INITIAL REVIEW ENGINEERING REPORT

PMN: 15-0176 

Post-Focus Draft Revision 1 4/29/2015

PV (kg/yr): 7,000 Import Only

ENGINEER: Macek \ DDB 

Revision Notes / Assessment Overview: The 3/16/2015 amendment indicated 

that all production process wastes are sent to off-site incineration. 

Specifically, the amendment stated that (1) all process wastes from the 

Salisbury plant are sent to VLS Recovery Services, 305 South Main St., 

Mauldin, SC 29662 (864-962-9953), and (2) all process wastes from the 

Rocky Hill plant are sent to Nexeo Solutions, 5200 Blazer Parkway, 

Dublin, OH 43017 (508-847-2242).

SUBMITTER: Henkel Corporation 

USE: Chemical intermediate to prepare a benzophenone-based acrylate 

monomer. Synthetic sequence: P-15-176 -> P-15-128. STN CA 121:134981 

describes the preparation of a methacrylate monomer.

OTHER USES: STN CA 

148:527636: corrosion inhibitor for photoresists; Analogs , 

: fragrance chemical; Analogs : chemical 

intermediate for polysulfide polymers; STN CA 146:18683, 142:417751: 

material for functionalized gold nanoparticles.

MSDS: No Label: No

TLV/PEL:

 

 

 

 

 

 

Consumer Use: No 

SAT (concerns) (01/21/2015):

Related Cases and Misc SAT Info: 
Migration to groundwater: Negligible to slow 

PBT rating: P1B1T2 

Health: 2 Dermal, Drinking Water, Inhalation 

Eco: 3 Water (All releases to water with a CC = 8 ppb) 

OCCUPATIONAL EXPOSURE RATING: 2B

NOTES & KEY ASSUMPTIONS: 

Generated by the 09/30/2013 version of ChemSTEER. 

POLLUTION PREVENTION CONSIDERATIONS:

None.

EXPOSURE-BASED REVIEW: No 
INITIAL REVIEW ENGINEERING REPORT

PMN: 15-0176 

Use: Chemical intermediate to a curable monomer

Henkel Salisbury Sailsbury NC 28147

Henkel Rocky Hill CT 06067

Number of Sites/ Location: 2 

Days/yr: 17

Basis: Submission indicates 2 operation sites, 3,000 kg/batch, 4 

batches/site-yr, and 100% PMN in raw material. CS calculates 875 

kg/site-batch.

Process Description: PMN and other reagents charged to mixing vessel 

(liquid, 100%) --> PMN destroyed (per submission)

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. Submission 

claims no releases during this operation. CEB assesses releases to water 

(per SAT), air, incineration and landfill for conservative estimates.
Air

Output 2: 1.9E-3 kg/site-day over 4 days/yr from 2 sites

or 7.6E-3 kg/site-yr from 2 sites or 1.5E-2 kg/yr-all sites

to: Air (per model)

from: Equipment Cleaning Losses of Liquids from a Single, Large Vessel

basis: EPA/OPPT Mass Transfer Coefficient Model.

Air

Typical: 5.7E-5 kg/site-day over 4 days/yr from 2 sites

or 2.3E-4 kg/site-yr from 2 sites or 4.5E-4 kg/yr-all sites

Worst Case: 1.1E-4 kg/site-day over 4 days/yr from 2 sites

or 4.5E-4 kg/site-yr from 2 sites or 9.1E-4 kg/yr-all sites

to: Air (per model)

from: Unloading Liquid Raw Material from Drums

basis: EPA/OAQPS AP-42 Loading Model.

Air

Output 2: 2.1E-6 kg/site-day over 4 days/yr from 2 sites

or 8.2E-6 kg/site-yr from 2 sites or 1.6E-5 kg/yr-all sites

to: Air (per model)

from: Cleaning Liquid Residuals from Drums Used to Transport the Raw 

Material

basis: EPA/OPPT Penetration Model.

Incineration

Conservative: 8.8E-2 kg/site-day over 4 days/yr from 2 sites

or 3.5E-1 kg/site-yr from 2 sites or 7.0E-1 kg/yr-all sites

to: Incineration (per 3/16/2015 amendment)

from: Equipment Cleaning Losses of Liquids from a Single, Large Vessel

basis: EPA/OPPT Single Vessel Residual Model, CEB standard 1% residual. 

CEB assumes minimum defalut of 99% reacted to estimate potential 

releases. Per 3/26/2015 Amendment, all waste from production processes 

is sent to off-site incineration.

Incineration

High End: 2.6E+1 kg/site-day over 4 days/yr from 2 sites

or 1.0E+2 kg/site-yr from 2 sites or 2.1E+2 kg/yr-all sites

to: Incineration (per 3/16/2015 amendment)

from: Cleaning Liquid Residuals from Drums Used to Transport the Raw 

Material

basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. Per the 

3/16/2015 amendment, all waste from production processes is sent to 

off-site incineration.

RELEASE TOTAL
2.1E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 30

Basis: 
Inhalation:

Exposure to Vapor (volatile) (Class II)

Typical:

> Potential Dose Rate: 2.7E-2 mg/day over 4 days/yr

> Lifetime Average Daily Dose: 2.4E-6 mg/kg-day over 4 days/yr

> Average Daily Dose: 4.3E-6 mg/day over 4 days/yr

> Acute Potential Dose: 3.9E-4 mg/day over 4 days/yr

Worst Case:

> Potential Dose Rate: 1.6E+0 mg/day over 4 days/yr

> Lifetime Average Daily Dose: 1.5E-4 mg/kg-day over 4 days/yr

> Average Daily Dose: 2.6E-4 mg/day over 4 days/yr

> Acute Potential Dose: 2.3E-2 mg/day over 4 days/yr

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

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT Mass Balance 

Model.

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? Yes

 OR 

 b) Hazard Rating for health of 2 or greater? 2 Yes

=> Inhalation Monitoring Data Desired? No

Dermal:

Exposure to Liquid at 100.00% concentration

High End:

> Potential Dose Rate: 2.2E+3 mg/day over 4 days/yr

> Lifetime Average Daily Dose: 2.0E-1 mg/day over 4 days/yr

> Average Daily Dose: 3.5E-1 mg/day over 4 days/yr

> Acute Potential Dose: 3.2E+1 mg/day over 4 days/yr

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

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal 

Contact with Liquids Model.
CALL BY: 

CALL TO: 

Organization: 

Date: 

Time: 

PMN: 15-0176 

Organization: 

Phone: 

Concerning what?

CBI: No

MEMORANDUM of TELEPHONE CONVERSATION (Contains No TSCA CBI)