P08-0263 ETD IRER.EN2.txt

INITIAL REVIEW ENGINEERING REPORT 

PMN: 08-0263

Post-Focus Draft Revision 1 2/27/2009

ENGINEER: Austin \ DTN/KPR

PV (kg/yr): 

Revision Notes / Assessment Overview: Feb 2009 revision:

SUBMITTER: 

USE:

OTHER USES:

MSDS: Yes Label: No

Gen Eqpt: face shield, impervious gloves, exhaust ventilation or

other engineering controls to keep the airborne concentration of

vapors below exposure limits.

Respirator: not applicable.

Health Effects: Danger! Causes eye burns, may be harmful if

swallowed. Do not get in eyes, do not ingest, avoid breathing

vapor.

TLV/PEL:

not established.

CRSS (03/10/2008):

Chemical Name: Ethanol, 2,

2'-[[3-[(2-hydroxyethyl)amino]propyl]imino]bis-, N-(hydrogenated

tallow alkyl) derivs.

S-H20: Dispersible g/L @

VP: 1.0E-6 torr @

MW: 458.77 %<500 %<1000

Physical State and Misc CRSS Info:

Neat: Solid (paste) Mfg: Proc/Form:

End Use: 

The MF and MW above are for the substance bearing a C18 alkyl

group. The alkyl chain distribution expected for hydrogenated

tallow is ca. 6% C14, 28% C16 and 66% C18. Submitted Data:

Yellow/brown liquid (paste); BP > 300°C; very slightly soluble

in water; Pour point = 35°C; Cloud point = 75°C; density = 0.93

g/cm3; pH: basic.Estimated Data (EPI with MP = 35°C): BP = 568.

56°C; VP = 8.18E-14 torr; WS = 0.000694 g/L; log P = 6.06. The

PMN substance is estimated to be dispersible in water based on

its structure, and submitter has clarified by phone that it

behaves like a surfactant.

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Consumer Use: 

SAT (concerns) (03/11/2008):

Related Cases and Related Cases and Misc SAT Info:

Migration to groundwater: Negligible

PBT rating: P1B1T1 .

Health: 2 Dermal, Inhalation, 

Eco: 3 Water (All releases to water with a CC =1ppb), 

OCCUPATIONAL EXPOSURE RATING: 1C

NOTES & KEY ASSUMPTIONS:

Generated by the 06/07/2005 version of ChemSTEER. // See

amendment to submission (fax to Sharon Austin on March 19) and

subsequent contact report on March 24. // 

POLLUTION PREVENTION CONSIDERATIONS:

P2 Claims:

 

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INITIAL REVIEW ENGINEERING REPORT 

PMN: 08-0263

MFG: 

Days/yr: 

Basis:

Process Description:

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. 

Conservative: 

 

to: 

from:

basis: 

 

 

 

 

RELEASE TOTAL

 kg/yr - 

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

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:

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Exposure to at concentration

High End: 

Number of workers (all sites) with dermal exposure: 

Basis:

INITIAL REVIEW ENGINEERING REPORT 

PMN: 08-0263

PROC: 

Number of Sites/ Location: Days/yr: 

Basis: 

 

Process Description:

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. Note landfill not required (migration negligible,

drinking water not required)

High End: 

 to: 

from:

basis:

High End: 

to:

from:

basis:

RELEASE TOTAL

 kg/yr - 

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OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis: CEB min number of 3 workers per site.

Inhalation:

Dermal:

Exposure to at concentration

High End: 

Number of workers (all sites) with dermal exposure: 

Basis:

INITIAL REVIEW ENGINEERING REPORT 

PMN: 08-0263

USE 

Number of Sites/ Location: 

Days/yr: 

Basis: 

Process Description: 

 

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. Note landfill not required (migration negligible,

drinking water not required)

Conservative:

to: 

from:

basis:

Output 2:

to: 

from:

basis:

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RELEASE TOTAL

 kg/yr - 

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

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: Kurt Rindfusz

Organization: ERG

CALL TO: 

Organization: 

Date: 03/24/2008

Time: 9:30 AM

Phone: 

PMN: 08-0263

Q1: 

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