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): Page 1p110081.en1.txt 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 Page 2p110081.en1.txt 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 Page 3p110081.en1.txt 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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