s110004.eng

INITIAL REVIEW ENGINEERING REPORT SNUN:11-0004 Focus Ready Draft 11/8/2010

ENGINEER: Macek \ BCS PV (kg/yr): 120,000 Import Only NX

SUBMITTER: Kuraray America Inc

USE: Solvent for inkjet printer ink. S-05-3 from the same submitter is used as a solvent for screen inks, plastic coatings, paint thinners, polyurethane resins, and in cleaning agents. from the same submitter is a solvent for paints. There are 73 STN CA references for the use of substance as a solvent. Analogs are solvents for various uses.

OTHER USES: : wetting agent for printing press solutions; STN CA 151:339883: cleaning agent for water-based detergents.

MSDS: Yes Label: No

Gen Eqpt: Eng Controls: Use in a totally enclosed system, or with local exhaust ventilation. // Eye/Face: Use chemical goggles. If vapor exposure causes eye discomfort, use a full-face respirator. // Skin: Use protective clothing impervious to this material. (silvershield gloves are impervious to this material.) Selection of specific items such as face shield, gloves, boots, apron, or full-body suit will depend on operation. Respirator: When respiratory protection is required, use an approved air-purifying or positive -pressure supplied-air respirator depending on the potential airborne concentration. Health Effects: Eye: :May cause moderate eye irritation. // Skin: :Prolonged or repeated exposure may cause slight skin irritation. May be harmful if absorbed. // Ingestion: May cause developmental effects. // Inhalation: May cause organ effects. TLV/PEL: none established

CRSS : Chemical Name: 1-Butanol, 3-methoxy-3-methyl-, 1-acetate S-H20: g/L @ VP: 1.9E+0 torr @ MW: 160.00 %<500 %<1000 Physical State and Misc CRSS Info: Neat: Liquid Mfg: NK: Imported Proc/Form: Dispersion: 95% SNUN substance in ink formulation End Use: Gas: SNUN substance evaporated from dried ink. Submitted Data: Liquid; MP < -100°C (DSC); BP = 187.3°C at 760 torr (OECD 103); VP = 1.935 torr (OECD 104); WS = 58.3 g/L (OECD 105); log P = 1.6 (OECD 117); density = 0.957 g/cm3 (Exp. ); flash point = 76°C (Exp.); not explosive; log Koc = 1. 2; surface tension = 65.5 nM/m; solubility in DMSO, acetone, ethanol, THF or n-hexane is greater than 500 g/L; hydrolysis half-life at pH 7 = 15200 hr (extrapolated from higher temp.); hydrolysis half-life at pH 9 = 157 hr Page 1s110004.eng (extrapolated from higher temp.); at pH 4 and 50°C over 5 days, less than 10% of the substance hydrolyzed. The submitted 1H NMR, UV/Vis and MS spectra are consistent with the structure of the SNUN substance.

Consumer Use: No

SAT (concerns) (11/02/2010):

Migration to groundwater: Negligible PBT rating: P1B1T2 . Health: 1-2 Dermal, Inhalation Eco: 2 Water (All releases to water with a CC = 450 ppb)

OCCUPATIONAL EXPOSURE RATING: 2-3D

NOTES & KEY ASSUMPTIONS: Generated by the 10/25/2004 version of ChemSTEER.

POLLUTION PREVENTION CONSIDERATIONS:
None.

EXPOSURE-BASED REVIEW: No

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INITIAL REVIEW ENGINEERING REPORT SNUN:11-0004

PROC: Formulation of Inkjet Printer Ink

Number of Sites/ Location: 1 Prism Inks, Inc. Sunnyvale CA 94085 Days/yr: 117

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. The 2001 GS for the Manufacture and Use of Printing Inks was used to supplement releases estimates. Note SAT concerns for dermal, inhalation, and all releases to water with CoC = 450 ppb. incineration releases << 28,000 kg/site-day; air releases > 0.54 kg/site-day; migration to groundwater = negl.; water releases are not expected based on GS.

Air Typical: 8.6E-3 kg/site-day over 117 days/yr from 1 site Worst Case: 1.7E-2 kg/site-day over 117 days/yr from 1 site

Air Output 2: 3.0E-4 kg/site-day over 117 days/yr from 1 site

Air Output 2: 9.3E-1 kg/site-day over 117 days/yr from 1 site

Air Typical: 4.2E-4 kg/site-day over 117 days/yr from 1 site Worst Case: 3.3E-3 kg/site-day over 117 days/yr from 1 site

Page 3s110004.eng Air Typical: 9.0E-3 kg/site-day over 117 days/yr from 1 site Worst Case: 1.8E-2 kg/site-day over 117 days/yr from 1 site

Incineration Output 2: 1.0E+0 kg/site-day over 117 days/yr from 1 site or 1.2E+2 kg/yr

Incineration or Landfill High End: 3.1E+1 kg/site-day over 117 days/yr from 1 site or 3.6E+3 kg/yr

Incineration or Landfill Conservative: 2.1E+1 kg/site-day over 1 day/yr from 1 site or 2.1E+1 kg/yr

RELEASE TOTAL 3.9E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 4 Basis: The submission states that 4 workers/site are exposed to PMN during various activities. CEB assesses all workers to 100% and 95% liquid PMN as conservative.

Inhalation:

Exposure to Vapor (Class II) Typical: 4.1E+0 mg/day over 117 days/yr Worst Case: 2.5E+2 mg/day over 117 days/yr Number of workers (all sites) with inhalation exposure: 4

NOTE: The respirator class is: II. Gas/vapor (all substances in the gas form). Page 4s110004.eng

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: 2.0E-1 mg/day over 117 days/yr Worst Case: 4.8E+1 mg/day over 117 days/yr Number of workers (all sites) with inhalation exposure: 4 Basis: Sampling Liquid Product; 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: 4.3E+0 mg/day over 117 days/yr Worst Case: 2.6E+2 mg/day over 117 days/yr Number of workers (all sites) with inhalation exposure: 4 Basis: Loading Liquid Product into Bottles; 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 117 days/yr Number of workers (all sites) with dermal exposure: 4 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

Exposure to Liquid at 95.00% concentration High End: 8.4E+2 mg/day over 117 days/yr Number of workers (all sites) with dermal exposure: 4 Basis: Sampling Liquid Product; EPA/OPPT 1-Hand Dermal Contact with Liquids Model.

Exposure to Liquid at 95.00% concentration High End: 1.7E+3 mg/day over 117 days/yr Number of workers (all sites) with dermal exposure: 4 Page 5s110004.eng Basis: Loading Liquid Product into Bottles; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT CBI: Yes SNUN:11-0004

USE: Commerical Inkjet Printing

Number of Sites/ Location: 4,858 unknown sites Days/yr: 250 Basis: The submission does not provide any information for the commerical use sites. PMN is used as 95% liquid. The GS for Toner Used in Photocopiers calculates the number of sites as (PV) x (% conc of PMN) x (1 cartridge/ 1 kg ink) x (copier-yr/26 cartridges) x (1 site/1 copier) = 120,000/0.95/26 = 4858 sites. CEB assumes 250 days of printing operation per year. ChemSTEER calculates a use rate of 0.099 kg/site-day.

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. The Photocopier toner GS was used to estimate releases. The GS estimates that all PMN will be releases to incineration or landfill. Note SAT concerns for dermal, inhalation, and all releases to water with CoC = 450 ppb. Incineration releases < 28,000 kg/site-day; air releases < 0.54 kg/site-day; migration to groundwater = negl.; water releases are not expected per GS.

Air Typical: 3.3E-3 kg/site-day over 250 days/yr from 4,858 sites Worst Case: 2.7E-2 kg/site-day over 250 days/yr from 4,858 sites

Incineration or Landfill Output 2: 7.2E-2 kg/site-day over 250 days/yr from 4,858 sites or 8.7E+4 kg/yr

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RELEASE TOTAL 1.2E+5 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 4,858 Basis: The submission does not estimate the number of workers. The GS assumes 1 worker/site.

Inhalation:

Exposure to Vapor (Class II) Typical: 1.6E+0 mg/day over 250 days/yr Worst Case: 3.8E+2 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 4, Basis: Offgas of solvents into printing production area; EPA/OPPT Mass Balance Model. Conservatively assumed an 8-hr exposure duration. See additional details on modeling apporoach used in release section of this report (for this activity) 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 95.00% concentration High End: 8.4E+2 mg/day over 26 days/yr Number of workers (all sites) with dermal exposure: 4,858 Basis: Unloading Liquid Raw Material from Bottles; EPA/OPPT 1-Hand Dermal Contact with Liquids Model. Incidental dermal exposure possible. Low potential in changeout due to container design and procedures. Possible dermal contact if printed pages could occur before ink dried. Used 1-hand dermal contact model for fewer days/yr.

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