p120041.en1

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0041

Post-Focus Draft Revision 1 9/7/2012

ENGINEER: Austin \ CLM

PV (kg/yr): 100,000 Import Only YX

SUBMITTER: Zydex Industries

USE: Waterproofing inorganic substrates (10%), asphalt

binder modifier (45%) and water proofing soil (45%).

P2REC: CRSS: Forward. P2 Claim: The PMN material will

replace P-08-141. The PMN material contains

ethoxysilanes instead of methoxysilanes and, upon use,

releases ethanol instead of methanol. Analogs P-08-0141

and P-08-140 are used as waterproofing agents for

cementitious building materials, for surface modification

of the gravel used for asphalt road paving and for

surface modification of soil, fly-ash, etc.

OTHER USES: No other uses were found.

MSDS: Yes Label: No

Gen Eqpt: Use explosion-proof ventilation equipment.

Facilities| storing or utilizing this material should be

equipped with an eyewash facility and a| safety shower.

Use adequate general or local exhaust ventilation to keep

airborne| concentrations below the permissible exposure

limits. OSHA Vacated PELs: Ethylene Glycol: 1000 ppm TWA;

1900 mg/m3 TWA // Wear appropriate protective eyeglasses

or chemical safety goggles as described by OSHA's eye and

face protection regulations in 29 CFR 1910.133 or

European Standard EN166. // Wear appropriate protective

gloves to prevent skin exposure. // Wear appropriate

protective clothing to prevent skin exposure.

Respirator: A respiratory protection program that meets

OSHA's 29 CFR 1910.134 and ANSI Z88.2 requirements or

European Standard EN 149 must be followed whenever

workplace conditions| warrant a respirator's use.

Health Effects: Eye : May cause irritation| Skin : May

cause irritation| Injection : May cause gastrointestinal

discomfort| Inhalation : May cause irritation to

respiratory tract // The product contains Ethylene glycol

as solvent. Ethylene glycol ACGIH TLV: TWA 1000 ppm; OSHA

PEL: TWA 1000 ppm. Liquid and high vapor concentrations

cause eye irritation. Contact with skin cause drying,

cracking and irritation. Inhalation causes irritation of

the respiratory tracks. Repeated or prolong exposure to

high vapor concentrations may cause drowsiness. Excessive

or repeated injection may cause central nervous system

effects, liver effects and reproductive effects.

TLV/PEL:

Ethylene Glycol 1000 ppm TWA; 1900 mg/m3 TWA

 

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silane quats upon reaction with substrate generates

methanol as byproduct. This replacement with ethoxy

silane quats generate ethanol. Methanol is lower boiling

and more toxic than ethanol. This replacement will make

product handling safer. The product also replaces solvent

based silanes used for similar applications. The solvent

based silane typically comes with 40-80 % solvent such as

methanol, ethanol and hydrocarbon solvents. These

products are used as supplied. Therefore the VOC is per

Kg of the product 400-800 g. The PMN substance is also

contains solvent (600g per Kg). However it is diluted

with water minimium 10 folds for some applications. The

performance of diluted PMN substance is very similer.

However PMN substance coverage is 10 fold more per unit

weight than conventional solvent based products. As a

result the PMN substance VOC per application is 6-12 fold

lower than solvent based systems. P2REC: CRSS: Forward.

EXPOSURE-BASED REVIEW: Yes (1 criteria met)

1) # of workers exposed: 300 >1000? No

2) >100 workers with >10 mg/day inhalation exposure: No

3) (a) >100 workers w/1-10 mg/day inh. exp. & >100

days/yr: Yes

 (b) Routine Dermal Cont: >250 workers & >100 days/yr:

Yes

INITIAL REVIEW ENGINEERING REPORT CBI: Yes

PMN: 12-0041

Use 1: Inorganic substrate and soil waterproofing (45% of

PV)

Number of Sites/ Location: 10

unknown sites

Days/yr: 100

Basis: Submission estimates a total of 100 sites for all

end uses. For this use of 55% of the PV, CEB estimates 55

use sites. Submission estimates 200 days/yr operation.

CEB calculates 5 kg/site-day use rate of PMN (12.5

kg/site-day use rate of 40% solution as imported; 125

kg/site-day use rate of 4% formulated product).

Submitter amendment of 10 customer sites, 100 opearting

days.

Process Description: [Note, 4.5% of this Use 1 portion of

the PV may be consumer use; as conservative, CEB assesses

this entire portion of the PV as potiential non-consumer

use] PMN in solution of ethylene glycol (liquid, 40%)

imported in 1-kg, 20-kg, or 1000-kg containers -->

Shipped via distributor to customer site --> Dilution

with water to 0.4-4% PMN solution --> Solution (liquid, 0.

4-4% PMN) sprayed on substrates such as soil, concrete,

bricks, stone, granite etc. --> PMN reacts with the

substrate surface; upon evaporation of water and solvent,

the hydrophilic surafce becomes hydrophobic (PMN

destroyed). (Submission, 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. Note, submission estimates 0.05

kg/day release from unspecified source/activity; this

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amount is less than the releases assessed per CEB

standard models.

Water

High End: 8.0E-1 kg/site-day over 11 days/yr from 10 sites

to:

from: Cleaning Liquid Residuals from Containers Used to

Transport the Raw Material

basis: EPA/OPPT Bulk Transport Residual Model, CEB

standard 0.2% residual.

Water or Incineration or Landfill

High End: 9.0E-2 kg/site-day over 10 days/yr from 10 sites

or 9.0E+0 kg/yr

to: uncertain

from: Equipment Cleaning Losses of Liquids from a Single,

Large Vessel

basis: EPA/OPPT Single Vessel Residual Model, CEB

standard 1% residual. 09/07/12 discussions with

following amendment - gravity drained tank. cleaned

every 10 days.

Air

Output 2: 3.4E+1 kg/site-day over 100 days/yr from 10

sites

to: air

from: Coating Using Hand-Held Spray Gun

basis: EPA/OPPT Automobile Refinish Coating Overspray

Loss Model (non-volatiles). CEB assumes no control

technology, as the waterproofing application is expected

to occur outdoors in the open air, based on the operation

description. Per submission, 2750 kg formulation can

waterproof 110,000 square feet of horizontal surface;

5250 kg formulation can waterproof 220,000 square feet of

horizontal surface; 25250 kg formulation can waterproof

up to 200 tons of soil. Note, the default spray gun

transfer efficiency for this CEB model is 25%, resulting

in 75% release to air; based on engineering judgment,

this may be an under-estimate of realistic transfer

efficiency--especially considering that particulate in

the air would be expected to ultimately deposit on the

ground (i.e., potentially the originally targeted

horizontal substrate or soil).

RELEASE TOTAL

3.4E+4 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 330

Basis: Submission estimates 2 workers/site. CEB

conservatively assesses default minimum 3 workers/site,

and assesses exposure to all physical forms of the LVE

that are present during the operation.

Inhalation:

Exposure to Particulate (Class I)

Upper Bound: 6.0E+0 mg/day over 100 days/yr

Number of workers (all sites) with inhalation exposure: 30

Basis: Coating Using Hand-Held Spray Gun; OSHA PNOR

PEL-Limiting Model.

NOTE: The respirator class is: I. Particulate (including

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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? 1-2 No

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Exposure to Liquid at 40.00% concentration

High End: 7.1E+2 mg/day over 100 days/yr

Number of workers (all sites) with dermal exposure: 30

Basis: Unloading Liquid Raw Material from Containers;

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

Exposure to Liquid at 4.00% concentration

High End: 3.5E+2 mg/day over 100 days/yr

Number of workers (all sites) with dermal exposure: 30

Basis: Coating Using Hand-Held Spray Gun; EPA/OPPT 2-Hand

Dermal Immersion in Liquid Model.

INITIAL REVIEW ENGINEERING REPORT CBI: Yes

PMN: 12-0041

Use 2: Asphalt binder modifier (45% of PV)

Number of Sites/ Location: 20

unknown sites

Days/yr: 75

Basis: Submission estimates a total of 100 sites for all

end uses. For this use of 45% of the PV, CEB estimates 45

use sites. Submission estimates 200 days/yr operation.

CEB calculates 5 kg/site-day use rate of PMN (12.5

kg/site-day use rate of 40% solution as imported).

Submitter amendment states 20 customers, 75 days per year.

Process Description: PMN in solution of ethylene glycol

(liquid, 40%) imported in 20-kg or 1000-kg containers -->

Shipped via distributor to customer site (asphalt

refinery/concrete plant) --> Solution of the PMN

substance is mixed in melted asphalt at the refinary or

terminal using metering pump that is attached directly to

the one ton or larger container. Similarly, at an asphalt

concrete drum plant, the solution is injected using a

metering pump into melted asphalt just before asphalt is

mixed with hot aggregates. In some case, the PMN

substance solution is mixed with asphalt binder in a

storage tank using metering pump. --> PMN destroyed.

(Submission, 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. Note, submission estimates 0.01

kg/day release from unspecified source/activity; this

amount is less than the releases assessed per CEB

standard models.

Water

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High End: 8.0E-1 kg/site-day over 6 days/yr from 20 sites

to:

from: Cleaning Liquid Residuals from Containers Used to

Transport the Raw Material

basis: EPA/OPPT Bulk Transport Residual Model, CEB

standard 0.2% residual.

Water

High End: 6.0E-2 kg/site-day over 1 day/yr from 20 sites

to:

from: Equipment Cleaning Losses of Liquids from a Single,

Large Vessel

basis: EPA/OPPT Single Vessel Residual Model, CEB

standard 1% residual. Assume gravity drained. Single

vessel. Cleaned at end of season - once per year.

RELEASE TOTAL

9.7E+1 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 60

Basis:

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 40.00% concentration

High End: 7.1E+2 mg/day over 75 days/yr

Number of workers (all sites) with dermal exposure: 60

Basis: Unloading Liquid Raw Material from Containers;

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

INITIAL REVIEW ENGINEERING REPORT CBI: Yes

PMN: 12-0041

Use 3: Waterproofing of the Building materials (10% of

PV)

Number of Sites/ Location: 20

Days/yr: 200

Basis: No description provided. Used the same weight

fraction as other applications. also assume pails as

material amount is low.

Process Description: Waterproofing of concrete material -

- received at 40%, diluted to 4% and applied to concrete

material via spray.

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

High End: 8.0E-2 kg/site-day over 12 days/yr from 20 sites

to:

from: Cleaning Liquid Residuals from Small Containers

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Used to Transport the Raw Material

basis: EPA/OPPT Bulk Transport Residual Model, CEB

standard 0.2% residual.

Water

High End: 5.0E-3 kg/site-day over 20 days/yr from 20 sites

to:

from: Equipment Cleaning Losses of Liquids from a Single,

Large Vessel

basis: EPA/OPPT Single Vessel Residual Model, CEB

standard 1% residual. Assumed gravity drained. Every 10

days.

RELEASE TOTAL

2.1E+1 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 40

Basis:

Inhalation:

Dermal:

Exposure to Liquid at 4.00% concentration

High End: 7.1E+1 mg/day over 200 days/yr

Number of workers (all sites) with dermal exposure: 20

Basis: Unloading Liquid Raw Material from Small

Containers; EPA/OPPT 2-Hand Dermal Contact with Liquids

Model.

Exposure to Liquid at 4.00% concentration

High End: 7.1E+1 mg/day over 200 days/yr

Number of workers (all sites) with dermal exposure: 20

Basis: Cleaning Liquid Residuals from Small Containers

Used to Transport the Raw Material; EPA/OPPT 2-Hand

Dermal Contact with Liquids Model.

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