file:///J|/INITENG/P13%20cases/p130468.eng.txt[7/2/2013 7:26:34 AM] INITIAL REVIEW ENGINEERING REPORT PMN: 13-0468 Focus Ready Draft 6/17/2013

ENGINEER: Arnold \ REC PV (kg/yr): 2,000

SUBMITTER: Henkel Corporation

USE: Site limited chemical intermediate to make a curable monomer. Concurrently submitted with P-13-0472. File 147: 167459 CA: use as a monomer in emulsion polymerization reaction. Files 143:267271 CA, 141:54709 CA, 137:47953 CA, and 131:229152 CA: use as a monomer in photoinitiated cationic polymerization.

OTHER USES: File 142:57229 CA: use as a cross-linking agent. Analog P-02-0253 is a chemical intermediate for resin synthesis for automotive top coatings.

MSDS: Yes Label: No

Gen Eqpt: Use adequate ventilation. // Chemical resistant, impermeable gloves. // Safety glasses, goggles. Respirator: Use NIOSH approved respirator if ventilation is inadequate. Health Effects: Inhalation: May be harmful if inhaled. May cause respiratory tract irritation. Central nervous system effects. // Skin: May cause skin irritation with discomfort or rash. May cause allergic skin reaction. // Eyes: Severe eye irritation. // Ingestion: Gastric disturbances. May be harmful if swallowed. TLV/PEL: None established.

CRSS (06/06/2013): Chemical Name: Oxirane, 2-[(1-propen-1-yloxy)methyl]- S-H20: 108 g/L @ VP: 8.7E+0 torr @ MW: 114.00 %<500 %<1000 Physical State and Misc CRSS Info: Neat: Liquid Mfg: Liquid Proc/Form: NA End Use: Destroyed. Submitted data: The submitted MSDS is for 60-100% PMN material and contained the following properties: liquid; flash point = 57 °C (est.); specific gravity = 0.96. EPI estimated data (input MP = 20 °C): BP = 137.9 °C; VP = 8. 72 torr; WS = 108 g/L; log P = 0.37. ACD Labs estimated data (STN pprop): BP = 143 °C; VP = 6.82 torr; WS = 18 g/L; log P = 0.708.file:///J|/INITENG/P13%20cases/p130468.eng.txt[7/2/2013 7:26:34 AM] Consumer Use: No

SAT (concerns) (06/07/2013): Related Cases and Related Cases and Misc SAT Info: Ecotox: Analogs: Migration to groundwater: Rapid PBT rating: P1B1T1 . Health: 2 Dermal, Inhalation Eco: 2 Water (All releases to water with a CC = 37.00 ppb)

OCCUPATIONAL EXPOSURE RATING: 2-3B

NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER. The PMN is a site-limited chemical intermediate and is detroyed during use. This PMN is submitted concurrently with . Releases to incineration, landfill, and air (volatilization) are expected. Additionally, this IRER provides both dermal and inhalation exposure assessments for MFG and USE. The submitter was contacted for additional information, see contact report. // The following same submitter, similar use past cases were referenced for consistency: (chemical intermediate); (site limited chemical intermediate for polymer synthesis); and (Prepolymer/chemical intermediate). // All past cases assessed inhalation and dermal exposures (consistent with the current IRER). assessed dust releases and inhalation exposure to particulates for a solid PMN; releases were assessed to incineration, landfill, and uncertain media. and assessed releases to air (volatilization) and incineration (per submission). All past cases are generally consistent with the current IRER.

POLLUTION PREVENTION CONSIDERATIONS: No Pollution Prevention information provided by the submitter.

EXPOSURE-BASED REVIEW: No

INITIAL REVIEW ENGINEERING REPORT PMN: 13-0468

Manufacturing: Batch

Number of Sites/ Location: 2 Henkel Rocky Hill CT 06067 Henkel Salisbury Salisbury NC 28147 Days/yr: 2 Basis: Submitter specifies 2 sites, 500 kg/bt, 24 hrs/bt, 4 bt/yr, and 100% PMN in manufactured product. CEB assumes 2 bt/site-yr.file:///J|/INITENG/P13%20cases/p130468.eng.txt [7/2/2013 7:26:34 AM] Process Description: Reagent Charging --> Rotovap Flask (triple pass condensers, thermocouple, oil bath, nitrogen purge, and vacuum) --> Reaction --> Purification (liquid, 100%) --> Storage (per 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. Submission does not estimate fugitive air emissions. Although incineration releases are presented in this IRER, note that incineration is <28,000 kg/st-day.

Air Output 2: 8.1E-1 kg/site-day over 2 days/yr from 2 sites to: Air (model) from: Equipment Cleaning Losses of Liquids from a Single, Large Vessel basis: EPA/OPPT Mass Transfer Coefficient Model.

Air Typical: 1.3E-2 kg/site-day over 2 days/yr from 2 sites Worst Case: 2.7E-2 kg/site-day over 2 days/yr from 2 sites to: Air (model) from: Loading Liquid Product into Drums basis: EPA/OAQPS AP-42 Loading Model.

Incineration Conservative: 5.0E+0 kg/site-day over 2 days/yr from 2 sites or 2.0E+1 kg/yr to: Off-site Incineration (per submission) from: Equipment Cleaning Losses of Liquids from a Single, Large Vessel basis: EPA/OPPT Single Vessel Residual Model, CEB standard 1% residual. Submission estimates 0.5 kg of liquid process waste per batch from distillation is disposed of via off-site via incineration. Per technical contact, reactor rinsate is drummed and disposed of via off-site incineration. CEB assesses equipment cleaning releases using the standard CEB loss fraction for a single, large vessel.

RELEASE TOTAL 2.3E+1 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 8 Basis: Submitter estimates exposure for up to 8 workers for all sites; CEB assumes that all workers conduct all activities.file:///J|/INITENG/P13%20cases/p130468.eng.txt[7/2/2013 7:26:34 AM] Inhalation:

Exposure to Vapor (Class II) Typical: 6.4E+0 mg/day over 2 days/yr Worst Case: 3.8E+2 mg/day over 2 days/yr Number of workers (all sites) with inhalation exposure: 8 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? 2 Yes Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal:

Exposure to Liquid at 100.00% concentration High End: 1.8E+3 mg/day over 2 days/yr Number of workers (all sites) with dermal exposure: 8 Basis: Loading Liquid Product into Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT PMN: 13-0468

Use: Site Limited Chemical Intermediate

Number of Sites/ Location: 2 Henkel Rocky Hill CT 06067 Henkel Salisbury Salisbury NC 28147 Days/yr: 250 Basis: PMN is a site-limited chemical intermediate. CEB assumes 250 day/yr operations; CS calculates a throughpur of 4 kg/st-day.

Process Description: PMN charged to reactor (liquid, 100%) --> reaction, PMN destroyed

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. Submission does not estimate fugitive air emissions. Although incineration releases are presented in this IRER, note that incineration is <28,000 kg/st-day.

Airfile:///J|/INITENG/P13%20cases/p130468.eng.txt [7/2/2013 7:26:34 AM] Typical: 1.1E-4 kg/site-day over 250 days/yr from 2 sites Worst Case: 2.1E-4 kg/site-day over 250 days/yr from 2 sites to: Air (model) from: Unloading Liquid Raw Material from Drums basis: EPA/OAQPS AP-42 Loading Model.

Air Output 2: 4.0E-6 kg/site-day over 250 days/yr from 2 sites to: Air (model) from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Penetration Model.

Incineration or Landfill High End: 6.2E+0 kg/site-day over 5 days/yr from 2 sites or 6.2E+1 kg/yr to: Incineration or Landfill (per technical contact) from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. Per technical contact, drums are used for intermediate storage; the drums are sent off to a third party as hazardous waste once empty and will be disposed of via incineration or landfill.

RELEASE TOTAL 6.3E+1 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 6 Basis: CEB assumes exposure for up to 3 workers/site and that all workers conduct all activities.

Inhalation:

Exposure to Vapor (Class II) Typical: 5.1E-2 mg/day over 250 days/yr Worst Case: 3.1E+0 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 6 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? 2 Yes Inhalation Monitoring Data Desired? Yes (both criteria met)file:///J|/INITENG/P13%20cases/p130468.eng.txt[7/2/2013 7:26:34 AM] Dermal:

Exposure to Liquid at 100.00% concentration High End: 1.8E+3 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 6 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

MEMORANDUM of CBI TELEPHONE CONVERSATION

CALL BY: Rachel Corbett Organization: ERG

CALL TO: Sean Burdzy

Organization: Henkel

Date: 06/10/2013

Time: 10:20 am

Concerning what TSCA CBI?

PMN: 13-0468

Q1: What happens to the PMN after manufacture?| A1: Use intermediate storage, drums.| | Q2: What happens to the storage containers? Are they ever cleaning, if so, where does the residue go?| A2: Storage containers become waste, and all of the waste is handled by a third party; most likely incineration or landfill. | | Q3: What about reactor cleaning? | A3: Occurs after ever batch. Solvent, followed by acetone, drummed and sent to waste facilty for incineration. | |