OCCUPATIONAL EXPOSURE RATING: 1-2B

NOTES & KEY ASSUMPTIONS: 

Generated by the 09/30/2013 version of ChemSTEER. This PMN is a 

site-limited chemical intermediate: synthetic 5-0573 is 

used to make all chemicals in consolidated set . The SAT 

report lists concern for dermal, drinking water, and inhalation 

exposures, as well as releases to water with a CoC of 220 ppb. This IRER

assesses all release media and exposure activities. // No same 

submitter, similar use past cases were found. The following different

submitter, si

consistency: 

were manufactured and used as volatile liquids, and assessed air 

releases and inhalation exposures (consistent with this IRER). L15-0257 

was manufactu impor olid particulate (not consistent with

this IRER). and referenced the updated March 2015 

guidance for estimating equipment g during chemical intermediate

use (consistent with this IRER); was generated prior to March 

2015. 

POLLUTION PREVENTION CONSIDERATIONS:

P2 Claim: This chemical is being utilized as an intermediate in 

production of furoate esters, which are expected to displace the use

of toluene (and in some cases benzene and xylene) as a raw starting 

material for the production of solvents and plasticizers. Furoate esters

exhibit the same functional properties as benzoate esters, which are 

used as both solvents and plasticizers. 

EXPOSURE-BASED REVIEW: No 
INITIAL REVIEW ENGINEERING REPORT 

PMN: 15-0573 

Manufacturing: Continuous 

Production Facility Albuquerque NM 87112

Number of Sites/ Location: 1 

Days/yr: 250 

Basis: The submission indicated a continuous process at 1 

submitter-controlled site. The submission estimates 40 kg/day (max),

18 hr/day, 260 days/yr. To scale up to the 3rd year PV and to maximize

exposure and release estimates, EPA assumes 250 days/yr. CS calculates

60 kg/day. PMN is produced at 50-90%. 

Process Description: Raw materials charged to reaction vessel -->

Solid/liquid separation --> Liquid/liquid separation --> 

Stabilization --> Packaging (liquid, 50-90%) (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. 
Air 

Output 2: 2.2E-2 kg/site-day over 250 days/yr from 1 site 

or 5.4E+0 kg/site-yr from 1 site or 5.4E+0 kg/yr-all sites 

to: air 

from: Equipment Cleaning Losses of Liquids from Multiple Vessels 

basis: EPA/OPPT Mass Transfer Coefficient Model. 

Air 

Typical: 1.3E-5 kg/site-day over 250 days/yr from 1 site 

or 3.2E-3 kg/site-yr from 1 site or 3.2E-3 kg/yr-all sites 

Worst Case: 2.5E-5 kg/site-day over 250 days/yr from 1 site 

or 6.4E-3 kg/site-yr from 1 site or 6.4E-3 kg/yr-all sites 

to: air 

from: Loading Liquid Product into Drums 

basis: EPA/OAQPS AP-42 Loading Model. 

Incineration 

Conservative: 1.2E+0 kg/site-day over 1 day/yr from 1 site 

or 1.2E+0 kg/site-yr from 1 site or 1.2E+0 kg/yr-all sites 

to: TSDF (amendment) 

from: Equipment Cleaning Losses of Liquids from Multiple Vessels 

basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard

2% residual. The submission does not discuss equipment cleaning. Because

of a continuous process, EPA assumes equipment cleaning once per year

(at the end of a campaign). The additional information sent in for 

P15-477 (product of P-15-573) indicates that the equipment cleaning 

waste is sent to TSDF (permitted Treatment, storage and disposal 

facilites) 

RELEASE TOTAL 

6.7E+0 kg/yr - all sites 

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 3

Basis: The submission estimates up to 3 workers potentially exposed.
Inhalation: 

Exposure to Vapor (volatile) (Class II)

Typical: 

> Potential Dose Rate: 6.1E-3 mg/day over 250 days/yr 

> Lifetime Average Daily Dose: 3.4E-5 mg/kg-day over 250 days/yr

> Average Daily Dose: 6.0E-5 mg/day over 250 days/yr 

> Acute Potential Dose: 8.7E-5 mg/day over 250 days/yr 

Worst Case: 

> Potential Dose Rate: 3.7E-1 mg/day over 250 days/yr 

> Lifetime Average Daily Dose: 2.1E-3 mg/kg-day over 250 days/yr

> Average Daily Dose: 3.6E-3 mg/day over 250 days/yr 

> Acute Potential Dose: 5.2E-3 mg/day over 250 days/yr 

Number of workers (all sites) with inhalation exposure: 3 

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? No 

 OR 

 b) Hazard Rating for health of 2 or greater? 2 Yes 

=> Inhalation Monitoring Data Desired? No

Dermal: 

Exposure to Liquid at 90.00% concentration

High End: 

> Potential Dose Rate: 2.0E+3 mg/day over 250 days/yr 

> Lifetime Average Daily Dose: 1.1E+1 mg/day over 250 days/yr

> Average Daily Dose: 2.0E+1 mg/day over 250 days/yr 

> Acute Potential Dose: 2.9E+1 mg/day over 250 days/yr 

Number of workers (all sites) with dermal exposure: 3 

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

with Liquids Model. 
INITIAL REVIEW ENGINEERING REPORT 

PMN: 15-0573 

Use: Site-Limited Chemical Intermediate

Production Facility Albuquerque NM 87112

Number of Sites/ Location: 1 

Days/yr: 203 

Basis: Chemical is a site-limited intermediate. The submi es not

provide process details. The product of the reaction, 

indicates a batch process, 138 batches/yr. The standard review for the

subsequent chemical assumed 203 days/year. Assume the same. 

Process Description: uid, 50-90%) added to reaction vessel -->

Reaction to produce --> 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: 5.6E+0 kg/site-day over 80 days/yr from 1 site 

or 4.5E+2 kg/site-yr from 1 site or 4.5E+2 kg/yr-all sites 

to: 

from: Cleaning Liquid Residuals from Drums Used to Transport the Raw

Material 

basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. 

Submission does not discuss container cleaning and were not able to get

more information from the company. EPA assesses release to uncertain 

media as conservative. 

Air 

Typical: 1.6E-5 kg/site-day over 203 days/yr from 1 site 

or 3.2E-3 kg/site-yr from 1 site or 3.2E-3 kg/yr-all sites 

Worst Case: 3.2E-5 kg/site-day over 203 days/yr from 1 site 

or 6.5E-3 kg/site-yr from 1 site or 6.5E-3 kg/yr-all sites 

to: air 

from: Unloading Liquid Raw Material from Drums 

basis: EPA/OAQPS AP-42 Loading Model. 

Air 

Output 2: 1.4E-6 kg/site-day over 80 days/yr from 1 site 

or 1.1E-4 kg/site-yr from 1 site or 1.1E-4 kg/yr-all sites 

to: air 

from: Cleaning Liquid Residuals from Drums Used to Transport the Raw

Material 

basis: EPA/OPPT Penetration Model. 

Air 

Output 2: 5.4E-3 kg/site-day over 203 days/yr from 1 site 

or 1.1E+0 kg/site-yr from 1 site or 1.1E+0 kg/yr-all sites 

to: air 

from: Equipment Cleaning Losses of Liquids from a Single, Large Vessel

basis: EPA/OPPT Mass Transfer Coefficient Model.

Incineration 

Output 1: 7.4E-3 kg/site-day over 203 days/yr from 1 site 

or 1.5E+0 kg/site-yr from 1 site or 1.5E+0 kg/yr-all sites 

Output 2: 3.7E-2 kg/site-day over 203 days/yr from 1 site 

or 7.5E+0 kg/site-yr from 1 site or 7.5E+0 kg/yr-all sites 

to: TSDF (amendment) 

from: Equipment Cleaning Losses of Liquids from a Single, Large Vessel
basis: User-Defined Loss Rate Model. The submission does not discuss 

equipment cleaning. Per March 2015 guidance on assessing releases of

a chemical intermediate from reactor cleaning, EPA assumes 95-99% 

reaction, with 1% residual. Therefore, LF = (1-0.95 to 0.9 01 = 

0.0001 to 0. e additional information sent in for 

(product of ) indicates that the equipment cleaning waste is

sent to TSDF (permitted Treatment, storage and disposal facilites) 

RELEASE TOTAL 

4.6E+2 kg/yr - all sites 

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 7

Basis: P15-0474C, the next step in the synthetic sequence estimates up

to 7 workers potentially exposed during the USE operation. 
Inhalation: 

Exposure to Vapor (volatile) (Class II)

Typical: 

> Potential Dose Rate: 7.6E-3 mg/day over 203 days/yr 

> Lifetime Average Daily Dose: 3.5E-5 mg/kg-day over 203 days/yr

> Average Daily Dose: 6.1E-5 mg/day over 203 days/yr 

> Acute Potential Dose: 1.1E-4 mg/day over 203 days/yr 

Worst Case: 

> Potential Dose Rate: 4.6E-1 mg/day over 203 days/yr 

> Lifetime Average Daily Dose: 2.1E-3 mg/kg-day over 203 days/yr

> Average Daily Dose: 3.6E-3 mg/day over 203 days/yr 

> Acute Potential Dose: 6.5E-3 mg/day over 203 days/yr 

Number of workers (all sites) with inhalation exposure: 7 

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, 

 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? No

Dermal: 

Exposure to Liquid at 90.00% concentration

High End: 

> Potential Dose Rate: 2.0E+3 mg/day over 203 days/yr 

> Lifetime Average Daily Dose: 9.2E+0 mg/day over 203 days/yr

> Average Daily Dose: 1.6E+1 mg/day over 203 days/yr 

> Acute Potential Dose: 2.9E+1 mg/day over 203 days/yr 

Number of workers (all sites) with dermal exposure: 7 

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal 

Contact with Liquids Model.