Initial Review Engineering Report for Premanufacture Notice (PMN) P-10-0452.txt

INITIAL REVIEW ENGINEERING REPORT 

PMN: 10-0452

Focus Ready Draft 8/16/2010

ENGINEER: Avcin \ BCS/CLM

PV (kg/yr): 

Revision Notes / Assessment Overview: Made fixes 8/11/10

according to CEB markups on first draft of IRER

SUBMITTER: Huntsman Corporation

USE: Epoxy curing agent which will be blended with an

epoxy resin system and injected into a mold containing

fiberglass. The finished article will be a wind turbine

blade for us

OTHER USES: 

MSDS: Yes Label: No

Gen Eqpt: Eng Controls: local exhaust ventilation. //

Eyes: safety eyewear. // Skin: personal protective

equipment for the body should be selected based on the

task being performed. // Hands: cheimcal-resistant,

impervious gloves.

Respirator: use a properly fitted, air-purifying or

air-fed respirator complying with an approved standard if

a risk assessment indicates this is necessary.

Health Effects: Corrosive to eyes and skin. Causes burns.

 May be harmful if absorbed through skin or if swallowed.

TLV/PEL:

none established

CRSS :

Chemical Name:

 

 Physical State and Misc CRSS Info:

Consumer Use: 

SAT (concerns) (08/06/2010):

Page 1

EPA SANITIZED Page 1 of 7
Initial Review Engineering Report for Premanufacture Notice (PMN) P-10-0452.txt

Related Cases and Related Cases and Misc SAT Info:

Migration to groundwater: Moderate

PBT rating: P1B1T1 .

Health: 2-3 Dermal, Inhalation

Eco: 2 Water (All releases to water with a CC = 98 ppb)

OCCUPATIONAL EXPOSURE RATING: 2-3B

NOTES & KEY ASSUMPTIONS:

Generated by the 06/07/2005 version of ChemSTEER. 

POLLUTION PREVENTION CONSIDERATIONS:

EXPOSURE-BASED REVIEW: 

INITIAL REVIEW ENGINEERING REPORT 

PMN: 10-0452

Page 2

EPA SANITIZED Page 2 of 7
Initial Review Engineering Report for Premanufacture Notice (PMN) P-10-0452.txt

MFG: Manufacture of PMN

Number of Sites/ Location: 

Days/yr: 

Basis:

Process Description:

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. 

Output 2: 

to: 

from:

basis:

Output 2: 

to: 

from: 

basis:

Output 2: 

to: 

from: 

basis:

Output 2: 

to: 

from:

basis: 

Page 3

EPA SANITIZED Page 3 of 7
Initial Review Engineering Report for Premanufacture Notice (PMN) P-10-0452.txt

Typical: 

Worst Case: 

to: air 

from: 

basis: 

Typical: 

Worst Case: 

to: 

from: 

basis: 

RELEASE TOTAL

 kg/yr -

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

Inhalation:

Exposure to 

Typical: 

Worst Case: 

Number of workers (all sites) with inhalation exposure: 

Basis:

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit

 or data not specific to industry): 

2)a) Exposure level > 1 mg/day? 

 OR

 b) Hazard Rating for health of 2 or greater?

Inhalation Monitoring Data Desired? 

met)

Exposure to 

Typical: 

Worst Case: 

Number of workers (all sites) with inhalation exposure: 

Basis:

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit

 or data not specific to industry): 

2)a) Exposure level > 1 mg/day? 

 OR

 b) Hazard Rating for health of 2 or greater?

Inhalation Monitoring Data Desired? 

Page 4

EPA SANITIZED Page 4 of 7
Initial Review Engineering Report for Premanufacture Notice (PMN) P-10-0452.txt

Dermal:

Exposure to 

High End: 

Number of workers (all sites) with dermal exposure: 

Basis:

Exposure to 

High End: 

Number of workers (all sites) with dermal exposure: 

Basis:

INITIAL REVIEW ENGINEERING REPORT 

PMN: 10-0452

PROC/USE: Fiberglass Wind Blade Production

Number of Sites/ Location: 

 Days/yr: 

Basis:

Process Description:

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. 

Output 2: 

to: 

from: 

basis:

High End: 

to: 

from:

basis: 

 

 

Conservative:

Page 5

EPA SANITIZED Page 5 of 7
Initial Review Engineering Report for Premanufacture Notice (PMN) P-10-0452.txt

to: 

from:

basis:

Output 2: 

to: 

from: 

basis:

Typical: 

Worst Case: 

to: 

from: 

basis: 

Output 2: 

to: 

from:

basis: 

Output 2: 

to: 

from:

basis: 

RELEASE TOTAL

 kg/yr - 

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

Inhalation:

Exposure to 

Typical: 

Worst Case: 

Number of workers (all sites) with inhalation exposure: 

Basis:

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit

 or data not specific to industry): 

Page 6

EPA SANITIZED Page 6 of 7
Initial Review Engineering Report for Premanufacture Notice (PMN) P-10-0452.txt

2)a) Exposure level > 1 mg/day? 

 OR

 b) Hazard Rating for health of 2 or greater?

Inhalation Monitoring Data Desired? 

met)

Dermal:

Exposure to 

High End: 

Number of workers (all sites) with dermal exposure: 

Basis:

Page 7

EPA SANITIZED Page 7 of 7