p110044.eng.txt

INITIAL REVIEW ENGINEERING REPORT 

PMN: 11-0044

Focus Ready Draft 11/15/2010

ENGINEER: Jon \ CLM

PV (kg/yr): 10,000

SUBMITTER: Gelest, Inc.

USE: Chemical intermediate to end-cap silicones (95%) and

research (5%).

OTHER USES

MSDS: Yes Label: No

Gen Eqpt: Local exhaust is required. Mechanical is

recommended. Chemical worker's goggles. Rubber, neoprene

or nitrile gloves.

Respirator: If exposure exceeds TLV, NIOSH approved

organic vapor respirator.

Health Effects: May cause immediate or delayed severe eye

irritation. Skin contact: No information available. Avoid

Contact. Inhalation: No information available. Avoid

inhalation.

TLV/PEL:

none established

CRSS :

Chemical Name: Disiloxane, 1,3-dibutyl-1,1,3,

3-tetramethylS-H20: 0.000001 g/L @

VP: 1.6E-1 torr @

MW: 247.00 %<500 %<1000

Physical State and Misc CRSS Info:

Neat: Liquid Mfg: Liquid Proc/Form: NA End Use: Destroyed.

 Submitted data: liquid; MP < -30 °C; BP = 78 °C at 4

torr; insoluble in water; flash point = 76 °C; density =

0.809 g/cc. Literature data (STN eprop): BP = 77.5 °C at

3.8 torr. NOMO5 (Class 2) estimated data from BP = 78 °C

at 4 torr: BP = 221 °C and VP = 0.16 torr. EPI estimated

data (input MP = 20 °C): BP = 218 °C; VP = 0.143 torr; WS

= 1.17E-6 g/L; log P = 7.71. ACDLabs estimated (STN

pprop): BP = 221 °C; VP = 0.164 torr; WS = 0.012 g/L; log

P = 5.525.

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Consumer Use: No

SAT (concerns) (11/05/2010):

Related Cases and Related Cases and Misc SAT Info:

Ecotox Related Cases:

Migration to groundwater: Negligible

PBT rating: P1B2T2 -

Health: 1-2 Dermal, Drinking Water, Inhalation

Eco: 3 Water (All releases to water with a CC = 1.00 ppb)

OCCUPATIONAL EXPOSURE RATING: 2-3B

NOTES & KEY ASSUMPTIONS:

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

PMN is part of a reaction series: P11-0043 (same

submitter, concurrently submitted) -> P11-0044. Changes

to either IRER may affect the other. The technical

contact was called to clarify information provided in

both submissions -- see Contact Report for P11-0043. This

IRER presents releases to incineration and air, and

dermal and inahalation exposures to liquid.

POLLUTION PREVENTION CONSIDERATIONS:

P2 Claim: At Gelest the standard operating procedure is

for the larger reactors, greater than 100 L, to be vented

to a scrubber system thus minimizing the amount of

material released to the atmosphere. Residual organic

materials and wash solvents are off-site incinerated.

This material would be run in reactors greater than 100 L

in size. The smaller scale reactions are run in flasks up

to 22 L in size and these are carried out in fume hoods

that are also connected to the scrubber system. Again the

residuals and wash solvents are off-site incinerated.

This process would be run in reactors up to 1000 gallon

in size.

EXPOSURE-BASED REVIEW: No

INITIAL REVIEW ENGINEERING REPORT 

PMN: 11-0044

Manufacturing

Number of Sites/ Location: 1

Gelest Morrisville PA 19067

Days/yr: 24

Basis: Submission specifies 1 site, 24 bt/yr, 72 hr/bt,

up to 500 kg/bt. ChemSTEER calculates 417 kg/bt.

Process Description: Charge raw materials to reactor,

including P11-0043 --> PMN formed --> Separation of

layers, aqueous layer disposed --> Crude product

distillation --> Purified product packaging (liquid, 100%

PMN). (Submission)

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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. Note, submission estimates a total of

0.4 kg/bt released to fugitive air during manufacturing,

which is more conservative than the sum of air emissions

calculated according to standard CEB models during

equipment cleaning and loading. CEB standard release

models are presented to generate parameters required for

inhalation models.

Air

Output 2: 1.1E-1 kg/site-day over 24 days/yr from 1 site

to: air

from: Equipment Cleaning Losses of Liquids from Multiple

Vessels

basis: EPA/OPPT Mass Transfer Coefficient Model.

Air

Typical: 4.4E-4 kg/site-day over 24 days/yr from 1 site

Worst Case: 8.9E-4 kg/site-day over 24 days/yr from 1 site

to: air

from: Loading Liquid Product into Drums

basis: EPA/OAQPS AP-42 Loading Model.

Air

Output 2: 4.0E-1 kg/site-day over 24 days/yr from 1 site

to: air, controlled by scubber (submission)

from: Fugitive Air Releases (Submission estimate)

basis: User-Defined Loss Rate Model. Submission estimates

a total of 0.4 kg/bt released to fugitive air during

manufacturing, which is more conservative than the sum of

air emissions calculated according to standard CEB models

during equipment cleaning and loading.

Incineration

Conservative: 8.3E+0 kg/site-day over 24 days/yr from 1

site

or 2.0E+2 kg/yr

to: off-site TSDF, incineration (submission)

from: Equipment Cleaning Losses of Liquids from Multiple

Vessels

basis: EPA/OPPT Multiple Process Vessel Residual Model,

CEB standard 2% residual. Submission specifies aqueous

separation layer and distillation forecut/residue

disposed off-site. Submission states: "For off-site waste

handling, Gelest employs an outside firm that transports

the waste to a federally permitted hazardous waste TSDF ..

. This pertains to any residual material rinsed from

containers or reactors as well." Submission contact adds

that organic wastes such as from this operation will be

incinerated at the TSDF.

RELEASE TOTAL

2.1E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 4

Basis: Submission indicates up to 4 workers/site present

during mfg. As conservative, CEB assumes same 4 workers

participate in each activity resulting in inhalation

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exposure to vapor.

Inhalation:

Exposure to Vapor (Class II)

Typical: 6.4E-1 mg/day over 24 days/yr

Worst Case: 5.7E+0 mg/day over 24 days/yr

Number of workers (all sites) with inhalation exposure: 4

Basis: Equipment Cleaning Losses of Liquids from Multiple

Vessels; 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? 1-2 No

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Exposure to Vapor (Class II)

Typical: 2.1E-1 mg/day over 24 days/yr

Worst Case: 1.3E+1 mg/day over 24 days/yr

Number of workers (all sites) with inhalation exposure: 4

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? Yes

 OR

 b) Hazard Rating for health of 2 or greater? 1-2 No

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Exposure to Liquid at 100.00% concentration

High End: 1.8E+3 mg/day over 24 days/yr

Number of workers (all sites) with dermal exposure: 4

Basis: Loading Liquid Product into Drums; EPA/OPPT 2-Hand

Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 11-0044

Use: Conversion into silocones

Number of Sites/ Location: 1

Gelest Morrisville PA 19067

Days/yr: 24

Basis: Submission specifies 1 site, 24 bt/yr, 72 hr/bt,

up to 500 kg/bt. ChemSTEER calculates 417 kg/bt.

Process Description: PMN (liquid, 100%) converted into

silicones via reaction. (per Submitter Contact)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

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IRER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources

to the same medium. Note, submission estimates a total

of 1.4 kg/bt released to fugitive air during use, which

is more conservative than the sum of air emissions

calculated according to standard CEB models during

unloading and container cleaning. CEB standard release

models are presented to generate parameters required for

inhalation models.

Air

Typical: 4.4E-4 kg/site-day over 24 days/yr from 1 site

Worst Case: 8.9E-4 kg/site-day over 24 days/yr from 1 site

to: air

from: Unloading Liquid Raw Material from Drums

basis: EPA/OAQPS AP-42 Loading Model.

Air

Output 2: 1.4E-5 kg/site-day over 24 days/yr from 1 site

to: air

from: Cleaning Liquid Residuals from Drums Used to

Transport the Raw Material

basis: EPA/OPPT Penetration Model.

Air

Output 2: 1.4E+0 kg/site-day over 24 days/yr from 1 site

to: air

from: Fugitive Air Release (Submission estimate)

basis: User-Defined Loss Rate Model. Submission estimates

a total of 1.4 kg/bt released to fugitive air during use,

which is more conservative than the sum of air emissions

calculated according to standard CEB models during

unloading and container cleaning.

Incineration

High End: 1.2E+1 kg/site-day over 24 days/yr from 1 site

or 3.0E+2 kg/yr

to: off-site TSDF, incineration (submission)

from: Cleaning Liquid Residuals from Drums Used to

Transport the Raw Material

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

residual. Submission states: "For off-site waste handling,

 Gelest employs an outside firm that transports the waste

to a federally permitted hazardous waste TSDF ... This

pertains to any residual material rinsed from containers

or reactors as well." Submission contact adds that

organic wastes such as from this operation will be

incinerated at the TSDF.

RELEASE TOTAL

3.3E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 7

Basis: Submission indicates up to 7 workers/site present

during mfg. As conservative, CEB assumes same 7 workers

participate in each activity resulting in inhalation

exposure to vapor.

Inhalation:

Exposure to Vapor (Class II)

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Typical: 2.1E-1 mg/day over 24 days/yr

Worst Case: 1.3E+1 mg/day over 24 days/yr

Number of workers (all sites) with inhalation exposure: 7

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? 1-2 No

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Exposure to Vapor (Class II)

Typical: 6.8E-3 mg/day over 24 days/yr

Worst Case: 2.0E-1 mg/day over 24 days/yr

Number of workers (all sites) with inhalation exposure: 7

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? 1-2 No

Inhalation Monitoring Data Desired? No

Dermal:

Exposure to Liquid at 100.00% concentration

High End: 1.8E+3 mg/day over 24 days/yr

Number of workers (all sites) with dermal exposure: 7

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

2-Hand Dermal Contact with Liquids Model.

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