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 Source 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 TOTAL
file:///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: 09-0019

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