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 1

EPA SANITIZED Page 1 of 7
s110004.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

Page 2

EPA SANITIZED Page 2 of 7
s110004.eng

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 3

EPA SANITIZED Page 3 of 7
s110004.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 4

EPA SANITIZED Page 4 of 7
s110004.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 5

EPA SANITIZED Page 5 of 7
s110004.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

Page 6

EPA SANITIZED Page 6 of 7
s110004.eng

 

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.

Page 7

EPA SANITIZED Page 7 of 7