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 1p130453.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).

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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 3p130453.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.)

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