p080179.en3 INITIAL REVIEW ENGINEERING REPORT PMN: 08-0179 Post-Focus Draft Revision 3 6/18/2009
ENGINEER: El-Zoobi \ DDH PV (kg/yr):

MSDS: Yes Label: No
Gen Eqpt: no equipment of engineering controls were provided in the submission (it appears pages were omitted from EC safety data sheet) Respirator: no respirator information was provided in the submission (it appears pages were omitted from EC safety data sheet) Health Effects: no health effects listed in the EC safety data sheet TLV/PEL: none established. Page 1p080179.en3

CRSS (01/24/2008): Chemical Name: 1,2,3-Propanetricarboxamide, N1,N2, N3-tris(2-methylcyclohexyl)- S-H20: 0.00028 g/L @ VP: 1.0E-6 torr @ MW: 461.69 %<500 %<1000 Physical State and Misc CRSS Info: Neat: Solid (white powder) Mfg: NK: Imported Proc/Form: Dispersion: < 0.5% PMN substance in dry plastic blend End Use: Solid: < 0.5% PMN substance entrained in plastic. Submitted Data: MP > 270°C (Exp, dec.); BP: decompose; VP = 1.358E-14 torr (Sub. Est.); S-H2O < 0.00028 g/L (Exp); Log P = 2.9-3.4 (Exp, midrange = 3.15); log Koc = 3.4 (Sub.Est.); density = 1.073 g/cm3; particle size = 12.5 μm. Submitted: FTIR, 1HNMR, UV/Vis spectra. The 1H NMR spectrum is consistent with the structure of the PMN substance. Estimated Data (EPI): BP = 702.76°C; VP = 9.69E-17 torr; S-H2O = 0.00004407 g/L; Log P = 5.22. Estimated Data (ACD Labs): BP = 728.2°C; VP = 4.62E-21 torr; S-H2O = 0.0012 g/L; Log P = 5.036.

Consumer Use: No
SAT (concerns) (01/25/2008): Migration to groundwater: Moderate PBT rating: P3B1T1 Health: 1 Eco: 2 Water (All releases to water with a CC = 7 ppb)

OCCUPATIONAL EXPOSURE RATING: NR

NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER.

POLLUTION PREVENTION CONSIDERATIONS: None Page 2p080179.en3

EXPOSURE-BASED REVIEW: No

INITIAL REVIEW ENGINEERING REPORT PMN: 08-0179
Processing:
Number of Sites/ Location: 4 unknown formulator sites Days/yr: 45 Basis: Submission states: 4 sites, 35-45 d/yr.
Process Description: Imported containers ( % solid PMN) unloaded and added to blender -> blended in with polyproplyene powder -> loading into containers ( % PMN in solid mixture), 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.

Incineration or Landfill Output 1: 1.9E+0 kg/site-day over 45 days/yr from 4 sites or 3.5E+2 kg/yr to: Uncertain (per GS) from: Unloading Solid Raw Material from Transport Containers

Landfill Output 2: 3.9E+0 kg/site-day over 45 days/yr from 4 sites or 7.0E+2 kg/yr to: Landfill (per Techncial Contact) from: Cleaning Solid/ Powder Residuals from Containers Used to Transport the Raw Material

RELEASE TOTAL 1.1E+3 kg/yr - all sites

Page 3p080179.en3

INITIAL REVIEW ENGINEERING REPORT PMN: 08-0179

Use: Number of Sites/ Location: 21 unknown use sites Days/yr: 250

Process Description: PMN and other additives heated -> molding/shaping -> trimming -> Finishing -> finsihed plastic article (per GS for Plastics Converting; PMN entrained in plastic, per 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.

MEMORANDUM of CBI TELEPHONE CONVERSATION

Page 4p080179.en3 CALL TO: Liam Killough

Date: 01/30/2008

Time: 10:30 AM

PMN: 08-0179

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