file:///J|/INITENG/P11%20cases/p110530.sr.txt[5/1/2013 1:59:04 PM] INITIAL REVIEW ENGINEERING REPORT PMN: 11-0530 Standard Review Draft 4/4/2013

ENGINEER: El-Zoobi \ AH \ JAS \ JD \ AG \ JASfile:///J|/INITENG/P11%20cases/p110530.sr.txt[5/1/2013 1:59:04 PM]file:///J|/INITENG/P11%20cases/p110530.sr.txt[5/1/2013 1:59:04 PM]file:///J|/INITENG/P11%20cases/p110530.sr.txt[5/1/2013 1:59:04 PM] INITIAL REVIEW ENGINEERING REPORT PMN: 11-0530file:///J|/INITENG/P11%20cases/p110530.sr.txt[5/1/2013 1:59:04 PM]file:///J|/INITENG/P11%20cases/p110530.sr.txt[5/1/2013 1:59:04 PM] .

INITIAL REVIEW ENGINEERING REPORT PMN: 11-0530file:///J|/INITENG/P11%20cases/p110530.sr.txt[5/1/2013 1:59:04 PM]file:///J|/INITENG/P11%20cases/p110530.sr.txt[5/1/2013 1:59:04 PM] INITIAL REVIEW ENGINEERING REPORT PMN: 11-0530file:///J|/INITENG/P11%20cases/p110530.sr.txt[5/1/2013 1:59:04 PM]file:///J|/INITENG/P11%20cases/p110530.sr.txt[5/1/2013 1:59:04 PM] INITIAL REVIEW ENGINEERING REPORT PMN: 11-0530file:///J|/INITENG/P11%20cases/p110530.sr.txt[5/1/2013 1:59:04 PM]file:///J|/INITENG/P11%20cases/p110530.sr.txt[5/1/2013 1:59:04 PM]file:///J|/INITENG/P11%20cases/p110530.sr.txt[5/1/2013 1:59:04 PM] INITIAL REVIEW ENGINEERING REPORT PMN: 11-0530file:///J|/INITENG/P11%20cases/p110530.sr.txt[5/1/2013 1:59:04 PM]file:///J|/INITENG/P11%20cases/p110530.sr.txt[5/1/2013 1:59:04 PM] INITIAL REVIEW ENGINEERING REPORT PMN: 11-0530file:///J|/INITENG/P11%20cases/p110530.sr.txt[5/1/2013 1:59:04 PM]file:///J|/INITENG/P11%20cases/p110530.sr.txt[5/1/2013 1:59:04 PM] INITIAL REVIEW ENGINEERING REPORT PMN: 11-0530file:///J|/INITENG/P11%20cases/p110530.sr.txt[5/1/2013 1:59:04 PM]file:///J|/INITENG/P11%20cases/p110530.sr.txt [5/1/2013 1:59:04 PM] C6F13 is 21.8% in PMN.// Perfluoro to WATER or INCINERATION or LAND from container cleaning to: uncertain: 2E-3 kg/site-day over 59 days/yr for 1 site or 0.1 kg/yr. // Perfluoro to WATER from Energency Use, to: POTW with dilution : 0.9 kg/site-day over 59 days/yr for 1 site or 54 kg/yr.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 24 Basis: CEB assesses the std default minimum of 3 workers/site.

Inhalation:

Exposure to Mist (non-volatile) (Class I) Output 1: 3.3E-2 mg/day over 1 days/yr Output 2: 1.7E+0 mg/day over 1 days/yr Number of workers (all sites) with inhalation exposure: 3 Basis: Emergency Use; User-defined Inhalation Model. Per P01-0232 (MW = 316, 100% conc), exposure to foam is expected during training and use on actual fires. During fire fighting, exposures to the foam, its degradation products, and toxic fumes from the fire may be expected to be acute. Portable extinguishers -- 80 ppm outdoors, 1 minute to 900 ppm indoors, >7.5 minutes = 24 to 1,800 mg/episode. Total flooding systems -- 7,000 ppm, > 1 minute or up to 10,000 ppm, < 1 minute (assume| 30 seconds) = <1,900 mg/episode. This IRER assesses a range of 80 ppm for 1 minute (portable fire| extinguisher) to 10,000 ppm for 30 seconds (flooding system). T he PMN concentration in the final foam is approximately 0.05% (per 11/4/11 amendment); therefore the exposure is adjusted according to the concentration. NOTE: The respirator class is: I. Particulate (including solid or liquid droplets).

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? Yes OR b) Hazard Rating for health of 2 or greater? 2 Yes Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal:

Exposure to Liquid at 1.20% concentration High End: 2.1E+1 mg/day over 1 days/yr Number of workers (all sites) with dermal exposure: 3 Basis: Unloading Liquid Raw Material from Tank Trucks; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.file:///J|/INITENG/P11%20cases/p110530.sr.txt [5/1/2013 1:59:04 PM] INITIAL REVIEW ENGINEERING REPORT CBI: Yes PMN: 11-0530

Use 4: Testing of Foam Systems at Industrial and Military Facilities (38.6% of Total PV)

Number of Sites/ Location: 96 unknown, different sites each yr; release from specific site once per period of expiration time. Days/yr: 2 Basis: To estmate the number of sites, CEB assumes PV x 99% x 95% industrial+military use / industrial use rate x Xnew. The industrial use rate is determined by the AFFF methodology (El-Zoobi and Avcin) estimates that the average amount of fluorinated surfactant used in commercial-industrial facilities = 1,900,000 gallons AFFF concentrate x density of AFFF concentrate x 1.06 % average fluorinated surfactant in concentrate / 149 refineries. (1.06% is the average PMN concentration in AFFF concentration for P11-530, P11-533, P11-534, P11-484, and P11-487). Calc:1,900,000 gal/site-yr x 3.78 kg/gal x 1.06% / 149 refineries = 510.93 kg/site-yr. Therefore, the number of sites = 52,000 x 99% x 95% industrial use / 510.93 kg/site-yr = 96 sites, with 1 day/site. CS calculates 6.8 kg/site-day.The total PV for this use is 653.2 kg/yr. See Release Section for discussion on rele ase days.

Process Description: AFFF concentrate (liquid, 1.2 %) mixed with water to a concentration of around 0.05% and discharged for testing purposes (per amendments 11/4/11 and 2/28/12)

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 Output 2: 3.4E+0 kg/site-day over 2 days/yr from 96 sites to: CEB assumes POTW (with dilution) from: System Testing basis: User-Defined Loss Rate Model. CEB assumes discharge from testing at industrial and military facilities will sent to POTW with dilution. Release of PMN is diluted during pre-treatment to not exceed a maximum concentration of AFFF concentrate in POTW influent that is indicated in product literature. A POTW influent flow rate of 1 million liters per day is assumed as a conservative value for calculation of a maximum number of release days. The number of days is calculated as follows: frequency = amount released / (concentration limit * POTW influent flow rate). Concentration limit = 50 mg/L of AFFF concentrate for 3% AFFF concentrate * 1.file:///J|/INITENG/P11%20cases/p110530.sr.txt [5/1/2013 1:59:04 PM] 2% PMN in concentrate = 0.6 mg/L. Frequency = 6.8 kg * 1000000 mg/Kg / (0.6 mg/L * 1000000 L/day) = 12 days.

Water or Incineration or Landfill High End: 6.8E-3 kg/site-day over 2 days/yr from 96 sites or 1.3E+0 kg/yr to: uncertain from: Cleaning Liquid Residuals from Tank Trucks Used to Transport the Raw Material basis: EPA/OPPT Bulk Transport Residual Model, CEB standard 0.2% residual.

RELEASE TOTAL 6.5E+2 kg/yr - all sites

C6F13 is 21.8% in PMN. // Perfluoro to WATER or INCINERATION or LAND from container cleaning to: uncertain : 2.E-3 kg/site-day over 2 days/yr for 96 sites or 0.3 kg/yr. // Perfluoro to WATER from Industrial and Military Testing, to: POTW with dilution : 0.9 kg/site-day over 2days/yr for 96 sites or 142 kg/yr.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 2,358 Basis: CEB ass esses the std default minimum of 3 workers/site.

Inhalation:

Exposure to Mist (non-volatile) (Class I) Output 1: 3.3E-2 mg/day over 1 days/yr Output 2: 1.7E+0 mg/day over 1 days/yr Number of workers (all sites) with inhalation exposure: Basis: System Testing; User-defined Inhalation Model. Per P01-0232 (MW = 316, 100% conc), exposure to foam is expected during training and use on actual fires. During fire fighting, exposures to the foam, its degradation products, and toxic fumes from the fire may be expected to be acute. Portable extinguishers -- 80 ppm outdoors, 1 minute to 900 ppm indoors, >7.5 minutes = 24 to 1,800 mg/episode. Total flooding systems -- 7,000 ppm, > 1 minute or up to 10,000 ppm, < 1 minute (assume| 30 seconds) = < 1,900 mg/episode. This IRER assesses a range of 80 ppm for 1 minute (portable fire| extinguisher) to 10,000 ppm for 30 seconds (flooding system). The PMN concentration in the final foam is approximately 0.05% (per 11/4/11 amendment); therefore the exposure is adjusted according to the concentration. NOTE: The respirator class is: I. Particulate (including solid or liquid droplets).

INHALATION MONITORING DATA REVIEW 1) Uncertainty (estimate based on model, regulatory limitfile:///J|/INITENG/P11%20cases/p110530.sr.txt [5/1/2013 1:59:04 PM] or data not specific to industry): Yes 2)a) Exposure level > 1 mg/day? Yes OR b) Hazard Rating for health of 2 or greater? 2 Yes Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal:

Exposure to Liquid at 1.20% concentration High End: 2.1E+1 mg/day over 1 days/yr Number of workers (all sites) with dermal exposure: 288 Basis: Unloading Liquid Raw Material from Tank Trucks; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT CBI: Yes PMN: 11-0530

Use 5: End of Life Disposal at Fire Departments (2.99% of Total PV)

Number of Sites/ Location: 1,484 Unknown sites; emergencies unplanned/random so releases likely occur at different sites each yr Days/yr: 3 Basis: The AFFF methodology (El-Zoobi and Avcin) estimates that the average amount of fluorinated surfactant used in fire department facilities = 1,360,000 gallons AFFF concentrate x density of AFFF concentrate x 1.06% average fluorinated surfactant in concentrate / 32, 000 fire departments. Calc: 1,360,000 gal/site-yr x 3.78 kg/gal x 1.06% / 32,000 fire departments = 1.7 kg PMN/site-day over 1 day/site. CEB assumes the PV for this use is the (Total PV - (PV from uses 1-4)) x 5% = 2,527 kg/yr. The number of sites = 2,527 kg/yr / 1.7 kg PMN/site-day = 1,484 sites. See Release Section for discussion of release days.

Process Description: AFFF solution (liquid, 1.2%) charged to fire fighting system and eventually removed from system because solution expires (per engineering judgement)

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 Output 2: 5.5E-1 kg/site-day over 3 days/yr from 1,484 sites to: CEB asssumes POTW (with dilution) from: Disposal of Expired AFFF Concentrate Containing the PMNfile:///J|/INITENG/P11%20cases/p110530.sr.txt [5/1/2013 1:59:04 PM] basis: User-Defined Loss Rate Model. There is a lag time between commencement of PMN use and commencement of releases that is equal to the PMN expiration time. The technical contact indicates that 95% of PMN is disposed to landill or incineration, and up to 5% to POTW (with dilution). For this operation CEB assumes that release from municipal fire departments may be sent to POTW (Use 6c estimates landfill or incineration releases). At an influent flow rate of 1 million liters per day, a single release would result in a concentration of 1.7 mg PMN-day/L [Calc = (1.7 kg) x (1E6 mg/kg) / (1E6 L/day). To obtain the required treatment rate of 0.60 mg PMN/L (Calc = 50 mg conc/L-day (for 3% AFFF concentrate) x 1.2% PMN), 3 days of release per year are required (Calc = 1.7 / 0.60).

Water or Incineration or Landfill High End: 1.7E-2 kg/site-day over 3 days/yr f rom 1,484 sites or 7.6E+1 kg/yr to: uncertain from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual.

RELEASE TOTAL 2.5E+3 kg/yr - all sites

C6F13 is 21.8% in PMN. // Perfluoro to WATER or AIR or INCINERATION or LAND from container cleaning to uncertain: 3.7E-3 kg/site-day over 3 days/yr for 1,484 sites or 17 kg/yr. // Perfluoro to WATER from discharge, to: POTW with dilution : 0.12 kg/site-day over 3 days/yr for 1,484 sites or 534 kg/yr.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 2,742 Basis: CEB assesses 3 workers/site.

Inhalation: negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 1.20% concentration High End: 2.1E+1 mg/day over 1 days/yr Number of workers (all sites) with dermal exposure: 4,452 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.file:///J|/INITENG/P11%20cases/p110530.sr.txt [5/1/2013 1:59:04 PM] INITIAL REVIEW ENGINEERING REPORT CBI: Yes PMN: 11-0530

Use 6a: Fire Fighting Conc for Deployment at Industrial Facilities (36.9% of Total PV)

Number of Sites/ Location: 62 unknown, different sites each yr; release from specific site once per period of expiration time. Days/yr: 1 Basis: The AFFF methodology (El-Zoobi and Avcin) estimates that the average amount of fluorinated surfactant used in commercial-industrial facilities = 1, 900,000 gallons AFFF concentrate x density of AFFF concentrate x 1.06 % average fluorinated surfactant in concentrate / 149 refineries. (1.06% is the average PMN concentration in AFFF concentration for P11-530, P11-533, P11-534, P11-484, and P11-487). Calc:1,900,000 gal/site-yr x 3.78 kg/gal x 1.06% / 149 refineries = 510. 93 kg/site-yr. // Amendment (11/28/2011) provided by Zofia Kosin estimated up to 65% of PV for industrial facilities. CEB assumed the PV for this use is (Total PV - PV from uses 1 through 5) x| 65% = 31,202 kg/yr // Number of sites = PV / M_avg_refinery. Calc = 31,202 / 510.93 kg/site-yr = 62 sites.

Process Description: AFFF solution (liquid, 1.2%) charged to fire fighting system and eventually removed from system because solution expires (per engineering judgement

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: 1.0E+0 kg/site-day over 1 day/yr from 62 sites or 6.2E+1 kg/yr to: uncertain from: Cleaning Liquid Residuals from Tank Trucks Used to Transport the Raw Material basis: EPA/OPPT Bulk Transport Residual Model, CEB standard 0.2% residual. Media of release for container cleaning is unknown. CEB assesses release to water, incineration or landfill.

Incineration or Landfill Output 2: 5.0E+2 kg/site-day over 1 day/yr from 62 sites or 3.1E+4 kg/yr to: CEB assume release to incineration or landfill from: Disposal of Expired AFFF Concentrate Containing the PMN basis: User-Defined Loss Rate Model. Accounting for container cleaning, LF = 1- 0.002 = 0.998. CEB assumesfile:///J|/INITENG/P11%20cases/p110530.sr.txt [5/1/2013 1:59:04 PM] release to incineration or landfill from industrial facilities. There is a lag time between commencement of PMN use and commencement of releases that is equal to the PMN expiration time.

RELEASE TOTAL 3.1E+4 kg/yr - all sites

C6F13 is 21.8% in PMN. // Perfluoro to WATER or AIR or INCINERATION or LAND from container cleaning to uncertain: 0.22 kg/site-day over 1 day/yr for 62 sites or 14 kg/yr. // Perfluoro to INCINERATION or LAND from discharge, to: incineration or land : 111.2 kg/site-day over 1 day/yr for 62 sites or 6,892 kg/yr.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 114 Basis: CEB assesses the std default minimum of 3 workers/site.

Inhalation: negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 1.20% concentration High End: 2.1E+1 mg/day over 1 days/yr Number of workers (all sites) with dermal exposure: 1 86 Basis: Unloading Liquid Raw Material from Tank Trucks; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT CBI: Yes PMN: 11-0530

Use 6b: Fire Fighting Conc for Deployment at Military Facilities (17.0% of Total PV)

Number of Sites/ Location: 18 unknown, different sites each yr; release from specific site once per period of expiration time. Days/yr: 1 Basis: The AFFF methodology (El-Zoobi and Avcin) estimates that the average amount of fluorinated surfactant used in military facilities = 2,836,500 gallons AFFF concentrate x density of AFFF concentrate x 1.06% average fluorinated surfactant in concentrate / 142 military facilities. (1.06% is the average PMN concentration in AFFF concentration for P11-530, P11-533, P11-534, P11-484, and P11-487). Calc: 2,836,500 gal/site-yr x 3.78 kg/gal x 1.06% / 142 military facilities = 800.37 kg/site-yr. // Amendment (11/28/2011)file:///J|/INITENG/P11%20cases/p110530.sr.txt [5/1/2013 1:59:04 PM] provided by Zofia Kosin estimated up to 30% of PV for military facilities. CEB assumes the PV for this operation is (Total PV - PV for uses 1 through 5) x 30% = 14,401 kg/yr. // Number of sites = PV / M_avg_military. Calc = (14,401kg/yr / 800.37 kg/site-yr = 18 sites.

Process Description: AFFF solution (liquid, 1.2%) charged to fire fighting system and eventually removed from system because solution expires (per engineering judgement

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: 1.6E+0 kg/site-day over 1 day/yr from 18 sites or 2.9E+1 kg/yr to: uncertain from: Cleaning Liquid Residuals from Tank Trucks Used to Transport the Raw Material basis: EPA/OPPT Bulk Transport Residual Model, CEB standard 0.2% residual. Media of release for container cleaning is unknown. CEB assesses release to water, incineration or landfill.

Incineration or Landfill Output 2: 8.0E+2 kg/site-day over 1 day /yr from 18 sites or 1.4E+4 kg/yr to: CEB assumes incineration or landfill from: Disposal of Expired AFFF Concentrate Containing the PMN basis: User-Defined Loss Rate Model. Disposal of Expired AFFF Concentrate Containing the PMN. CEB assesses 99.8% loss, accounting for container cleaning releases. LF= 1 - Container Cleaning = 1 -0.002 = 0.998. There is a lag time between commencement of PMN use and commencement of releases that is equal to the PMN expiration time. CEB assumes release to incineration or landfill.

RELEASE TOTAL 1.4E+4 kg/yr - all sites

| C6F13 is 21.8% in PMN. // Perfluoro to WATER or AIR or INCINERATION or LAND from container cleaning to uncertain: 0.35 kg/site-day over 1 day/yr for 18 sites or 6.3 kg/yr. // Perfluoro to INCINERATION or LAND from discharge, to: incineration or land : 174 kg/site-day over 1 day/yr for 18 sites or 3,134 kg/yr.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 36 Basis: CEB assesses the std default minimum of 3file:///J|/INITENG/P11%20cases/p110530.sr.txt [5/1/2013 1:59:04 PM] workers/site.

Inhalation: negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 1.20% concentration High End: 2.1E+1 mg/day over 1 days/yr Number of workers (all sites) with dermal exposure: 54 Basis: Unloading Liquid Raw Material from Tank Trucks; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT CBI: Yes PMN: 11-0530

Use 6c: Fire Fighting Conc for Deployment at Fire Departments (2.84% of Total PV)

Number of Sites/ Location: 1,410 unknown, different sites each yr; release from specific site once per period of expiration time. Days/yr: 1 Basis: The AFFF methodology (El-Zoobi and Avcin) estimates that the average amount of fluorinated surfactant used in fire department facilities = 1,360,000 gallons AFFF concentrate x density of AFFF concentrate x 1.06% average fluorinated surfactant in concentrate / 32, 000 fire departments. Calc: 1,360,000 gal/site-yr x 3.78 kg/gal x 1.06% / 32,000 fire departments = 1.75 kg/site-yr. (1.06% is the average PMN concentration in AFFF concentration for P11-530, P11-533, P11-534, P11-484, and P11-487). // Amendment (11/28/2011) provided by Zofia Kosin estimated up to 5% of PV for fire department facilities. CEB assumed the PV for this operation (Total PV - PV from uses 1 through 5) x 5% = 2,400 kg/yr. // Number of sites = PV / M_avg_fire_dep. Calc = 2,400/ 1.7 kg/site-yr = 1,410 sites.

Process Description: AFFF solution (liquid, 1.2%) charged to fire fighting system and eventually removed from system because solution expires (per engineering judgement

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: 5.1E-2 kg/site-day over 1 day/yr from 1,410 sites or 7.2E+1 kg/yrfile:///J|/INITENG/P11%20cases/p110530.sr.txt [5/1/2013 1:59:04 PM] to: uncertain from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. Media of release for container cleaning is unknown. CEB assesses release to water, incineration or landfill.

Incineration or Landfill Output 2: 1.7E+0 kg/site-day over 1 day/yr from 1,410 sites or 2.3E+3 kg/yr to: CEB assumes landfill or incineration from: Disposal of Expired AFFF Concentrate Containing the PMN basis: Disposal of Expired AFFF Concentrate Containing the PMN basis: User-Defined Loss Rate Model. Accounting for container cleaning, LF = 1- 0.03 = 0.97. CEB assumes release to landfill or incineration.

RELEASE TOTAL 2.4E+3 kg/yr - all sites

C6F13 is 21.8% in PMN. // Perfluoro to WATER or AIR or INCINERATION or LAND from container cleaning to uncertain: 0.011 kg/site-day over 1 day/yr for 1,410 sites or 16 kg/yr. // Perfluoro to INCINERATION or LAND from discharge, to: incineration or land : 0.36 kg/site-day over 1 day/yr for 1,410 sites or 508 kg/yr.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 2,721 Basis: CEB assesses the std default minimum of 3 workers/site.

Inhalation: negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 1.20% concentration High End: 2.1E+1 mg/day over 1 days/yr Number of workers (all sites) with dermal exposure: 4,230 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

CBI: Yesfile:///J|/INITENG/P11%20cases/p110530.sr.txt [5/1/2013 1:59:04 PM] MEMORANDUM of CBI TELEPHONE CONVERSATION

CALL BY: Ariel Hou Organization: ERG for CEB

CALL TO: Thomas J. Martin

Organization: Chemguard, Inc.

Date: 08/03/2011

Time: 12:00pm

Phone: 817-473-1036

Concerning what TSCA CBI?

PMN: 11-0530

The following contact report applies to P11-0527 - 0530 and 0532. Submitter called back at 2:30pm to answer questions. Q1: Submission lists 10 sites. Does the operation occur at all sites at once or just one of the 10 sites (similar to previous submission, P11-0483)?| A1: Most of the processing will be done at Chemdesign. The others are just possible manufacturing sites, but it's unlikely that we will manufacture there. | | Q2: What happens to the storage drums? Is the drum cleaned on a regular basis? A2: We typically have dedicated drums or totes and they are re-used each time as needed. At end of useful life, there is a contractor that conditions and disposes of the drum.