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 

SANITIZED Page 1 of 20
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: Solutio

SANITIZED Page 2 of 20
 

Consumer 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: 

SANITIZED Page 3 of 20
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: No 

SANITIZED Page 4 of 20
STANDARD 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: 

SANITIZED Page 5 of 20
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 REVIEW 

SANITIZED Page 6 of 20
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 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. 

SANITIZED Page 7 of 20
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. 

SANITIZED Page 8 of 20
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/yr 

SANITIZED Page 9 of 20
Number 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. 

SANITIZED Page 10 of 20
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 

site 

SANITIZED Page 11 of 20
to: 

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). 

SANITIZED Page 12 of 20
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. 

SANITIZED Page 13 of 20
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 

sites 

SANITIZED Page 14 of 20
Worst 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: 567 

SANITIZED Page 15 of 20
Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 

2-Hand Dermal Contact with Liquids Model. 

SANITIZED Page 16 of 20
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 mist 

SANITIZED Page 17 of 20
basis: 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 No 

SANITIZED Page 18 of 20
Inhalation 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. 

SANITIZED Page 19 of 20
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. 

SANITIZED Page 20 of 20