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

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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

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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

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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

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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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