW from: Equipment Cleaning Losses of Liquids from Multiple
Vessels basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual. CEB assesses release to water as worst case, media of release is uncertain

Air Output 2: 1.2E-5 kg/site-day over 250 days/yr from 4 sites

to:from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Penetration Model.

Air Typical: 3.4E-4 kg/site-day over 250 days/yr from 4 sites Worst Case: 6.9E-4 kg/site-day over 250 days/yr from 4 sites

to: from: Unloading Liquid Raw Material from Drums basis: EPA/OAQPS AP-42 Loading Model.

Air Output 2: 1.9E-1 kg/site-day over 250 days/yr from 4 sites

to: from: Equipment Cleaning Losses of Liquids from Multiple
Vessels basis: EPA/OPPT Mass Transfer Coefficient Model.

Air Typical: 3.4E-4 kg/site-day over 250 days/yr from 4 sites Worst Case: 6.9E-4 kg/site-day over 250 days/yr from 4 sites

to: from: Loading Liquid Product into Drums basis: EPA/OAQPS AP-42 Loading Model.

RELEASE TOTAL 1.0E+4 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers: 12 Days/yr: 250

Inhalation: Assume CEB default of >3 workers per site.

Exposure to Vapor (Class II) Typical: 3.3E-1 mg/day over 250 days/yr Worst Case: 2.0E+1 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 12 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT
Mass Balance Model. NOTE: The respirator class is: II. Gas/vapor (all substances in the gas form).

INHALATION MONITORING DATA REVIEW1) Uncertainty (estimate based on model, regulatory limit or data not specific to industry): Yes 2)a) Exposure level > 1 mg/day? Yes

OR b) Hazard Rating for health of 2 or greater? 1-2 No Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal:

Exposure to Liquid at 100.00% concentration High End: 1.8E+3 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 12 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.STANDARD REVIEW ENGINEERING REPORT SNUN:05-0003

Use 1: Wood Furniture Coating

Number of Sites/ Location: 143

Days/yr: 250 Basis: Submission does not provide use site information. referenced the CEB Spray coating scenario. Assumed Yrm = 0.5 based on scenario, which states 40-60% in solvent-based (high solids) and 14-25% in solvent-based (conventional) metal coatings. CEB assesses 20 sites, based on GS for furniture spray coating, which indicates 0.1 kg coating/unit, 400 units/site-day, 250 days/yr (100,000 kg/yr / 50% x 0.1 x 400 x 250)). estimated 50 sites for 500,000 kg/yr.

Process Description: PMN formulation (7%) received in drums => Loaded in to spray coating system => PMN spray applied to wooden furniture => Coating cured (PMN destroyed).

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources to the same medium.

Water or Incineration or Landfill High End: 4.4E-1 kg/site-day over 48 days/yr from 143 sites or 3.0E+3 kg/yr to: On-site WWT or POTW from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. CEB assesses release to water as worst case, media of release is uncertain.

Air Output 2: 2.4E-6 kg/site-day over 250 days/yr from 143 sites

to: from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Penetration Model.Air Typical: 6.9E-5 kg/site-day over 250 days/yr from 143 sites Worst Case: 1.4E-4 kg/site-day over 250 days/yr from 143 sites

to: from: Unloading Liquid Raw Material from Drums basis: EPA/OAQPS AP-42 Loading Model.

Landfill Output 2: 5.0E+4 kg/yr to: Landfill from: Overspray Losses basis: CEB Generic Scenario for Wood Furniture Spray Coating estimates >50% overspray for air-atomized spraying, release to landfill.

RELEASE TOTAL 5.3E+4 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers: 11,440 Days/yr: 250

Inhalation: Furniture spray scenario indicates up to 40 painters per site and up to 100 total workers per site.

Exposure to Vapor (Class II) Typical: 1.7E-2 mg/day over 250 days/yr Worst Case: 9.9E-1 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 8, Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT
Mass Balance Model. NOTE: The respirator class is: II. Gas/vapor (all substances in the gas form).

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

Exposure to Particulate (Class I) Upper Bound: 1.0E+1 mg/day over 250 days/yrNumber of workers (all sites) with inhalation exposure: 2, Basis: Coating Using Hand-Held Spray Gun; 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? Yes

OR b) Hazard Rating for health of 2 or greater? 1-2 No Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal:

Exposure to Liquid at 7.00% concentration High End: 1.2E+2 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 8,580 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

Exposure to Liquid at 7.00% concentration High End: 6.1E+2 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 2,860 Basis: Coating Using Hand-Held Spray Gun; EPA/OPPT 2-Hand Dermal Immersion in Liquid Model.STANDARD REVIEW ENGINEERING REPORT SNUN:05-0003

Use 2: Solvent Automobile OEM Spray Coating

Number of Sites/ Location: 1

Days/yr: 237 Basis: Submission does not provide use site information. CEB assessment based on GS for Automobile OEM Spray Coating, default solids fraction of 0.25, assess remaining 75% as PMN solvent.

Process Description: Unload coating product containing the assessed chemical from shipping container -> Mix and/or store (optional) -> Transfer to spray gun feed system -> Apply coating to automobile surfaces (some sprayed coating does not remain on the surfaces - it passes into the booth ventilation system and is either captured in exhaust controls or is exhausted into the air through the stack) -> Bake/cure coating at high temperatures (assessed chemical is destroyed or fixed to the coated surface)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources to the same medium.

Water Output 2: 1.2E+1 kg/site-day over 237 days/yr from 1 site

to: from: Automotive OEM Spray Coating Application basis: EPA/OPPT Automobile OEM Coating Overspray Loss Model (non-volatiles).

Air Output 2: 5.2E+0 kg/site-day over 237 days/yr from 1 site

to: from: Automotive OEM Spray Coating Application basis: EPA/OPPT Automobile OEM Coating Overspray Loss Model (non-volatiles).

Air Typical: 6.4E-4 kg/site-day over 237 days/yr from 1 site Worst Case: 1.3E-3 kg/site-day over 237 days/yr from 1 siteto: from: Unloading Liquid Raw Material from Drums basis: EPA/OAQPS AP-42 Loading Model.

Landfill Output 2: 2.7E+4 kg/yr

to: from: Automotive OEM Spray Coating Application basis: EPA/OPPT Automobile OEM Coating Overspray Loss Model (non-volatiles).

RELEASE TOTAL 3.1E+4 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers: 18 Days/yr: 237

Inhalation:

Exposure to Mist (volatile) (Class III) What-If: 6.4E+0 mg/day over 237 days/yr Number of workers (all sites) with inhalation exposure: 17 Basis: Automotive OEM Spray Coating Application; EPA/OPPT Automobile OEM Spray Coating Inhalation Model (non-volatile non-polyisocyanates). NOTE: The respirator class is: III. Combination Gas/Vapor and Particulate (gas and liquid/solid physical forms are both present).

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? Yes

OR b) Hazard Rating for health of 2 or greater? 1-2 No Inhalation Monitoring Data Desired? Yes (both criteria met)

Exposure to Vapor (Class II) Typical: 3.1E-1 mg/day over 237 days/yr Worst Case: 1.8E+1 mg/day over 237 days/yr Number of workers (all sites) with inhalation exposure: 1 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT
Mass Balance Model. NOTE: The respirator class is: II. Gas/vapor (all substances in the gas form).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? Yes

OR b) Hazard Rating for health of 2 or greater? 1-2 No Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal:

Exposure to Liquid at 7.00% concentration High End: 6.1E+2 mg/day over 237 days/yr Number of workers (all sites) with dermal exposure: 17 Basis: Automotive OEM Spray Coating Application; EPA/OPPT 2-Hand Dermal Immersion in Liquid Model.

Exposure to Liquid at 7.00% concentration High End: 1.2E+2 mg/day over 237 days/yr Number of workers (all sites) with dermal exposure: 1 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.STANDARD REVIEW ENGINEERING REPORT SNUN:05-0003

Use 3: Cleaning Agent

Number of Sites/ Location: 189

Days/yr: 250 Basis: Generic scenario for semi aqueous cleaners for metal cleaning and degreasing: 100 gal of cleaner x 3.785 L/gal x| (1+0.20 addition for dragout losses) x 25% PMN = 114 kg/site-yr -> 6,000 kg/yr / 114 kg/site-yr = 53 sites; 250 days/yr (default)

Process Description: PMN is unloaded from drums (7% LVE emulsion) => decanter => sprayed onto part => the part is rinsed => LVE is recycled back into process => excess is sent to onsite wastewater treatment (Generic Scenario for semi solvent cleaners for metal cleaning and degreasing)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources to the same medium.

Water or Incineration or Landfill High End: 4.4E-1 kg/site-day over 2 days/yr from 189 sites or 1.7E+2 kg/yr to: On-site WWT or POTW from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. CEB assesses release to water as worst case, media of release is uncertain.

Air Output 2: 1.1E-7 kg/site-day over 250 days/yr from 189 sites

to: from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Penetration Model.

Air Typical: 3.1E-6 kg/site-day over 250 days/yr from 189 sitesWorst Case: 6.3E-6 kg/site-day over 250 days/yr from 189 sites

to: from: Unloading Liquid Raw Material from Drums basis: EPA/OAQPS AP-42 Loading Model.

Incineration Output 2: 5.8E+3 kg/yr to: Incineration from: Cleaning Bath Dump basis: User-Defined Loss Rate Model. GS and past case L04-0439C estimate bath dumped once per year, release to incineration of all PMN not previously released from container residue.

RELEASE TOTAL 6.0E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers: 567 Days/yr: 250

Inhalation: Assume CEB default of >3 workers per site.

Exposure to Vapor (Class II) Typical: 1.5E-3 mg/day over 250 days/yr Worst Case: 9.0E-2 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT
Mass Balance Model. NOTE: The respirator class is: II. Gas/vapor (all substances in the gas form).

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

Dermal:

Exposure to Liquid at 7.00% concentration High End: 1.2E+2 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 567Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.STANDARD REVIEW ENGINEERING REPORT SNUN:05-0003

Use 4: Screen Printing Ink

Number of Sites/ Location: 37

Days/yr: 250 Basis: Submission does not provide use site information. Based on CEB generic scenario for printing ink number of sites = (59,505 total sites X 6,000 kg/yr / (35% PMN in ink) / (138E6 kg ink/yr) = 7 sites, 5-6 worker, 250 days/yr (default).

Process Description: Screen printing ink (7% PMN) unloaded from drums into ink tank => Ink transferred to ink rollers => Ink coated onto substrate => Ink dried (Generic scenario for Printing Ink, past case )

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources to the same medium. Water - not expected. Generic scenario for printing inks (note from John Blouin, CEB) states printing ink sites will not release to water.

Air Output 2: 5.6E-7 kg/site-day over 250 days/yr from 37 sites

to: from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Penetration Model.

Air Typical: 1.6E-5 kg/site-day over 250 days/yr from 37 sites Worst Case: 3.2E-5 kg/site-day over 250 days/yr from 37 sites

to: from: Unloading Liquid Raw Material from Drums basis: EPA/OAQPS AP-42 Loading Model.

Air Output 2: 4.8E-2 kg/site-day over 250 days/yr from 37 sites

to: from: Printing Press cleaning / printing press mistbasis: EPA/OPPT Mass Transfer Coefficient Model.

Incineration or Landfill High End: 1.8E+2 kg/yr

to: from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. CEB assesses release to water as worst case, media of release is uncertain.

Incineration or Landfill Conservative: 6.0E+1 kg/yr

to: from: Printing Press cleaning / printing press mist basis: EPA/OPPT Single Vessel Residual Model, CEB standard 1% residual. Printing ink generic scenario states that cleaning losses will be a fraction of container losses.

RELEASE TOTAL 6.8E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers: 222 Days/yr: 250

Inhalation: CEB printing ink generic scenario states 5-6 workers. Assumed 3 exposed to unloading/cleaning and 3 from printing press operation.

Exposure to Vapor (Class II) Typical: 8.1E-3 mg/day over 250 days/yr Worst Case: 4.9E-1 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT
Mass Balance Model. NOTE: The respirator class is: II. Gas/vapor (all substances in the gas form).

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 NoInhalation Monitoring Data Desired? No

Exposure to Mist (volatile) (Class III) Median: 3.0E-1 mg/day over 250 days/yr Upper Bound: 4.3E+0 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: Basis: Printing Press cleaning / printing press mist; User-defined Inhalation Model. NOTE: The respirator class is: III. Combination Gas/Vapor and Particulate (gas and liquid/solid physical forms are both present).

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? Yes

OR b) Hazard Rating for health of 2 or greater? 1-2 No Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal:

Exposure to Liquid at 7.00% concentration High End: 1.2E+2 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 111 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

Exposure to Liquid at 7.00% concentration High End: 1.2E+2 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 111 Basis: Printing Press cleaning / printing press mist; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.MEMORANDUM of CBI TELEPHONE CONVERSATION

CALL BY: Paul Hanson Organization: ERG

CALL TO: Toshihiro Omatsu

Organization: Kuraray America, Inc.

Date: 04/04/2005

Time: 11 AM

Phone: 212-986-2230 ext 119

Concerning what TSCA CBI?

SNUN:05-0003

Q1: The MSDS is referenced in the list of attachments, did you attach that?| A1: He faxed the MSDS to Amy Clark (fax 202-564-9490) , but he will fax again to the same number, attention Paul Hanson (ERG). | I notified Daryl Hudson (GeoLogics) to give the MSDS to ERG on Wednesday or to Greg Macek if I am not available. | | Q2: Are you importing the PMN at 100% concentration?| A2: Yes.| | Q3: Do you have any info on number or processing or use sites?| A3: No, they will sell to formulators and end users.| | Q4: Can you clarify the end uses any further, substrates?| A4: No, he can only say it would be typical of use in polyurethanes. He updated the categories of uses as well on page 7 per the request of Amy Clark, he will fax the new page 7 with the MSDS. Q5: Is the cleaning use commercial or potentially consumer?| A5: Could be consumer, it is used as a cleaning agent in Japan, not sure of potential end users in US. Q6: Do you have any information for the percent in formulation for each use. A7: He will have to check with Japan and get back to Greg Macek 202-564-8516 in a few days.