INITIAL REVIEW ENGINEERING REPORT PMN: 12-0073 Focus Ready Draft 12/15/2011 ENGINEER: Jon \ JAS PV (kg/yr): 63,000 SUBMITTER: H.B.Fuller Company USE:

OTHER USES: MSDS: No Label: No TLV/PEL: none established.

CRSS : Chemical Name: S-H20: Reacts g/L @ VP: 1.0E-6 torr @ MW: Physical State and Misc CRSS Info: Neat: Solid

Consumer Use: SAT (concerns) (12/09/2011): Related Cases and Related Cases and Misc SAT Info: Ecotox Related Caes: Migration to groundwater: Negligible PBT rating: P3B1T1 PMN: P1B1T1 Health: 1-2 Dermal, Inhalation Eco: 1 No releases to Water Page 1p120073.eng.txt OCCUPATIONAL EXPOSURE RATING: 1A NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER.

POLLUTION PREVENTION CONSIDERATIONS: No Pollution Prevention information provided by the submitter. EXPOSURE-BASED REVIEW: No

 INITIAL REVIEW ENGINEERING REPORT PMN: 12-0073 Page 2p120073.eng.txt Number of Sites/ Location: 1 H.B. Fuller Company Grand Rapids MI 49544-1198 H.B. Fuller Pilot Facility Vadnais Heights MN 55110 Days/yr: 67 Basis: The submission indicates 2 sites (CEB assessed one site, since one site is a pilot site), 3,000 kg/batch (max), 7 hr/batch, 67 batches.yr. PMN manufactured at 69. 22% concentration. CEB assumes 2 sites, 67 batches/site-yr. CS calculates 940.3 kg PMN/batch. Process Description

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY IRER Note: The submission indicates that 0.5 kg/batch is sent for off-site incineration , and 0.5 kg/batch is sent for off-site incineration The submission does not address CEB does not assess these releases below because or SAT requirements or triggers were not met: WATER - not required, per SAT; LAND - migration to gw is negl; AIR - VP < 0.01 torr; INCIN - releases << 28, 000 kg/site-day.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 6 Basis: The submission indicates up to 4 total workers may be potentially exposed. CEB assumes the std. default minimum of 3 workers/site. Inhalation: negligible (VP < 0.001 torr)

Dermal: Exposure to Liquid at 69.22% concentration High End: 1.2E+3 mg/day over 67 days/yr Number of workers (all sites) with dermal exposure: 3 Basis: EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

 INITIAL REVIEW ENGINEERING REPORT PMN: 12-0073

Number of Sites/ Location: 1 Axion Water San Diego CA Page 3p120073.eng.txt Days/yr: 250 Basis: The submission estimates 1 customer site. CEB assumes 250 days/yr. CS calculates 252 kg/site-batch. Process Description:

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY IRER Note: The submission indicates that 0.8 kg/batch is landfilled from , and 0.2 kg/batch is landfilled

. CEB does not assess releases below because or SAT requirements or triggers were not met: WATER - not required, per SAT; LAND - migration to gw is negl; AIR - VP < 0.01 torr - mists are not expected (see contact report); INCIN - releases << 28,000 kg/site-day.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 3 Basis: The submission estimates up to 2 workers potentially exposed. CEB assesses the std default minimum of 3 workers/site. Inhalation: negligible (VP < 0.001 torr).

Dermal: Exposure to Liquid at 69.22% concentration High End: 1.2E+3 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 3 Basis: EPA/OPPT 2-Hand Dermal Contact with Liquids Model.



MEMORANDUM of CBI TELEPHONE CONVERSATION CALL BY: Jason A. Sese Organization: ERG for CEB Page 4p120073.eng.txt CALL TO: Christine Griese Organization: Senior Chemist - H.B. Fuller Date: 12/12/2011 Time: 2:35 PM Phone:

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