p110043.eng.txt

INITIAL REVIEW ENGINEERING REPORT PMN: 11-0043 Focus Ready Draft 11/15/2010

ENGINEER: Jon \ CLM PV (kg/yr): 12,000

SUBMITTER: Gelest, Inc.

USE: Reducing agent (5%) for organic substrates or chemical intermediate (95%) for 1,1,3, 3-tetramethyldisiloxane and 1,3-dibutyl-1,1,3, 3-tetramethyldisiloxane (P-11-0044).

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. Inhalation: No information available. TLV/PEL: none established

CRSS :Chemical Name: Disiloxane, 1-butyl-1,1,3,3-tetramethylS-H20: 0.00012 g/L @ VP: 1.9E+2 torr @ MW: 190.00 %<500 %<1000 Physical State and Misc CRSS Info: Neat: Liquid Mfg: Liquid Proc/Form: NA End Use: Destroyed. Submitted data: liquid; MP < 0 °C; BP = 153 °C at 760 torr; VP = 194.8 torr at 27 °C; insoluble in water; flash point = 27 °C; density = 0.782 g/cc. NOMO5 (Class 2) estimated from BP = 153 °C at 760 torr: VP = 4.5 torr. EPI estimated data (input MP = 20 °C, BP = 153 °C): BP = 137 °C; VP = 3.49 torr; WS = 0.00012 mg/L; log P = 5.69. ACDLabs estimated data (STN pprop): BP = 157 °C; VP = 3. 72 torr; WS = 0.015 g/L; log P = 5.13. The Si-H bond is susceptible to slow hydrolysis (days) to produce the corresponding silanol and hydrogen gas. Organohydrosilanes do not generally react with pure water under normal conditions. The presence of acidic or alkaline catalysts, however, brings about the reaction. The ease of hydrolysis depends on the pH and is more rapid under alkaline than acidic conditions (Kirk-Othmer).

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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: P3B1T2 PMN: P1B1T2 // Hyd Pdt: P3B1 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 -> P11-0044 (same submitter, concurrently submitted). Changes to either IRER may affect the other. The technical contact was called to clarify information provided in both submissions. This IRER presents releases to incineration and air, and dermal and inahalation exposures to liquid. The VP of this PMN is outside of the specified range for use of standard CEB models to estimate air and inhalation releases; the models were used in absence of alternatives, and additionally submission estimated releases are presented.

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: 11-0043

Manufacturing

Number of Sites/ Location: 1 Gelest Morrisville PA 19067 Days/yr: 24 Basis: Submission specifies 1 site, 24 bt/yr, 72 hr/bt, 500 kg/bt.

Process Description: Charge raw materials to reactor --> PMN formed --> Separation of layers, aqueous layer disposed --> Crude product distillation --> Purified Page 2p110043.eng.txt product packaging (liquid, 100% PMN). (Submission)

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.

Air Output 2: 1.1E+2 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. The vapor pressure of the PMN is greater than the design range for use of the EPA/OPPT Mass Transfer Coefficient model. However, in absence of a default model to estimate potential air emissions during equipment cleaning, CEB presents the results according to the Mass Transfer Coeff model. Note, the submission estimates 0.4 kg/day total fugitive air release; this CEB model output is significantly greater than the emissions expected to occur, per submission.

Air Typical: 5.0E-1 kg/site-day over 24 days/yr from 1 site Worst Case: 10.0E-1 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. The vapor pressure of the PMN is greater than the design range for use of the AP-42 loading model. However, in absence of a default model to estimate potential air emissions during unloading, CEB presents the results according to the AP-42 model. Note, the submission estimates 0.4 kg/day total fugitive air release, which is relatively consistent with this CEB model output.

Incineration Conservative: 1.0E+1 kg/site-day over 24 days/yr from 1 site or 2.4E+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 2.8E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 4 Basis: Submission estimates up to 4 workers/site present Page 3p110043.eng.txt duing mfg. CEB conservatively assumes that all 4 workers are exposed during both equipment cleaning and product loading. Both of the release models were applied to the PMN in absence of another default model, although the PMN's vapor pressure is outside of the stated design range for these release models.

Inhalation:

Exposure to Vapor (Class II) Typical: 6.4E+2 mg/day over 24 days/yr Worst Case: 5.7E+3 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: 2.4E+2 mg/day over 24 days/yr Worst Case: 1.4E+4 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: 11-0043

Use: Chemical intermediate/ reducing agent

Number of Sites/ Location: 1 Gelest Morrisville PA 19067 Days/yr: 24 Basis: Submission specifies 2 potential sites (5% of PV may be used off-site) however technical contact states Page 4p110043.eng.txt that Gelest will likely do all processing at same site as mfg, and CEB assumes 1 use site; 24 bt/yr, 72 hr/bt, 500 kg/bt.

Process Description: PMN (liquid, 100%) combined with organic substrate or acid catalyst --> Reacted to form product chemicals, P11-0044 and tetramethyldisiloxane. (Submission)

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.

Air Typical: 5.0E-1 kg/site-day over 24 days/yr from 1 site Worst Case: 10.0E-1 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. The vapor pressure of the PMN is greater than the design range for use of the AP-42 loading model. However, in absence of a default model to estimate potential air emissions during unloading, CEB presents the results according to the AP-42 model. Note, the submission estimates 1.4 kg/day total fugitive air release, which is relatively consistent with the total of CEB model output.

Air Output 2: 1.7E-2 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. The vapor pressure of the PMN is greater than the design range for use of the EPA/OPPT Penetration model. However, in absence of a default model to estimate potential air emissions during equipment cleaning, CEB presents the results according to the Penetration model. Note, the submission estimates 1.4 kg/day total fugitive air release, which is relatively consistent with the total from CEB model outputs.

Incineration High End: 1.5E+1 kg/site-day over 24 days/yr from 1 site or 3.6E+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 3.8E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Page 5p110043.eng.txt Tot. # of workers exposed via assessed routes: 7 Basis: Submission estimates up to 7 workers/site present duing use. CEB conservatively assumes that all 7 workers are exposed during both raw material unloading and container cleaning. Note, inhalation exposure estimated according to the Mass Balance Model with the AP-42 Loading Model release is orders of magnitude higher than that estimated according to the Mass Balance Model with the Penetration Model release. Both of the release models were applied to the PMN in absence of another default model, although the PMN's vapor pressure is outside of the stated design range for these release models.

Inhalation:

Exposure to Vapor (Class II) Typical: 2.4E+2 mg/day over 24 days/yr Worst Case: 1.4E+4 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: 8.0E+0 mg/day over 24 days/yr Worst Case: 2.4E+2 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? 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: 7 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.



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MEMORANDUM of TELEPHONE CONVERSATION

CALL BY: Casey MacQueen Organization: ERG for CEB

CALL TO: Gerry Larson

Organization: Gelest

Date: 11/08/2010

Time: 3pm

Phone: 215-547-1015

Concerning what TSCA ?

PMN: 11-0043

This contact report applies to both P11-0043 and P11-0044

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