file:///J|/SNURS/SNUR%20Batch%20FY10-3/sanitized%20report/sanitized%20engineering%20reports/p090038.sanitized.en2.txt [5/11/2010 1:13:24 PM] INITIAL REVIEW ENGINEERING REPORT PMN: 09-0038 Post-Focus Draft Revision 2 2/11/2009 ENGINEER: Macek \ AG PV (kg/yr): Revision Notes / Assessment Overview: The previous version of the engineering report (Post-Focus Draft Revision 1, dated 1/29/09) has been revised to incorporate additional clarifying information provided by the submitter (See phone log dated 2/10/09). The processing scenario, depicted in previous versions of the engineering report, has been removed. SUBMITTER: Incorez Corporation
USE:
OTHER USES: MSDS: Yes Label: No Gen Eqpt: protective gloves (butyl rubber, nitrile, rubber, neoprene or PVC, or viton rubber (fluor rubber)) / safety goggles or face shield / appropriate clothing to prevent skin contact / adequate ventilation Respirator: suitable respiratory equipment with combination filter (type A2/P2) Health Effects: Inhalation may cause damage to mucous membranes in nose, throat, and bronchial system / Ingestion may cause burns in mucous membranes, throat, oesophagus and stomach / Skin contact may cause serious chemical burns of the skin; may cause sensitization by skin contact / Eye contact may cause chemical eye burns TLV/PEL: Not Provided

CRSS : Chemical Name: S-H20: g/L @ VP: 1.5E-3 torr @ MW: 250.00 %<500 %<1000 Physical State and Misc CRSS Info:

Consumer Use: No SAT (concerns) (11/07/2008): Migration to groundwater: Negligible PBT rating: P1B1T2file:///J|/SNURS/SNUR%20Batch%20FY10-3/sanitized%20report/sanitized%20engineering%20reports/p090038.sanitized.en2.txt [5/11/2010 1:13:24 PM] Health: 2 Dermal, Inhalation Eco: 3 Water (All releases to water with a CC = 1 ppb)
OCCUPATIONAL EXPOSURE RATING: 2-3B
NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER. POLLUTION PREVENTION CONSIDERATIONS: None.

EXPOSURE-BASED REVIEW: No

INITIAL REVIEW ENGINEERING REPORT PMN: 09-0038 Manufacturing: Number of Sites/ Location: 1 Incorez Corporation Middletown CT 06457 Days/yr: 10 Basis: Submission provides max PV of kg/yr, 1 MFG site, kg/site-bt, 8 hr/bt, and 5 bt/year. To match max PV, CEB scales up to 10 bt/year using kg/site-bt. PMN is 100% concen tration. Process Description:
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 Typical: 2.0E-5 kg/site-day over 10 days/yr from 1 site Worst Case: 4.0E-5 kg/site-day over 10 days/yr from 1 site to: Air from: basis:
Air Output 2: 2.5E-4 kg/site-day over 10 days/yr from 1 site to: Air from: basis:
Incineration Conservative: 2.0E+1 kg/site-day over 10 days/yr from 1 site or 2.0E+2 kg/yr to: Incineration from: basis:file:///J|/SNURS/SNUR%20Batch%20FY10-3/sanitized%20report/sanitized%20engineering%20reports/p090038.sanitized.en2.txt [5/11/2010 1:13:24 PM] RELEASE TOTAL 2.0E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 3 Basis: Submission indicates 2 workers exposed. CEB assesses 3 workers/site exposed as minimum default. Inhalation: Exposure to Vapor (Class II) Typical: 9.6E-3 mg/day over 10 days/yr Worst Case: 5.8E-1 mg/day over 10 days/yr Number of workers (all sites) with inhalation exposure: 3 Basis: 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? Yes (both criteria met) Exposure to Vapor (Class II) Typical: 1.5E-3 mg/day over 10 days/yr Worst Case: 1.3E-2 mg/day over 10 days/yr Number of workers (all sites) with inhalation exposure: 3 Basis: 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? Yes (both criteria met) Dermal: Exposure to Liquid at 100.00% concentration High End: 1.8E+3 mg/day over 10 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 REPORTfile:///J|/SNURS/SNUR%20Batch%20FY10-3/sanitized%20report/sanitized%20engineering%20reports/p090038.sanitized.en2.txt [5/11/2010 1:13:24 PM] PMN: 09-0038
Use: Number of Sites/ Location: 200 Unknown Sites Days/yr: 2 Basis: Process Description: The containing the PMN chemical is used in . The submitter indicated that application will be by (CEB assumes
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 Typical: 2.5E-6 kg/site-day over 2 days/yr from 200 sites Worst Case: 2.5E-6 kg/site-day over 2 days/yr from 200 sites to: from: basis:
Air Output 2: 2.7E-6 kg/site-day over 2 days/yr from 200 sites to: from: basis:
Air Output 2: 9.9E-4 kg/site-day over 2 days/yr from 200 sites to: from: basis:
Landfill High End: 3.0E-1 kg/site-day over 2 days/yr from 200 sites or 1.2E+2 kg/yr to: from: basis:
Landfill Conservative: 1.0E+0 kg/site-day over 2 days/yr from 200 sites or 4.0E+2 kg/yr to: Landfill from: basis:
RELEASE TOTALfile:///J|/SNURS/SNUR%20Batch%20FY10-3/sanitized%20report/sanitized%20engineering%20reports/p090038.sanitized.en2.txt [5/11/2010 1:13:24 PM] 5.2E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 20 Basis: Inhalation: Exposure to Vapor (Class II) Typical: 1.2E-3 mg/day over 40 days/yr Worst Case: 3.6E-2 mg/day over 40 days/yr Number of workers (all sites) with inhalation exposure: 20 Basis: 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 Dat a Desired? Yes (both criteria met) Exposure to Vapor (Class II) Typical: 1.3E-3 mg/day over 40 days/yr Worst Case: 3.8E-2 mg/day over 40 days/yr Number of workers (all sites) with inhalation exposure: 20 Basis: 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? Yes (both criteria met) Exposure to Particulate (Class I) Upper Bound: 6.0E+1 mg/day over 40 days/yr Number of workers (all sites) with inhalation exposure: 20 Basis: 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? Yesfile:///J|/SNURS/SNUR%20Batch%20FY10-3/sanitized%20report/sanitized%20engineering%20reports/p090038.sanitized.en2.txt [5/11/2010 1:13:24 PM] 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 40.00% concentration High End: 7.1E+2 mg/day over 40 days/yr Number of workers (all sites) with dermal exposure: 20 Basis: Unloading Liquid Raw Material from Containers; EPA/OPPT 2-Hand Dermal Contact with Liquids Model. Exposure to Liquid at 40.00% concentration High End: 7.1E+2 mg/day over 40 days/yr Number of workers (all sites) with dermal exposure: 20 Basis: Cleaning Liquid Residuals from Containers Used to Transport the Raw Material; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

MEMORANDUM of CBI TELEPHONE CONVERSATION CALL BY: Greg Macek Organization: USEPA/OPPT/EETD/CEB CALL TO: Kris Evanoff; Dr. Neil Carter Organization: Incorez Corporation
Date: 12/23/2008 Time: Phone: Concerning what TSCA CBI? PMN: 09-0038file:///J|/SNURS/SNUR%20Batch%20FY10-3/sanitized%20report/sanitized%20engineering%20reports/p090038.sanitized.en2.txt [5/11/2010 1:13:24 PM] MEMORANDUM of CBI TELEPHONE CONVERSATION CALL BY: Dr. Neil Carter Organization: Incorez CALL TO: Greg Macek Organization: USEPA/OPPT/EETD/CEB Date: 02/10/2009 Time: 11:00 am Phone: Concerning what TSCA CBI? PMN: 09-0038