Clariant Corp. - Mt. Holly, NC - USA


### Document Control Office (DCO) Office of Pollution Prevention and Toxics (OPPT) US Environmental Protection Agency EPA East, Room 6428 1201 Constitution Avenue, NW Washington, DC. 20004 Telephone: 202-564-8930 or 8940

Attn: EPA-HQ-OPPT-2008-0319 Mary Dominiak

Mt. Holly, NC, 09/08/2008 EPA-HQ-OPPT-2008-0319 Monoglyme Use and Expos ure information for the CHAMP Initial Risk-based Prioritization Ms. Terry L. Wells Product Safety Phone: 704 822-2245 Fax: 704 330-1551 terry.wells@clariant.com Functional Chemicals Clariant Corp. 625 East Catawba Ave. 28120 Mt. Holly, NC USA

Page 1 of 1 Company Sanitized, Does Not Contain CBI

Clariant Monoglyme Activities

Clariant manufactures Monoglyme in Europe and imports < 250,000 kg/yr in bulk containers or drums. The product is sold as imported without further pr ocessing at Clariant facilities. Clariant sells monoglyme to <10 customers per year. Use and exposure information was requested from all customers for the last 3 years. Clariant received responses from customers which account for approx. 95% of the Monoglyme volume. The remaining cust omers purchased <10,000 kg/customer over the 2 last years. Some are no longer using monoglym e, and some are small solvent distributors.

Downstream Use of Monoglyme

Monoglyme is used as a solvent or processing aid in the manufacture or formulation of industrial chemicals. The large majority of the monoglyme sold by Clariant is used as a site limited processing aid for industrial chemical manufacture. The remaining volume is used in quantities of <10 - 1000 kg/site over 100-1000 additional sites.

Use 1 Solvent for industrial chemical manufacturing Site limited, < 5 sites <200,000 kg/year No offsite distribution General Information: Monoglyme is used to manufacture industrial chemicals.Page 2 of 2 Occupational Exposure Estimate/site

Worker activity Protective Equipment No. of workers exposed Max hr/day Days/yr

Unloading trucks/drums Air-purifying respirator, goggles, gloves, apron 2-5 4 12-60

Sampling Air-purifying respirator, goggles, gloves, apron 2-5 2 365

Maintenance activities Air-purifying respirator, goggles, gloves, apron 10-20 10 12-36

Unloading trucks/drums Air-purifying respirator, goggles, gloves, apron 2-5 4 12-60

Environmental Release and Disposal Estimate

Description of Release Media of Release Control Technology and efficiency kg/day Days/yr

Cleaning process equipment surface water off-site waste water treatment 1-10 12-36

Waste water surface water Aeration ponds 0.5-5 365

Flare Stack air Flare, 98% 1-10 365

Fugitives fugitive air none 5-25 365

Process scrubbers Stack air scrubber 90% 1-50 365

Use 2 Processing Aid for Fluoropolymer Etchant formulation Site limited, <10 sites <1000kg/year/site >50% of Etchant is used on-site; <50% Offsite Distribution for use as an Etchant solution for fluropolymer adhesion Formulation of Fluoropolymer Etchant in a laboratory environment: <10 sites formulate Fluoropolymer Etchant products to make fluoropolymers bondable to a wide variety of articles. i.e., Teflon. The monoglyme is removed from the drums using general industrial ventilation, workers wear typical laboratory safety equipment, including respirators and gloves. The majority of the handling is done in a laboratory chemical hood. Formulated fluoropolymer solution contains approx. 80-90% monoglyme. Product is bottled into 1 pint-1 gallon containers for use in etchant application.Page 3 of 3 Occupation Exposure Estimate/site

Worker activity Protective Equipment Form/Conc. Monoglyme No. of workers exposed Max hr/day Days/yr

Drum unloading Exhaust fan, normal work clothes or Respirator, Gloves, goggles, Liquid 100% 2-5 0.5 24

Drumming 1 gallon containers Lab hood, typical lab safety

wear Liquid 90% 2-5 24

Emptying bottles into Etchant process (closed) Lab hood, typical lab safety

wear Liquid 90% 20-50 8 220

Recovering used Etchant soln in original 1 gallon bottles Lab hood, typical lab safety

wear Liquid 80-90% 20-50 220

Description of Release Media of Release Control Technology and efficiency kg/day Days/yr

Solvent is re-used until spent, spent solvent is collected for disposal Air Off- or On-site incineration

If you have any questions, or need further information, please let me know.

Sincerely,

Terry L. Wells Product Safety Manager Functional ChemicalsClariant Corp. - Mt. Holly, NC - USA


### Document Control Office (DCO) Office of Pollution Prevention and Toxics (OPPT) US Environmental Protection Agency EPA East, Room 6428 1201 Constitution Avenue, NW Washington, DC. 20004 Telephone: 202-564-8930 or 8940

Attn: EPA-HQ-OPPT-2008-0319 Mary Dominiak

Mt. Holly, NC, 09/08/2008 EPA-HQ-OPPT-2008-0319 Diglyme Use and Exposure information for the CHAMP Initial Risk-based Prioritization Ms. Terry L. Wells Product Safety Phone: 704 822-2245 Fax: 704 330-1551 terry.wells@clariant.com Functional Chemicals Clariant Corp. 625 East Catawba Ave. 28120 Mt. Holly, NC USA

Page 1 of 1 COMPANY SANITIZED – DOES NOT CONTAIN CBI

Clariant Diglyme Activities

Clariant manufactures Diglyme in Europe and impo rts <250,000 kg/yr in bulk containers or drums. The product is sold as imported with out further processing at Clariant fa cilities. Clariant sells Diglyme to <20 customers per year. Use and exposure info rmation was requested from all customers for the last 3 years. Clariant receiv ed responses from customers which account for approx. 95% of the Diglyme volume. The remaining customers purchas ed <10,000 kg/customer over the 2 last years. Some are no longer using Diglyme, and some are small solvent distributors.

Downstream Use of Diglyme

Diglyme is used as a solvent or processing aid in the manufacture or formulation of industrial chemicals. Much of the Diglyme sold by Clariant is used as a site limited processing aid at <10 industrial sites. The remaining amount is used in quantities of <10 - 1000 kg/site over 100-1000 additional sites.

Use 1 Manufacturing Solvent for Industrial Chemical Site limited, <5 sites <250,000 kg/year No offsite distribution General Information: Diglyme is used in a continuo us process. Diglyme is used as a solvent, approx. 1 worker/shift samples this material 4 times per shi ft. The finished industrial products do not contain residual Diglyme. Most of the solvent is recy cled and reused. However, losses of about 50-250,000 Kg/yr must be replaced with fresh solvent. Diglyme losses are roughly estimated at 40-50% vapor sent to a flare, 40-50% decomposition products (i.e., MeOH and 2-MethoxyEthanol) and the remaining 2- 5% Diglyme is sent to a biologica l wastewater treatment system.Page 2 of 2 Occupational Exposure Estimate/site

Worker activity Protective Equipment Form/Conc. Diglyme No. of workers exposed Max hr/day Days/yr

Unloading Enclosed process, face shield, nitrile gloves, splash suit, Liquid 100% 2 0.2h/day 6

Sampling face shield, nitrile gloves, splash suit Liquid 25% 2 <0.1hr/day 330

Maintenance chemical hood, goggles nitrile gloves, Liquid 25% 2-4

Analysis face shield, nitrile gloves, splash suit Liquid 25% 4 <0.1 hr/day 330

Environmental Release and Disposal Estimate/site

Description of Release Media of Release Control Technology and efficiency kg/day Days/yr

Vessel Cleaning Recycle Recycle wash water back to process 0 2-4

Water Release from recovery process POTW TOC analysis, permitted 24 330

Vapor Recovery Flare 290 330

Breakdown to MeOH and 2- Methoxyethanol

Use 2 Processing Aid for Fluoropolymer Etchant formulation Site limited, <10 sites (small-medium) <100,000 kg/year >50% of Etchant is used on-site; <50% Offsite Distribution for use as an Etchant solution for fluropolymer adhesion (see use 3) Formulation of Fluoropolymer Etchant: basic proces s description: <10 sites formulate Fluoropolymer Etchant products to make fluoropolymers bondable to a wide variety of articles. i.e., Teflon. The Diglyme is removed from the drums using general industrial ventilation, workers wear normal work clothing. The blending vessel is nitrogen blanke ted, closed process. Formulated fluoropolymer solution contains approx. 80-90% Diglyme. Product is bottled into 1 pint-1 gallon containers for use in etchant application. Fugitive emissions from the process are very small, and are permitted fugitive emissions.Page 3 of 3 Occupational Exposure Estimate/site

Worker activity Protective Equipment Form/Conc. Diglyme No. of workers exposed Max hr/day Days/yr

Drum unloading Enclosed with Ind, ventilation, normal work clothes or Respirator, Gloves, goggles, Exhaust fan Liquid 100% 3 0.5 100

Drumming 1 gallon containers Ind, ventilation, normal work clothes Liquid 90% 3

Emptying bottles into Etchant process (closed) Ind, ventilation, normal work clothes Liquid 90% 20 16 220

Recovering used Etchant soln in original 1 gallon bottles Ind, ventilation, normal work clothes Liquid 80-90% 20 17 220

Environmental Release and Disposal Estimate/site

Description of Release Media of Release Control Technology and efficiency kg/day Days/yr

Fugitive emissions from drum unloading and gallon container filling Air permitted emissions <1.0 100

Cleaning formulation vessel <12

Distillation process release

Use 3 Fluoropolymer Etchant application 100-1000 Sites <10 gallons/year – 1000 gallons/yr

Use of fluoropolymer etchant Diglyme is used as a processing aid/solvent at 80-90% in a fluoropolymer application. At this time, all of the sites which formulate the fluropolymer solution also apply the Etchant solution to finished articles. The etching process is a closed process. All of the Diglyme is recovered from this process as used solu tion, which is re-used, and finally distilled. The Diglyme is recovered and re-used again in this process. The formulation sites may also sell the fluoropolymer etchant solution with 80 - 90% Diglym e to 100 - >1000 customers in 1 pint to 1 gallon containers for use in their own et chant applications. Customer volumes range from <1gallon per order, to several skids of gallon containers per month for "typical" customers. At least one largePage 4 of 4 etchant solution manufacturer has a very successful recycling program to collect spent fluoropolymer solution for recovery of the Diglyme and re-use in the etchant formulations. The finished products are all articles, i.e., circuit boards, auto components; Diglyme content on finished article would be in ppb range.

Use 4 Chemical Intermediate Manufacture <10 Sites, Site Limited 10,000-50,000 kg/year Occupational Exposure Estimate/site

Worker activity Protective Equipment No. of workers exposed Max hr/day Days/yr

Unloading, sampling, charging Chemical resistant gloves, eye protection, respiratory protection when exposed to vapor 4 3 200

Environmental Release and Disposal Estimate/site

Description of Release Control Technology and efficiency kg/day Days/yr

Cleaning process equipment, drums point source air, fugitive air, on-site WWT Thermal oxidizer for air emissions, 98% destruction efficiency no data 200 days per year

If you have any questions, or need further information, please let me know.

Sincerely,

Terry L. Wells Product Safety Manager Functional Chemicals