file:///J|/SNURS/SNUR%20Batch%20FY10-3/sanitized%20report/sanitized%20engineering%20reports/p090019.sanitized.eng.txt [5/11/2010 1:13:28 PM] INITIAL REVIEW ENGINEERING REPORT PMN: 09-0019 Focus Ready Draft 10/30/2008 ENGINEER: Macek \ AG PV (kg/yr):

SUBMITTER: USE: Monomer for epoxy resin for filament winding ( ) and for electrical encapsulation - motors, generators ( ). OTHER USES: MSDS: Yes Label: No Gen Eqpt: impermeable gloves / splash-proof chemical goggles / general mechanical and local exhaust in accordance with ACGIH recommendations Respirator: NIOSH-approved organic vapor cartridge respirator when vapor/mist exposure is likely Health Effects: causes skin and eye irritation / possible sensitization in susceptible individuals TLV/PEL: None Established

CRSS : Chemical Name: 4-Cyclohexene-1,2-dicarboxylic acid, 1, 2-bis(2-oxiranylmethyl) ester S-H20: 1.23 g/L @ VP: 1.8E-5 torr @ MW: 282.00 %<500 %<1000 Physical State and Misc CRSS Info:

Consumer Use: No SAT (concerns) (10/24/2008): Migration to groundwater: Negligible PBT rating: P1B1T2 Health: 2 Dermal, Inhalation Eco: 2 Water (All releases to water with a CC = 42 ppb) OCCUPATIONAL EXPOSURE RATING: 1B NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER. POLLUTION PREVENTION CONSIDERATIONS: None.file:///J|/SNURS/SNUR%20Batch%20FY10-3/sanitized%20report/sanitized%20engineering%20reports/p090019.sanitized.eng.txt [5/11/2010 1:13:28 PM] EXPOSURE-BASED REVIEW: No INITIAL REVIEW ENGINEERING REPORT PMN: 09-0019 Processing: Formulating Epoxy System Number of Sites/ Location: 3 Unknown Sites Days/yr: 60 Basis: Process Description: Import PMN ( ) --> Mixer --> Product Loading ( ) (per submission and CRSS) 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. Water or Incineration or Landfill High End: 6.2E+0 kg/site-day over 38 days/yr from 3 sites or 7.1E+2 kg/yr to: Uncertain from: basis: Water or Incineration or Landfill Conservative: 1.3E+0 kg/site-day over 60 days/yr from 3 sites or 2.4E+2 kg/yr to: Uncertain from: basis: Air Output 2: 2.0E-1 kg/site-day over 60 days/yr from 3 sites to: Air / Point Sourc e Scrubber from: basis: RELEASE TOTAL 9.9E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 9 Basis: Submission estimates 1 worker. CEB estimates 3 workers/site. Inhalation: negligible (VP < 0.001 torr)file:///J|/SNURS/SNUR%20Batch%20FY10-3/sanitized%20report/sanitized%20engineering%20reports/p090019.sanitized.eng.txt [5/11/2010 1:13:28 PM] Dermal: Exposure to Liquid at % concentration High End: 1.8E+3 mg/day over 60 days/yr Number of workers (all sites) with dermal exposure: 9 Basis: Exposure to Liquid at % concentration High End: 1.2E+3 mg/day over 60 days/yr Number of workers (all sites) with dermal exposure: 9 Basis: INITIAL REVIEW ENGINEERING REPORT PMN: 09-0019 Use 1: Filament Wound Objects Number of Sites/ Location: 3 Unknown Sites Days/yr: 60 Basis: Submission indicates % of PV is for epoxy resin for filament winding. It appears use sites are the same as formulating sites, although submission is not entirely clear. Process Description: Epoxy System ( ) --> Resin Bath --> Filament Winding Part --> Forced Draft Oven --> Stand-alone Part (PMN destroyed) (per submission and CRSS) 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. Water or Incineration or Landfill High End: 3.0E+0 kg/site-day over 60 days/yr from 3 sites or 5.4E+2 kg/yr to: Uncertain from: basis: Water or Incineration or Landfill Conservative: 1.0E+0 kg/site-day over 60 days/yr from 3 sites or 1.8E+2 kg/yr to: Uncertain from: basis: RELEASE TOTALfile:///J|/SNURS/SNUR%20Batch%20FY10-3/sanitized%20report/sanitized%20engineering%20reports/p090019.sanitized.eng.txt [5/11/2010 1:13:28 PM] 7.2E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 9 Basis: CEB assesses 3 workers/site. Inhalation: negligible (VP < 0.001 torr)

Dermal: Exposure to Liquid at 70.00% concentration High End: 1.2E+3 mg/day over 60 days/yr Number of workers (all sites) with dermal exposure: 9 Basis: INITIAL REVIEW ENGINEERING REPORT PMN: 09-001 9 Use 2: Electrical Insulating/Encapsulation Number of Sites/ Location: 3 Unknown Sites Days/yr: 60 Basis: Submission indicates % of PV is for epoxy resin for electrical encapsulation. It appears use sites are the same as formulating sites, although submission is not entirely clear. Process Description: Epoxy System ( % PMN, liquid) --> Encapsulation --> Oven --> Stand-alone Part (PMN destroyed) (per submission and CRSS) 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. Water or Incineration or Landfill High End: 10.0E-1 kg/site-day over 60 days/yr from 3 sites or 1.8E+2 kg/yr to: Uncertain from: basis: Water or Incineration or Landfill Conservative: 3.3E-1 kg/site-day over 60 days/yr from 3 sites or 6.0E+1 kg/yr to: Uncertain from: basis:file:///J|/SNURS/SNUR%20Batch%20FY10-3/sanitized%20report/sanitized%20engineering%20reports/p090019.sanitized.eng.txt[5/11/2010 1:13:28 PM] RELEASE TOTAL 2.4E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 9 Basis: CEB assesses 3 workers/site. Inhalation: negligible (VP < 0.001 torr)

Dermal: Exposure to Liquid at % concentration High End: 1.2E+3 mg/day over 60 days/yr Number of workers (all sites) with dermal exposure: 9 Basis:

CBI: MEMORANDUM of CBI TELEPHONE CONVERSATION CALL BY: Anthony Gaglione Organization: ERG CALL TO: Organization: Date: 10/27/2008 Time: 12:06 PM Phone: Concerning what TSCA CBI? PMN: 09-0019