p130453.eng

INITIAL REVIEW ENGINEERING REPORT 

PMN: 13-0453

Focus Ready Draft 7/29/2013

ENGINEER: Jon \ EV

PV (kg/yr): 300

SUBMITTER: Henkel Corporation

USE: Coatings for electronic components. ortho/para

Phenol FGEW = 122 (Worst case, assuming one reactive site

per phenyl ring).

OTHER USES: Analogs 

 are used as resins in photoresist coatings.

Analog is used as a chemical intermediate in the

manufacture of photoresists. Analog is used as

a resin for microelectronics processing coating. Analog

 is used as a chemical intermediate for a

photoactive compound. Analog is used as a

chemical intermediate. Analog is used as a

film-forming component of a photoresist formulation.

MSDS: Yes Label: No

Gen Eqpt: Provide adequate local exhaust ventilation.

Wear safety goggles or safety glasses with side shields.

Wear full face protection if potential exists for

splashing or spraying. Use chemical resistant,

impermeable clothing, including gloves and either an

apron or body suit.

Respirator: Use a NIOSH-approved air-purifying respirator.

Health Effects: Combustible liquid and vapor. May cause

central nervous system effects. Causes eye irritation.

May cause skin and respiratory tract irritation.

TLV/PEL:

Toluene, Hydroxy-2-methylpentan-4-on-2, and n-Butyl

alcohol 20 , 50, and 20 ppm ACGIH TLV

CRSS :

Chemical Name: Formaldehyde, polymer with 2,

3-dimethylphenol, 2,4-dimethylphenol, 2,5-dimethylphenol,

3,5-dimethylphenol, 3-ethylphenol, 4-ethylphenol,

3-methylphenol, 4-methylphenol and phenol

S-H20: 0.0167 g/L @

VP: 1.0E-6 torr @

MW: 255.00 40.50%<500 53.60%<1000

Physical State and Misc CRSS Info:

Neat: Liquid (Est.) Mfg: Solution: 35% PMN material in

water, toluene, n-butanol, and diacetone alcohol

Proc/Form: Solution: 18.81% PMN material End Use:

Destroyed (Est.). NAVG = 255 with 40.5% < 500 and 53.6% <

1000 by GPC. Submitted Properties: None, the MSDS is for

formulated material. The IR spectrum is included with the

PMN submission. Estimated Properties: BP = 398 °C (EPI);

VP = 4.9E-7 torr (EPI); WS = 0.0167 g/L (EPI); logP = 5.

24 (EPI). The EPI estimations were performed for the

reaction product of 2 equivalents of dimethylphenol and 1

equivalent of formaldehyde, having a molecular weight of

256 g/mole and a molecular formula of C17 H20 O2.

Page 1
p130453.eng

ortho/para Phenol FGEW = 122 (Worst case, assuming one

reactive site per phenyl ring).

Consumer Use: No

SAT (concerns) (07/19/2013):

Related Cases and Related Cases and Misc SAT Info:

.

Migration to groundwater: Slow

PBT rating: P1B1T2 .

Health: 1-2 Dermal, Drinking Water, Inhalation

Eco: 3 Water (All releases to water with a CC = 5 ppb.)

OCCUPATIONAL EXPOSURE RATING: 1B

NOTES & KEY ASSUMPTIONS:

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

technical contact was called for additional information

on PMN use (see contact report). For consistency, this

IRER references the following different-submitter,

similar-use past cases: . /// MFG: No releases assessed. Submission indicates all

releases will be sent to incineration -- incineration

release assessment triggers not met. This IRER presents

dermal exposures from container loading. // USE: This

IRER assesses releases to uncertain media from equipment

and container cleaning residuals (consistent with all

past cases). This IRER presents dermal exposures from

container unloading (consistent with all past cases).

Inhalation exposures not expected (negligible VP)

(consistent with all past cases).

POLLUTION PREVENTION CONSIDERATIONS:

P2 Claim: All waste streams are captured and treated as

hazardous waste. Waste is not released to a landfill or

drain.

EXPOSURE-BASED REVIEW: No

INITIAL REVIEW ENGINEERING REPORT 

PMN: 13-0453

Manufacturing

Number of Sites/ Location: 1

Henkel Corporation Salisbury NC 28147

Days/yr: 9

Basis: Submission indicates 1 site, 9 bt/yr, and 33 kg/bt.

Process Description: Raw materials charged to reactor ->

Reaction (PMN created; liquid, 35%PMN) -> QC sampling ->

Transfer to 5-gal pails (per submission and CRSS)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

Submission indicates that aqueous, equipment cleaning

solvent, and QC sampling wastes are incinerated. These

releases are not assessed below since release triggers

not met. Submission did not provide daily or annual

release estimates; however, the released amount would be

<<28,000 kg/st-day (acute assessment trigger) and <<698,

000 kg/st-yr (chronic assessment trigger).

Page 2
p130453.eng

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 6

Basis: Submission states 6 workers/site.

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 35.00% concentration

High End: 6.2E+2 mg/day over 9 days/yr

Number of workers (all sites) with dermal exposure: 6

Basis: Loading Liquid Product into Containers; EPA/OPPT

2-Hand Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 13-0453

Use: Dip Coating of Electronics

Number of Sites/ Location: 6

unknown sites

Days/yr: 250

Basis: Submission did not provide information on

downstream uses of PMN. Technical contact indicated 6

sites. CEB assumes 250 bt/yr. CS calculates 0.2 kg/bt.

Process Description: PMN received in 5-gal pails (liquid,

35% PMN) -> Transfer to dip coater and mixed with other

coating additives (liquid, 18.81% PMN) -> Dip coating ->

Heat curing (PMN destroyed) (per technical contact 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: 2.0E-1 kg/site-day over 8 days/yr from 6 sites

or 9.5E+0 kg/yr

to:

from: Cleaning Liquid Residuals from Containers Used to

Transport the Raw Material

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

residual.

Water or Incineration or Landfill

Conservative: 2.0E-3 kg/site-day over 250 days/yr from 6

sites

or 3.0E+0 kg/yr

to:

from: Equipment Cleaning Losses of Liquids from a Single,

Large Vessel

Page 3
p130453.eng

basis: EPA/OPPT Single Vessel Residual Model, CEB

standard 1% residual.

RELEASE TOTAL

1.3E+1 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 18

Basis: Submission did not provide information on

downstream uses of PMN. CEB assumes a minimum default of

3 workers/site.

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 35.00% concentration

High End: 6.2E+2 mg/day over 250 days/yr

Number of workers (all sites) with dermal exposure: 18

Basis: Unloading Liquid Raw Material from Containers;

EPA/OPPT 2-Hand Dermal Contact with Liquids Model.



CBI: Yes

MEMORANDUM of CBI TELEPHONE CONVERSATION

CALL BY: Edward Viveiros

Organization: ERG for EPA

CALL TO: Dale Starkey

Organization: Henkel Electronic Materials LLC

Date: 07/22/2013

Time: 11:15 AM

Phone: 

Concerning what TSCA CBI?

PMN: 13-0453

Q1: Could you please elaborate on the downstream

processing/use of the PMN?| A1: The PMN formulation will

be shipped to about 6 sites, where it will be used as a

polymer coating for capacitors. The capacitors will be

dip coated and then heat cured. (Note that the submitter

indicated spray or roll coating are not likely

application methods for the PMN.)

Page 4