file:///J|/INITENG/P13%20cases/p130472.eng.txt[7/2/2013 7:30:58 AM]

INITIAL REVIEW ENGINEERING REPORT 

PMN: 13-0472

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 

 monomer/crosslinker in epoxide

adhesive materials. reactive monomer for

poly(ethyleneglycol) polymers. chemical

intermediate. cross-linking monomer for

polymer microspheres for oil field profile control. 158:

: functionalized monomer for PEGylation and

functionalization of Metal Oxide Nanoparticles.

OTHER USES: modifier of electrolyte of

lithium-sulfur rechargeable batteries. Analog 

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. // Skin: May be

harmful if absorbed through skin. May cause skin

irritation. // Eyes: May cuase irritation. // Ingestion:

May be harmful if swallowed.

TLV/PEL:

None established.

CRSS (06/06/2013):

Chemical Name: Oxirane, 2-[[2-(ethenyloxy)ethoxy]methyl]-

S-H20: 501 g/L @

VP: 2.2E-1 torr @

MW: 144.00 %<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 = 71 °C (est.); specific gravity = 0.97.

Literature data (STN eprop): BP = 66 °C at 2.7 torr.

NOMO5 estimated data from measured boiling point: BP =
file:///J|/INITENG/P13%20cases/p130472.eng.txt[7/2/2013 7:30:58 AM]

215 °C and VP = 0.22 torr. EPI estimated data (input MP =

20 °C): BP = 174 °C; VP = 1.74 torr; WS = 501 g/L; log P

= -0.31. ACD Labs estimated data (STN pprop): BP = 202.5

°C; VP = 0.414 torr; WS = 35 g/L; log P = 0.346.

Consumer Use: No

SAT (concerns) (06/07/2013):

Related Cases and Related Cases and Misc SAT Info:

Migration to groundwater: Rapid

PBT rating: P1B1T1 .

Health: 2 Dermal, Inhalation

Eco: 2 Water (All releases to water with a CC = 100.00

ppb)

OCCUPATIONAL EXPOSURE RATING: 2B

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. 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: 13-0472

Manufacturing: Batch

Number of Sites/ Location: 2
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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.

Process Description: Reagent Charging --> Reactor Vessel

--> Reaction --> Separation Flask --> Distillation

(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

Typical: 3.4E-4 kg/site-day over 2 days/yr from 2 sites

Worst Case: 6.7E-4 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.

Air

Output 2: 9.7E-2 kg/site-day over 2 days/yr from 2 sites

to: Air (model)

from: Equipment Cleaning Losses of Liquids from Multiple

Vessels

basis: EPA/OPPT Mass Transfer Coefficient Model.

Incineration

Conservative: 1.0E+1 kg/site-day over 2 days/yr from 2

sites

or 4.0E+1 kg/yr

to: Off-site Incineration (per submission)

from: Equipment Cleaning Losses of Liquids from Multiple

Vessels

basis: EPA/OPPT Multiple Process Vessel Residual Model,

CEB standard 2% residual. Submission estimates 0.5 kg/bt

of liquid process waste from aqueous layer disposal and 0.

343 kg/bt of liquid waste from distillation are 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

4.0E+1 kg/yr - all sites
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OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 10

Basis: Submitter estimates exposure for up to 9 workers

for all sites; CEB assumes 5 workers/site and that all

workers conduct all activities.

Inhalation:

Exposure to Vapor (Class II)

Typical: 1.6E-1 mg/day over 2 days/yr

Worst Case: 9.7E+0 mg/day over 2 days/yr

Number of workers (all sites) with inhalation exposure: 10

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: 10

Basis: Loading Liquid Product into Drums; EPA/OPPT 2-Hand

Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 13-0472

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 (CRSS, past case

P13-0300, P09-0552, L09-0240)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources
file:///J|/INITENG/P13%20cases/p130472.eng.txt[7/2/2013 7:30:58 AM]

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

Typical: 2.7E-6 kg/site-day over 250 days/yr from 2 sites

Worst Case: 5.4E-6 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: 1.0E-7 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

6.2E+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: 1.3E-3 mg/day over 250 days/yr

Worst Case: 7.8E-2 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
file:///J|/INITENG/P13%20cases/p130472.eng.txt[7/2/2013 7:30:58 AM]

 or data not specific to industry): Yes

2)a) Exposure level > 1 mg/day? No

 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 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: 13-0472

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. | |