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0I5t.?R29 :.:111 : 32 Federal Express April 28, 2015 Document Control Office (7407M)
- Room 6428 (202) 564-8930 OPPT U.S. EPA Confidential Business Information Center (CBIC) 1201 Constitution Ave., NW Washington, DC 20460-0001 Ladies and Gentlemen: CBIC Control Number 

# 364852·1

Re: Proposed Significant New Use Rule Toluene Diisocyanates (TDI) and Related Compounds, 80 FR 2068 (January 15, 2015); Docket ID: EPA-HQ-OPPT-2011-0976 [ ] company that manufactures 2,4-toluene diisocyanate (CASRN 584- 84-9), 2,6-toluene diisocyanate (CASRN 91-08-7), toluene diisocyanate unspecified isomers (CASRN 26471-62-5) (these three substances hereafter referred to as TDI). [ ] manufactures TDI for distribution in commerce, primarily for industrial and commercial use, 

### [ 

### ]

. [ 

### ] These comments will: 1) inform the U

.S. EPA of [ ] existing manufacture, processing, use and distribution ofTDI, including distribution to consumers; 2) provide industrial hygiene monitoring and [ ] data supporting a conclusion of low exposure; 3) seek clarity on compliance requirements. 1. Existing Manufacture, Processing, Use and Distribution of TDI Manufacture ofTDI [ Processing ofTDI [ Use ofTDI by BASF and Third Parties 

### [ ] Distribution ofTDI [ 2. Industrial Hygiene and [ 

### 1Data

# ..

3. Compliance Requirements Associated with the Proposed SNUR The proposed SNUR does not prohibit the manufacture ofTDI , however, 40 CFR 721.5(a)(1) states that a manufacturer or importer ofTDI who distributes the substance in commerce for a new use must first file a SNUN

. [ ] Further, 40 CFR 721.5(a)(2) states a manufacturer who does not engage in a new use, but distributes a SNUR substance in commerce must file a SNUN unless it notifies recipients ofthe SNUR. [ ] 40 CFR 721 .5(b) also states that manufacturers who distribute a SNUR substance in commerce to recipients that it knows will engage in a new use to file a SNUN

. [ ]

Best Regards,LIST OF ATTACHMENTS 1) [ 

### 2) Commercial Distribution 3) [ ] 4) [ ] 5) [ ] 

### 6) EPA-HQ-OPPT-2011
-0976-0002 7) Isocyanate Testing During Spray Roof Application [ 8) Test DataAttachment 1Attachment 2Attachment 3Attachment 4Attachment 5Attachment 6 EPA-HQ-OPPT-2011-0976-0002 copy obtained from docketInteroffice Date: May 27, 2009 To: From: Subject: Isocyanate testing during [ Revised April 2015* ] RoofAppl ication at [
Executive Summary Industrial hygiene air monitoring was conducted at [ May 4, 2009 to assess airborne concentrations of [ ] facility on April 29 and ] TOI during application ofa [ ] roof system. Testing was performed during [ ] application ofthree spray top coatings: [ ]

. The [ ] coatings were identified as containing up to [ TDI and [ ] containing up to [ 

### ]

. Results from the monitoring indicate • Recommendations • The personal protective equipment protocols in use at the time by the sprayerwere appropriate for isocyanate protection and should be continued

. Others on the roof near the spray operation should follow similar protocols

.



# . [ ].
• Conduct sampling to evaluate solvent emissions from spray coat systems
. • Advise facility maintenance engineers to close off air intakes and exhausts necessary to prevent vapors from being drawn into building

.Introduction and Scope At the request of [ ] isocyanate exposure assessmentwas conducted during a spray roofing system application that included [ ] TDI. Personal breathing zone samples were taken ofthe spray applicator while area samples were taken directly downwind at ground level approximately 30 feet from the building

. Site Conditions The [ ] facility shut off air intakes and exhausts near the spray area and closed the parking lot to the south which was generally downwind. Otherwise, normal operations were conducted. The weather conditions on day one included light rain in the morning with clearing by late afternoon

.Winds ranged from 5- 15 mph in the early afternoon to less than 5 mph in the evening

. Sampling during [ ] application occurred in the afternoon while the [ ] tests occurred in the evening when the winds had calmed

. The weather conditions on day two were sunny with winds ranging from 5- 15 mph in the early afternoon to less than 5 mph in the evening

. [ ] testing also occurred in the evening when the winds had calmed and temperature were above 60°F. Regulated Limits The Occupational Safety & Health Administration (OSHA) specifies a ceiling limit of 20 parts per billion (ppb) for both isocyanates while the American Conference of Governmental Industrial Hygienists (ACGIH) has established a Threshold Limit Value (TLV) for both isocyanates of 5 ppb as an 8-hour Time-Weighted Average (TWA)

. Methodology Sampling was performed using SKC AirCheck Hi-Flow pumps to collect personal breathing zone and area samples of isocyanate aerosol and vapor. The pumps were calibrated to a flow-rate ofapproximately 1.0 Llminute using a BIOS dry piston calibrator. The average flowrate before and after sampling was used to calculate air volumes

. The samples were collected on 13 mm glass fiber filters impregnated with 1-(2-pyridyl) piperazine (1 ,2 PP). As soon as a sample was collected, the filter was removed from the cassette with tweezers and placed in a vial containing two milliliters of a solution containing 90% acetonitrile and 10% dimethylsulfoxide.The vials along with a blankfilter in a vial of solution were shipped to [ ] lab

. The samples were analyzed using a modified version of OSHA Method 47 at this American Industrial Hygiene Association (AIHA) accredited laboratory

. The concentrations reported in ppb include the vapor and aerosol form ofthe isocyanates

. 

### Observations 1) Solvent odors were evident on the roof, inside the building and downwind outside the building during spraying. A slight negative pressure relative to outdoors existed inside the building. 2) Solvent thinning ofthe coatings using xylene was performed

. Grounding and bonding of solvent transfer equipmentwas lacking. 3) Roofing personnel working near the spray applicator did not follow same PPE protocol as the spray applicator. Wind direction occasionally shifted and roof equipment (HVAC, etc
.) created turbulent wind currents
. 

### Results The [ ] result forthe [ ] while applying the [ ] urethane foam was below the OSHA ceiling limit of 20 ppb

. The area sample taken approximately 30 feet downwind was non-detect. Continuous spraying over an entire shift could result in a sprayer exposure at or above the ACGIH TLV of 5 ppb

. The sprayer used appropriate PPE to prevent overexposure to [ ]. Table 1 : [ 

### 1 Results Sample ID Date Type Material Sprayed Result (ppb) 04/29/09 Area *NO @ 0.22 ppb 04/29/09 Personal 6
.8 All TDI results were below detection limits. Table 2· TDI Results 

### . Sample ID Date Type Material Applied 2,4TDI 2,6TDI Result (ppb) Result (ppb) 04/29/09 Area NO @ 0
.21 NO @ 0.53 04/29/09 Personal NO@ 0.32 NO@ 0.81 05/04/09 Area NO@ 0.40 NO@ 0.99 05/04/09 Personal NO @ 0.43 NO @ 1
.1 05/04/09 Area NO@ 0.49 NO@ 1 .2 05/04/09 Personal NO@ 0.42 NO@ 1.1

.. *NO 

## =Not Detected at spec1f1 ed detect1on hm1t.Conclusions and Recommendations 1) The results indicate TDI was not detectable when applying any ofthe [ ] coatings containing [ ] TDI and the [ containing ] TDI. 2) [ 3) The personal protective equipment protocols in use atthe time were appropriate for isocyanate protection and should continue

. Others personnel on the roof near the [ ] operation should follow similar protocols. 4) It is recommended that additional sampling be conducted to evaluate TDI exposure when spraying the [ ] and repeat sampling for all coatings to increase statistical validity ofthe dataset. 5) It is also recommended thatfurther evaluation of solvent emissions from [ systems be performed to determine nuisance, industrial hygiene, safety and environmental impacts related to solvent usage in these systems. 6) Instruction should be provided to building maintenance personnel regarding proper building pressurization and precautions necessary for air intakes and exhausts to prevent vapor entrainment during [ ] operations. 7) Grounding and bonding of solventtransfer should be initiated and enforced

. Itwould be preferable that no solvent be added to the [ ] formulations

.

### Attachment 8 Test Data