file:///J|/SNURS/SNUR%20Batch%20FY10-3/sanitized%20report/sanitized%20engineering%20reports/p090038.sanitized.eng.txt [5/11/2010 1:13:23 PM] INITIAL REVIEW ENGINEERING REPORT PMN: 09-0038 Focus Ready Draft 11/17/2008

ENGINEER: Macek \ AG PV (kg/yr):

SUBMITTER: Incorez Corporation

USE:

OTHER USES:

MSDS: Yes Label: No

Gen Eqpt: protective gloves (butyl rubber, nitrile, rubber, neoprene or PVC, or viton rubber (fluor rubber)) / safety goggles or face shield / appropriate clothing to prevent skin contact / adequate ventilation Respirator: suitable respiratory equipment with combination filter (type A2/P2) Health Effects: Inhalation may cause damage to mucous membranes in nose, throat, and bronchial system / Ingestion may cause burns in mucous membranes, throat, oesophagus and stomach / Skin contact may cause serious chemical burns of the skin; may cause sensitization by skin contact / Eye contact may cause chemical eye burns TLV/PEL: Not Provided

CRSS : Chemical Name: S-H20: g/L @ VP: 1.5E-3 torr @ MW: 250.00 %<500 %<1000 Physical State and Misc CRSS Info:

Consumer Use: No

SAT (concerns) (11/07/2008): Migration to groundwater: Negligible PBT rating: P1B1T2 Health: 2 Dermal, Inhalation Eco: 3 Water (All releases to water with a CC = 1 ppb)

OCCUPATIONAL EXPOSURE RATING: 2-3C

NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER.file:///J|/SNURS/SNUR%20Batch%20FY10-3/sanitized%20report/sanitized%20engineering%20reports/p090038.sanitized.eng.txt [5/11/2010 1:13:23 PM] POLLUTION PREVENTION CONSIDERATIONS: None.

EXPOSURE-BASED REVIEW: No

INITIAL REVIEW ENGINEERING REPORT PMN: 09-0038

Manufacturing:

Number of Sites/ Location: 1 Incorez Corporation Middletown CT 06457 Days/yr: 10 Basis: Submission provides max PV of kg/yr, 1 MFG site, kg/site-bt, 8 hr/bt, and 5 bt/year. To match max PV, CEB scales up to 10 bt/year using kg/site-bt. PMN is 100% concentration.

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.

Water or Incineration or Landfill Conservative: 2.0E+1 kg/site-day over 10 days/yr from 1 site or 2.0E+2 kg/yr to: Uncertain from: ba sis: CEB assesses to uncertain media.

Air Typical: 2.0E-5 kg/site-day over 10 days/yr from 1 site Worst Case: 4.0E-5 kg/site-day over 10 days/yr from 1 site to: Air from:

Air Output 2: 2.5E-4 kg/site-day over 10 days/yr from 1 site to: Air from: basis:

RELEASE TOTAL 2.0E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 3 Basis: Submission indicates 2 workers exposed. CEB assesses 3file:///J|/SNURS/SNUR%20Batch%20FY10-3/sanitized%20report/sanitized%20engineering%20reports/p090038.sanitized.eng.txt [5/11/2010 1:13:23 PM] workers/site exposed as minimum default.

Inhalation:

Exposure to Vapor (Class II) Typical: 9.6E-3 mg/day over 10 days/yr Worst Case: 5.8E-1 mg/day over 10 days/yr Number of workers (all sites) with inhalation exposure: 3 Basis: 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? 2 Yes Inhalation Monitoring Data Desired? Yes (both criteria met)

Exposure to Vapor (Class II) Typical: 1.5E-3 mg/day over 10 days/yr Worst Case: 1.3E-2 mg/day over 10 days/yr Number of workers (all sites) with inhalation exposure: 3 Basis: 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? 2 Yes Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal:

Exposure to Liquid at 100.00% concentration High End: 1.8E+3 mg/day over 10 days/yr Number of workers (all sites) with dermal exposure: 3 Basis:

INITIAL REVIEW ENGINEERING REPORT PMN: 09-0038

Processing:

Number of Sites/ Locatio n: 1 Incorez Corporation Middletown CT 06457 Days/yr: 250 Basis:file:///J|/SNURS/SNUR%20Batch%20FY10-3/sanitized%20report/sanitized%20engineering%20reports/p090038.sanitized.eng.txt [5/11/2010 1:13:23 PM] 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.

Water or Incineration or Landfill High End: 6.2E+0 kg/site-day over 96 days/yr from 1 site or 6.0E+2 kg/yr to: Uncertain from: basis: CEB assesses to uncertain media.

Water or Incineration or Landfill Conservative: 8.0E-1 kg/site-day over 250 days/yr from 1 site or 2.0E+2 kg/yr to: Uncertain from: basis: CEB assesses to uncertain media.

Air Typical: 8.0E-7 kg/site-day over 250 days/yr from 1 site Worst Case: 1.6E-6 kg/site-day over 250 days/yr from 1 site to: Air from: basis:

Air Output 2: 2.6E-8 kg/site-day over 250 days/yr from 1 site to: Air from: basis:

Air Output 2: 2.5E-4 kg/site-day over 250 days/yr from 1 site to: Air from: basis:

Air Typical: 8.0E-7 kg/site-day over 250 days/yr from 1 site Worst Case: 1.6E-6 kg/site-day over 250 days/yr from 1 site to: Air from: basis:

RELEASE TOTAL 8.0E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 3 Basis: Submission does not provide processing information. CEBfile:///J|/SNURS/SNUR%20Batch%20FY10-3/sanitized%20report/sanitized%20engineering%20reports/p090038.sanitized.eng.txt [5/11/2010 1:13:23 PM] assesses 3 workers/site.

Inhalation:

Exposure to Vapor (Class II) Typical: 3.8E-4 mg/day over 250 days/yr Worst Case: 2.3E-2 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 3 Basis: 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? 2 Yes Inhalation Monitoring Data Desired? Yes (both criteria met)

Exposure to Vapor (Class II) Typical: 1.2E-5 mg/day over 250 days/yr Worst Case: 3.7E-4 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 3 Basis: 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? 2 Yes Inhalation Monitoring Data Desired? Yes (both criteria met)

Exposure to Vapor (Class II) Typical: 1.5E-3 mg/day over 250 days/yr Worst Case: 1.3E-2 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 3 Basis: 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? 2 Yes Inhalation Monitoring Data Desired? Yes (both criteria met)

Exposure to Vapor (Class II) Typical: 3.8E-4 mg/day over 250 days/yrfile:///J|/SNURS/SNUR%20Batch%20FY10-3/sanitized%20report/sanitized%20engineering%20reports/p090038.sanitized.eng.txt [5/11/2010 1:13:23 PM] Worst Case: 2.3E-2 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 3 Basis: Loading Liquid Product into 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? 2 Yes 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: 3 Basis:

Exp osure 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: 3 Basis:

INITIAL REVIEW ENGINEERING REPORT PMN: 09-0038

Use:

Number of Sites/ Location: 2 Unknown Sites Days/yr: 250 Basis: Submission does not provide use information.

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.

Water or Incineration or Landfill High End: 6.2E+0 kg/site-day over 48 days/yr from 2 sites or 6.0E+2 kg/yr to: Uncertain from: basis:

Water or Incineration or Landfill Conservative: 8.0E-1 kg/site-day over 250 days/yr from 2 sites or 4.0E+2 kg/yrfile:///J|/SNURS/SNUR%20Batch%20FY10-3/sanitized%20report/sanitized%20engineering%20reports/p090038.sanitized.eng.txt [5/11/2010 1:13:23 PM] to: Water, Incineration or Landfill from: basis:

Air Typical: 4.0E-7 kg/site-day over 250 days/yr from 2 sites Worst Case: 8.0E-7 kg/site-day over 250 days/yr from 2 sites to: Air from: basis: Air Output 2: 1.3E-8 kg/site-day over 250 days/yr from 2 sites to: Air from: basis:

Air Output 2: 3.0E+0 kg/site-day over 250 days/yr from 2 sites to: Uncertain from: basis: .

Air Output 2: 9.9E-4 kg/site-day over 250 days/yr from 2 sites
to: from: basis:

Incineration or Landfill Output 2: 2.7E+1 kg/site-day over 250 days/yr from 2 sites or 1.4E+4 kg/yr to: Uncertain from: basis:

RELEASE TOTAL 1.6E+4 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 40 Basis: CEB assesses 20 workers/site according to .

Inhalation:

Exposure to Vapor (Class II) Typical: 1.9E-4 mg/day over 250 days/yr Worst Case: 1.2E-2 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 40 Basis: NOTE: The respirator class is: II. Gas/vapor (all substances in the gas form).

INHALATION MONITORING DATA REVIEWfile:///J|/SNURS/SNUR%20Batch%20FY10-3/sanitized%20report/sanitized%20engineering%20reports/p090038.sanitized.eng.txt [5/11/2010 1:13:23 PM] 1) Uncertainty (estimate based on model, regulatory limit, or data not specific to indus try): Yes 2)a) Exposure level > 1 mg/day? No OR b) Hazard Rating for health of 2 or greater? 2 Yes Inhalation Monitoring Data Desired? Yes (both criteria met)

Exposure to Vapor (Class II) Typical: 6.1E-6 mg/day over 250 days/yr Worst Case: 1.8E-4 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 40 Basis: 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? 2 Yes Inhalation Monitoring Data Desired? Yes (both criteria met)

Exposure to Particulate (Class I) Upper Bound: 1.5E+2 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 40 Basis: 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? 2 Yes 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: 40 Basis: