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. Page 1p110044.eng.txt

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) Page 2p110044.eng.txt

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 Page 3p110044.eng.txt 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 Page 4p110044.eng.txt 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) Page 5p110044.eng.txt 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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