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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.
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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.
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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.
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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.

Air
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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)
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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. | |