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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. 
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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: 

basis: 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 3
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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/ Location: 1

Incorez Corporation Middletown CT 06457

Days/yr: 250

Basis: 
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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. CEB
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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/yr
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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: 

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: 

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/yr
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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 REVIEW
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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: 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: