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

Page 1p120041.en1 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 Page 3p120041.en1 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 Page 4p120041.en1 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 Page 5p120041.en1 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 Page 6p120041.en1 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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