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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: P1B1T2
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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% concentration.

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: 
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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 REPORT 
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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 TOTAL
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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 Data 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? Yes
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 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: 09-0038
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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