INITIAL REVIEW ENGINEERING REPORT

PMN: 13-0931 

Post-Focus Draft Revision 2 1/16/2014

PV (kg/yr): 10,000 

ENGINEER: Macek \ AH \ REC 

Revision Notes / Assessment Overview: Revision #2 (1/16/14): Submitter 

indicated that the physical state of the PMN material as neat material

and as processed and used is as a liquid (See contact report of 1/15/14

and MSDS). Therefore, CEB's models for estimating losses associated

with transfer of solids are no longer applicable. Since the PMN 

chemical is a liquid with a v.p. of 0.001 torr, CEB ran applicable models

to estimate air releases and vapor inhalation exposure. In amendment

as well as in the 1/15/14 telecon the submitter indicated that there

are no water releases from the site. | | | | Revision #1(1/8/2014: 

Submitter provided additional information on the production volume, 

category of use, mass balance and procedure, and MSDS within an Amendment

submitted on 12/12/2013. Per Amendment, PV increased from 5,000 kg 

PMN/yr to 10,000 kg PMN/yr. Category of use changed to site limited 

endcapping agent for novel reactive polymers. Manufacturing releases

for filter media disposal and stripping wastes to incineration have been

added per the Amended Exposure and Release Data provided. MSDS 

information updated within the current assessment. 

SUBMITTER: Henkel Corporation 

USE: Revision 1/8/2014: Site limited endcapping agent for novel reactive

polymers. /// Polymerizable component (monomer) in adhesive 

formulations. Analog L-05-430 is used as a monomer for adhesives for

DVDs. Analog L-98-117 is used as a component of adhesives for plastic.

OTHER USES: CA 151:537063, 131:291346, 130:200949 - Ophthalmic device 

material with high refractive index. CA 149:62770 - Production of 

polymeric ocular drug delivery devices. CA 131:291344 - Component of 

intraocular lens coating composition. CA 105:99271 - Reactive diluent 

for photocurable coatings for optical fibers. Analog P-01-579 is used 

as a component of radiation cured coatings. Analog P-01-420 is used 

as a monomer. Analogs P-08-161 and P-07-599 are used as monomers for 

optical film resins. 

EPA SANITIZED Page 1 of 14
MSDS: Yes Label: No

Gen Eqpt: Safety goggles or safety glasses with side shields. // Chemical

resistant, impermeable gloves. 

Respirator: A NIOSH-approved air-purifying respirator with an organic 

vapor cartridge or canister may be permissible under certain 

circumstances where airborne concentrations are expected to exceed 

exposure limits. Protection provided by air-purifying respirators is 

limited. Use a positive-pressure, air-supplied respirator if there is 

any potential for uncontrolled release, exposure levels are not known

or any other circumstances where air-purifying respirators may not 

provide adequate protection. 

Health Effects: Inhalation: May cause respiratory tract irritation. //

Skin contact: Irritating to skin. // Eye contact: Moderate eye 

irritation. // Ingestion: Not expected under normal conditions of use.

// Existing conditions aggravated by exposure: Eye, skin, and 

respiratory disorders. 

TLV/PEL: 

None established. 

CRSS (10/21/2013): 

Chemical Name: 2-Propenoic acid, 4-phenoxybutyl ester 

S-H20: 0.0394 g/L @ 

Physical State and Misc CRSS Info: 

MW: 220.00 %<500 %<1000

VP: 1.0E-3 torr @ 

Neat: Solid Mfg: Solid Proc/Form: Solution (Est.): 10% PMN material in

adhesive End Use: Destroyed. Submitted Properties: None. The GC-MS and 

1H-NMR spectra are included with the PMN submission. The 1H-NMR 

spectrum is consistent with the structure submitted. Estimated 

Properties: BP = 300 °C (EPI), 324 °C (ACD); VP = 0.00101 torr (EPI), 

0.00024 torr (ACD); WS = 0.0394 g/L (EPI), 0.24 g/L (ACD); logP = 3.44

(EPI), 3.33 (ACD). 

Consumer Use: No 

SAT (concerns) (10/22/2013):

Analogs: .

Related Cases and Misc SAT Info: 

Migration to groundwater: Negligible 

PBT rating: P1B1T1 

Health: 1-2 Dermal, Drinking Water, Inhalation 

Eco: 3 Water (All releases to water with a CC = 1 ppb) 

EPA SANITIZED Page 2 of 14
EPA SANITIZED Page 3 of 14
INITIAL REVIEW ENGINEERING REPORT 

PMN: 13-0931 

Manufacturing 

Henkel Salisbury Salisbury NC 28147

Number of Sites/ Location: 1 

Days/yr: 100 

Basis: Revision 1/8/2014: Submitter increased PV from 5,000 kg PMN/yr

to 10,000 kg PMN/yr. CEB assumes 1 site, 100 kg/bt, and 100% PMN in 

product; CS calculates 100 batches/site-yr. /// Per submission: 1 site, 

100 kg/bt, 15 hr/bt, and 50 bt/yr. 

Process Description: Raw materials (liquid) --> reactor 1 -->

filtration --> phase separation --> liquid extraction --> vacuum -->

PMN product (liquid, 100%) stored on-site (submitter stated in 1/15/14 

telecon and also indicated in phone log that the PMN material is a 

liquid). 

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. Revision 

1/8/2013: Per 12/12/2014 Amendment (Exposure and Release Data), no water

releases are expected. /// Note the PMN is slightly volatile; 

therefore, fugutive losses are assessed using std. CEB models. 

EPA SANITIZED Page 4 of 14
Air 

Typical: 6.0E-7 kg/site-day over 100 days/yr from 1 site 

or 6.0E-5 kg/site-yr from 1 site or 6.0E-5 kg/yr-all sites 

Worst Case: 1.2E-6 kg/site-day over 100 days/yr from 1 site 

or 1.2E-4 kg/site-yr from 1 site or 1.2E-4 kg/yr-all sites 

to: 

from: Loading Liquid Product into Drums 

basis: EPA/OAQPS AP-42 Loading Model. 

Air 

Output 2: 1.5E-4 kg/site-day over 100 days/yr from 1 site 

or 1.5E-2 kg/site-yr from 1 site or 1.5E-2 kg/yr-all sites 

to: 

from: Equipment Cleaning Losses of Liquids from a Single, Large Vessel

basis: EPA/OPPT Mass Transfer Coefficient Model. 

Incineration 

Output 2: 1.0E-1 kg/site-day over 100 days/yr from 1 site 

or 1.0E+1 kg/site-yr from 1 site or 1.0E+1 kg/yr-all sites 

to: Incineration (per amendment 12/12/2013) 

from: Filter Media Changeout 

basis: User-Defined Loss Rate Model. Per 12/12/2013 Amendment (Exposure

and Release Data), submitter estimates a release on 0.1 kg/bt to 

incineration from filter wastes. 

Incineration 

Output 2: 1.0E-1 kg/site-day over 100 days/yr from 1 site 

or 1.0E+1 kg/site-yr from 1 site or 1.0E+1 kg/yr-all sites 

to: Incineration (per amendment 12/12/2013) 

from: Stripping Wastes 

basis: User-Defined Loss Rate Model. Per 12/12/2013 Amendment (Exposure

and Release Data), submitter estimates 0.1 kg/bt released to 

incineration from stripping wastes. 

Incineration 

Conservative: 1.0E+0 kg/site-day over 100 days/yr from 1 site

or 1.0E+2 kg/site-yr from 1 site or 1.0E+2 kg/yr-all sites 

to: Incineration 

from: Equipment Cleaning Losses of Liquids from a Single, Large Vessel

basis: EPA/OPPT Single Vessel Residual Model, CEB standard 1% residual.

Submission estimates 0.1 kg/bt (0.1% loss) sent to off-site incineration 

as hazardous waste. CEB default of 1% loss is assessed as conservative.

RELEASE TOTAL 

EPA SANITIZED Page 5 of 14
1.2E+2 kg/yr - all sites 

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 4

Basis: 

EPA SANITIZED Page 6 of 14
Inhalation: 

Exposure to Vapor (volatile) (Class II)

Typical: 

> Potential Dose Rate: 2.9E-4 mg/day over 100 days/yr 

> Lifetime Average Daily Dose: 6.4E-7 mg/kg-day over 100 days/yr

> Average Daily Dose: 1.1E-6 mg/day over 100 days/yr 

> Acute Potential Dose: 4.1E-6 mg/day over 100 days/yr 

Worst Case: 

> Potential Dose Rate: 1.7E-2 mg/day over 100 days/yr 

> Lifetime Average Daily Dose: 3.8E-5 mg/kg-day over 100 days/yr

> Average Daily Dose: 6.7E-5 mg/day over 100 days/yr 

> Acute Potential Dose: 2.5E-4 mg/day over 100 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? No 

 OR 

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

=> Inhalation Monitoring Data Desired? No

Exposure to Vapor (volatile) (Class II)

Typical: 

> Potential Dose Rate: 9.2E-4 mg/day over 100 days/yr 

> Lifetime Average Daily Dose: 2.1E-6 mg/kg-day over 100 days/yr

> Average Daily Dose: 3.6E-6 mg/day over 100 days/yr 

> Acute Potential Dose: 1.3E-5 mg/day over 100 days/yr 

Worst Case: 

> Potential Dose Rate: 8.3E-3 mg/day over 100 days/yr 

> Lifetime Average Daily Dose: 1.9E-5 mg/kg-day over 100 days/yr

> Average Daily Dose: 3.3E-5 mg/day over 100 days/yr 

> Acute Potential Dose: 1.2E-4 mg/day over 100 days/yr 

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

Basis: Equipment Cleaning Losses of Liquids from a Single, Large Vessel;

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 

EPA SANITIZED Page 7 of 14
 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: 

> Potential Dose Rate: 2.2E+3 mg/day over 100 days/yr 

> Lifetime Average Daily Dose: 5.0E+0 mg/day over 100 days/yr

> Average Daily Dose: 8.8E+0 mg/day over 100 days/yr 

> Acute Potential Dose: 3.2E+1 mg/day over 100 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. 

Exposure to Liquid at 100.00% concentration

High End: 

> Potential Dose Rate: 2.2E+3 mg/day over 100 days/yr 

> Lifetime Average Daily Dose: 5.0E+0 mg/day over 100 days/yr

> Average Daily Dose: 8.8E+0 mg/day over 100 days/yr 

> Acute Potential Dose: 3.2E+1 mg/day over 100 days/yr 

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

Basis: Equipment Cleaning Losses of Liquids from a Single, Large Vessel;

EPA/OPPT 2-Hand Dermal Contact with Liquids Model. 

EPA SANITIZED Page 8 of 14
INITIAL REVIEW ENGINEERING REPORT 

PMN: 13-0931 

Use: Site-limited Chemical Intermediate

Henkel Salisbury Salisbury NC 28147

Number of Sites/ Location: 1 

Days/yr: 100 

Basis: Revision 1/8/2014:Submitter increased PV from 5,000 kg PMN/yr

to 10,000 kg PMN/yr. CEB assumes 100 bt/site-yr as the polymerization 

occurs at the mfg site. CS calculates a use rate of 100 kg PMN/st-bt. 

/// Per technical contact, polymerization occurs at the mfg site. CEB

assumes 50 bt/site-yr. 

Process Description: PMN (liquid, 100%) --> charged into reaction 

vessel --> polymerized and destroyed (technical contact) 

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. 

EPA SANITIZED Page 9 of 14
Air 

Typical: 6.0E-7 kg/site-day over 100 days/yr from 1 site 

or 6.0E-5 kg/site-yr from 1 site or 6.0E-5 kg/yr-all sites 

Worst Case: 1.2E-6 kg/site-day over 100 days/yr from 1 site 

or 1.2E-4 kg/site-yr from 1 site or 1.2E-4 kg/yr-all sites 

to: 

from: Unloading Liquid Raw Material from Drums 

basis: EPA/OAQPS AP-42 Loading Model. 

Air 

Output 2: 2.0E-8 kg/site-day over 100 days/yr from 1 site 

or 2.0E-6 kg/site-yr from 1 site or 2.0E-6 kg/yr-all sites 

to: 

from: Cleaning Liquid Residuals from Drums Used to Transport the Raw

Material 

basis: EPA/OPPT Penetration Model. 

Incineration 

High End: 6.2E+0 kg/site-day over 48 days/yr from 1 site 

or 3.0E+2 kg/site-yr from 1 site or 3.0E+2 kg/yr-all sites 

to: Incineration 

from: Cleaning Liquid Residuals from Drums Used to Transport the Raw

Material 

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

Submission indicated that all wastes are drummed and sent to off-site 

incineration as hazardous waste. In an amendment to the PMN, the 

submitter indicated that there are no aqueous wastes from this site.

RELEASE TOTAL 

3.0E+2 kg/yr - all sites 

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 3

Basis: 

EPA SANITIZED Page 10 of 14
Inhalation: 

Exposure to Vapor (volatile) (Class II)

Typical: 

> Potential Dose Rate: 2.9E-4 mg/day over 100 days/yr 

> Lifetime Average Daily Dose: 6.4E-7 mg/kg-day over 100 days/yr

> Average Daily Dose: 1.1E-6 mg/day over 100 days/yr 

> Acute Potential Dose: 4.1E-6 mg/day over 100 days/yr 

Worst Case: 

> Potential Dose Rate: 1.7E-2 mg/day over 100 days/yr 

> Lifetime Average Daily Dose: 3.8E-5 mg/kg-day over 100 days/yr

> Average Daily Dose: 6.7E-5 mg/day over 100 days/yr 

> Acute Potential Dose: 2.5E-4 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? No 

 OR 

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

=> Inhalation Monitoring Data Desired? No

Exposure to Vapor (volatile) (Class II)

Typical: 

> Potential Dose Rate: 9.4E-6 mg/day over 100 days/yr 

> Lifetime Average Daily Dose: 2.1E-8 mg/kg-day over 100 days/yr

> Average Daily Dose: 3.7E-8 mg/day over 100 days/yr 

> Acute Potential Dose: 1.3E-7 mg/day over 100 days/yr 

Worst Case: 

> Potential Dose Rate: 2.8E-4 mg/day over 100 days/yr 

> Lifetime Average Daily Dose: 6.3E-7 mg/kg-day over 100 days/yr

> Average Daily Dose: 1.1E-6 mg/day over 100 days/yr 

> Acute Potential Dose: 4.0E-6 mg/day over 100 days/yr 

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

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 

EPA SANITIZED Page 11 of 14
 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: 

> Potential Dose Rate: 2.2E+3 mg/day over 100 days/yr 

> Lifetime Average Daily Dose: 5.0E+0 mg/day over 100 days/yr

> Average Daily Dose: 8.8E+0 mg/day over 100 days/yr 

> Acute Potential Dose: 3.2E+1 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. 

Exposure to Liquid at 100.00% concentration

High End: 

> Potential Dose Rate: 2.2E+3 mg/day over 100 days/yr 

> Lifetime Average Daily Dose: 5.0E+0 mg/day over 100 days/yr

> Average Daily Dose: 8.8E+0 mg/day over 100 days/yr 

> Acute Potential Dose: 3.2E+1 mg/day over 100 days/yr 

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

Basis: Cleaning Liquid Residuals from Drums Used to Transport the Raw

Material; EPA/OPPT 2-Hand Dermal Contact with Liquids Model. 

EPA SANITIZED Page 12 of 14
CALL BY: 

CALL TO: 

Organization: Henkel 

Date: 10/23/2013 

Time: 1:30PM 

PMN: 13-0931 

Organization: ERG for CEB

Phone: 

Concerning what TSCA CBI?

CBI: Yes 

MEMORANDUM of CBI TELEPHONE CONVERSATION

Q1: What is the physical form of the neat PMN? Is it a flakey solid?

Fine powder? Resin? A1:It's a crystalline -- not a dusty solid. | | Q2: Please describe what happens to the PMN after it leaves MFG site.

How many customers do you have? A2: After mfg, it's stored on-site then 

charged into another reaction vessel where it's combined with high-MW 

polymers and polymerized. The end-product will then be sold to adhesive 

formulators, and is usually formualted sealant products. By the time 

it leaves our site, it is no longer the same PMN substance. | | Q3:

For EPA's perspective, this chemical really is an intermediate and is

site-limited -- because the original PMN substance no longer exists by

the time it's sold to an adhesive formulator. Is this correct? If so,

please revise the PMN submission to clarify the category of use. A4:

You are correct, this chemical is an intermediate. Also, I should've

indicated this chemical as being site-limited. I will re-submit the PMN.

EPA SANITIZED Page 13 of 14
CALL BY: Greg Macek 

CALL TO: 

Organization: Henkel 

Date: 01/15/2014 

Time: 2:30 pm 

PMN: 13-0931 

Organization: ERG for CEB

Phone: 

Concerning what TSCA CBI?

CBI: Yes 

MEMORANDUM of CBI TELEPHONE CONVERSATION

The submitter technical contact was asked about the potential for 

releases during transfer of solid material. In response, the technical

contact stated that the PMN chemical is a liquid as also indicated in

the MSDS.| | The submitter also stated that there are no water releases 

from this facility.| | 

EPA SANITIZED Page 14 of 14