p110081.en1.txt

INITIAL REVIEW ENGINEERING REPORT 

PMN: 11-0081

Standard Review Draft II 3/15/2011

ENGINEER: Austin \ JAS

PV (kg/yr): 30,000 Import Only

Revision Notes / Assessment Overview: This IRER

incorporates additional information from submitter on

equipment and drum cleaning residuals. These residuals

will be collected and incinerated, and the sumbitter has

agreed to the condition of no releases to

water.

SUBMITTER: K+S North America

USE: Chemical intermediate for 1H-pyrazole, 3,4-dimethyl-,

 phosphate which will be used as a fertilizer additive.

OTHER USES:

MSDS: Yes Label: No

Gen Eqpt: chemically resistant gloves/ tightly sealed

goggles/ protective work clothing.

Respirator: In case of brief exposure or low pollution

use respiratory filter device (Combination filter: ABEK)

In case of intensive or longer exposure use respiratory

protective device that is independent of circulating air.

Health Effects: Harmful if swallowed / risk of serious

damage to eyes.

TLV/PEL:

Phosphoric acid 8 % 1 mg/m3 OSHA PEL

CRSS :

Chemical Name: 1H-Pyrazole, 3,4-dimethylS-H20: 12.4 g/L @

VP: 8.5E-2 torr @

MW: 96.00 %<500 %<1000

Physical State and Misc CRSS Info:

Neat: Solid Mfg: NK: Import Proc/Form: Solution: Imported

as 72% PMN material in 20% water and 8% phosphoric acid

End Use: Destroyed. Submitted Data: logP = 1.26; pH =

4-6 at 72% in water and phosphoric acid; Viscosity =

20-30 mPas at 72% in water and phosphoric acid.

Literature Data: MP = 152-155 °C, 57-58 °C, 56 °C (CAS

Prop file); BP = 106-107 °C at 11 torr (CAS Prop file).

Estimated Data: BP = 225.5 °C (NOMO5), 216 °C (EPI), 220

°C (ACD); VP = 0.085 torr (NOMO5), 0.14 torr (EPI), 0.17

torr (ACD); WS = 12.4 g/L (EPI), 2.1 g/L (ACD); logP = 1.

15 (EPI), 1.36 (ACD).

Consumer Use: No

SAT (concerns) (12/10/2010):

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Related Cases and Related Cases and Misc SAT Info:

Analogs: 

Migration to groundwater: Rapid

PBT rating: P2B1T2 .

Health: 2 Dermal, Drinking Water, Inhalation

Eco: 2 Water (All releases to water with a CC = 19 ppb.)

OCCUPATIONAL EXPOSURE RATING: 2A

NOTES & KEY ASSUMPTIONS:

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

IRER is for a PMN used as a chemical intermediate. The

cover letter of the submission indicates that the US site

for the proceses involving this PMN has not yet been

determined, and currently provides a single site in New

York. The submitter states that the information will be

provided as soon as possible; therefore the USE sites may

change. This PMN is import only; therefore MFG is not

assessed. The SAT report lists concern for dermal,

inhalation, and drinking water exposures, as well as

releases to water with a CoC of 19 ppb. Migration to gw

is rapid.

POLLUTION PREVENTION CONSIDERATIONS:

P2 Claim: The PMN substance will be completely reacted in

a closed system. There will be essentially no release to

the environment.

EXPOSURE-BASED REVIEW: No

INITIAL REVIEW ENGINEERING REPORT 

PMN: 11-0081

Use: Chemical Intermediate

Number of Sites/ Location: 1

K+S North America New York NY 10605

Days/yr: 100

Basis: The submission specifies 1 site, 100 batches/yr,

300 kg/batch, 24 hr/batch, PMN imported in 72% solution.

Process Description: PMN (72%, liquid) is charged to

reactor --> PMN is 100% consumed in reaction (per

submission and CRSS).

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.

Air

Typical: 9.1E-5 kg/site-day over 100 days/yr from 1 site

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Worst Case: 1.8E-4 kg/site-day over 100 days/yr from 1

site

to: air

from: Unloading Liquid Raw Material from Drums

basis: EPA/OAQPS AP-42 Loading Model.

Air

Output 2: 3.6E-6 kg/site-day over 100 days/yr from 1 site

to: air

from: Cleaning Liquid Residuals from Drums Used to

Transport the Raw Material

basis: EPA/OPPT Penetration Model.

Incineration

High End: 9.0E+0 kg/site-day over 100 days/yr from 1 site

or 9.0E+2 kg/yr

to: POTW (per submission)

from: Cleaning Liquid Residuals from Drums Used to

Transport the Raw Material

basis: EPA/OPPT Drum Residual Model, CEB standard 3%

residual. The submission estimates a general release of <

1 pound/batch of PMN to POTW, but does not discuss

container cleaning. CEB conservatively assesses 3%

residual to water as conservative. Additional submitter

information on drum cleaning residuals was provided.

These residuals will be collected and incinerated, and

the sumbitter has agreed to the condition of a SNUR

with no releases to water

RELEASE TOTAL

9.0E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 3

Basis: The submission estimates a total of 3 workers

during blending operations.

Inhalation:

Exposure to Vapor (Class II)

Typical: 4.4E-2 mg/day over 100 days/yr

Worst Case: 2.6E+0 mg/day over 100 days/yr

Number of workers (all sites) with inhalation exposure: 3

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? 2 Yes

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Exposure to Vapor (Class II)

Typical: 1.7E-3 mg/day over 100 days/yr

Worst Case: 5.1E-2 mg/day over 100 days/yr

Number of workers (all sites) with inhalation exposure: 3

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Basis: Cleaning Liquid Residuals from Drums Used to

Transport the Raw Material; 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 72.00% concentration

High End: 1.3E+3 mg/day over 100 days/yr

Number of workers (all sites) with dermal exposure: 3

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT

2-Hand Dermal Contact with Liquids Model.

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