p090636.eng.txt

INITIAL REVIEW ENGINEERING REPORT PMN: 09-0636 Focus Ready Draft 10/19/2009

ENGINEER: Avcin \ DGR PV (kg/yr): 107,800 YX

SUBMITTER: FUJIFILM Hunt Chemicals USA, Inc.

USE: Chemical intermediate

OTHER USES:

MSDS: No Label: No

TLV/PEL:

CRSS : Chemical Name: Benzenamine, 5-(1, 1-dimethylethyl)-2-[(2-ethylhexyl)thio]-, 4-methylbenzenesulfonate (1:1) S-H20: 0.0004 g/L @ VP: 1.0E-6 torr @ MW: 465.00 %<500 %<1000 Physical State and Misc CRSS Info: Neat: Solid Mfg: Solid (wet cake) Proc/Form: NA End Use: Destroyed. Submitted data: Solid, mp 180 °C, insoluble in water, solubility 100 g/L in toluene at 50 °C. Estimated data: The PMN material is a tosylate salt of an amine and is not amenable to estimation using either EPISuite or ACDLabs. PChem properties for the free amine and free acid are as follows: Amine: bp 170-174 °C/1.5 torr (measured, ), vp 2.9E-05 torr (NOMO5), water sol. 0.037 mg/L (EPI, mp entered as 20 °C), LogP 6.95 (EPI). pTSA: mp 104.5 °C (measured), bp 140 °C/20 torr (measured), vp 2.9E-06 torr (EPI), water sol. 602 g/L (measured), LogP -0.62 (EPI). Measured data for pTSA are from Physprop. The water solubility for the PMN material is estimated to be 0.4 mg/L based on the estimate for the free amine and an observed 10-fold increase in water sol. for various benzenesulfonic acid salts of aniline derivatives: o-toluidine 16.9 g/L, salt 200 g/L; p-toluidine 6.5 g/L, salt 74 g/L; 2,4,5-trimethylaniline 1. 2 g/L; salt 20.3 g/L; 2-naphthylamine 0.19 g/L, salt 5.9 g/L. All data are from water sol database (salts) and/or physprop.

Consumer Use: No

SAT (concerns) (10/02/2009): Related Cases and Related Cases and Misc SAT Info:

Migration to groundwater: Anion rapid; Cation negl PBT rating: P2B3T2 Anion: P1B1T1; Cation: P2B3T2 Health: 1-2 Dermal, Drinking Water, Inhalation, XB Testing (Testing desired) Eco: 3 Water (All releases to water with a CC = 1 ppb), XB Page 1p090636.eng.txt Testing (Testing desired)

OCCUPATIONAL EXPOSURE RATING: 2-3B

NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER. The technical contact was called with questions, see contact report for details. This PMN has a high PB rating (P2B3 for cation), all release media and exposures were considered. Per submission/technical contact, all waste expected to go to off-site incineration. CEB also assessed release to water/incineration/landfill for container residue due to unknown drum reconditioner operations, and release to air due to unknown air pollution control for dust. Inhalation exposures to particulate and dermal exposures to solids assessed. Exposure-based criteria evaluated below. There was no MSDS in the submission (none shown on list of attachments).

POLLUTION PREVENTION CONSIDERATIONS: None provided.

EXPOSURE-BASED REVIEW: Yes (0 criteria met)

1) # of workers exposed: 24 >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: No (b) Routine Dermal Cont: >250 workers & >100 days/yr: No

INITIAL REVIEW ENGINEERING REPORT PMN: 09-0636

Manufacturing: Batch Production

Number of Sites/ Location: 1 FUJIFILM Hunt Chemicals USA, Inc. Dayton TN 37321 Days/yr: 77 Basis: Submission estimates 1 site, 1,400 kg/bt, 24 hr/bt, 80 bt/yr, 95% PMN in product. ChemSTEER calculates 77 bt/yr for mass balance.

Process Description: Starting materials charged to reactor -> PMN formed (liquid) -> Seed crystals added -> Crystallization -> PMN slurry transferred to second tank for cooling (hard-piped) -> Centrifuge -> PMN transferred to plastic drums (wet cake, Page 2p090636.eng.txt 95%). (Submission, technical contact)

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 - not expected per submission/technical contact. Incineration - all process wastes to off-site incineration (RCRA incinerator or kiln, 99.99% eff.) per submission/technical contact. Landfill - not expected per submission/technical contact. Air - assessed per EPA/OPPT Dust Model.

Air or Incineration Output 2: 7.0E+0 kg/site-day over 77 days/yr from 1 site or 5.4E+2 kg/yr to: Air or off-site incineration from: Loading Solid Product into Transport Containers basis: User-Defined Loss Rate Model. EPA/OPPT Dust Emissions from Transferring Solids Model (revised Nov 2006) estimates 0.5% of the quantity transferred is released to water, incineration, land or air. Technical contact indicates all waste from the process is sent to off-site incineration (RCRA incinerator or kiln, 99.99% eff.). CEB assesses release to air or incineration (i.e., if PMN dust is captured it will be sent to incineration). Note dust release may be mitigated by transfer as wet centrifuge cake rather than as a dry solid.

Incineration Conservative: 2.8E+1 kg/site-day over 77 days/yr from 1 site or 2.2E+3 kg/yr to: Off-site incineration (technical contact) from: Equipment Cleaning Losses of Liquids from Multiple Vessels basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual. Multiple vessels containing PMN: Reactor D, Reactor F, Centrifuge. Technical contact indicates all waste from the process is sent to off-site incineration (RCRA incinerator or kiln, 99.99% eff.).

Incineration Output 2: 7.2E+1 kg/site-day over 77 days/yr from 1 site or 5.5E+3 kg/yr to: Off-site incineration (Submission) from: Centrifuge Mother Liquor Discharge basis: User-Defined Loss Rate Model. Submission estimates 72 kg/bt (~5%) released from spent mother liquor to off-site incineration (RCRA incinerator or kiln, 99.99% eff.).

RELEASE TOTAL 8.2E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 12 Basis: Submission estimates 12 workers exposed to wet solid that is 95% PMN.

Inhalation: Potential inhalation exposure assessed due to chance of airborn PMN (submission indicates that air purifying respirator is called for)

Exposure to Particulate (Class I) Upper Bound: 1.4E+2 mg/day over 77 days/yr Number of workers (all sites) with inhalation exposure: 12 Page 3p090636.eng.txt Basis: Loading Solid Product into Transport Containers; OSHA PNOR PEL-Limiting Model. 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

OR b) Hazard Rating for health of 2 or greater? 1-2 No Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal:

Exposure to Solid at 95.00% concentration High End: 2.9E+3 mg/day over 77 days/yr Number of workers (all sites) with dermal exposure: 12 Basis: Loading Solid Product into Transport Containers; EPA/OPPT Direct 2-Hand Dermal Contact with Solids Model.

INITIAL REVIEW ENGINEERING REPORT PMN: 09-0636

Use: Intermediate for

Number of Sites/ Location: 1 FUJIFILM Hunt Chemicals USA, Inc. Dayton TN 37321 Days/yr: 77 Basis: Submission indicates 1 Use batch per Mfg batch, 1 site, 1, 400 kg/bt, 24 hr/bt, 80 bt/yr, 95% PMN in raw material. ChemSTEER calculates 77 bt/yr for mass balance.

Process Description: PMN in plastic drums (wet solid, 95%) -> PMN and other materials charged to reactor -> PMN reacted to form (PMN destroyed). (Submission, technical contact, 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. Water - not expected per submission/technical contact, but assessed for container residue due to uncertainty. Incineration - all process wastes to off-site incineration (RCRA incinerator or kiln, 99.99% eff.) per submission/technical contact. Landfill - not expected per submission/technical contact, but assessed for container residue due to uncertainty (note drinking water concern, non-negligible migration for anion). Air - assessed per EPA/OPPT Dust Model.

Water or Incineration or Landfill Output 2: 1.4E+1 kg/site-day over 77 days/yr from 1 site or 1.1E+3 kg/yr to: Uncertain from: Cleaning Solid/ Powder Residuals from Containers Used to Transport the Raw Material basis: EPA/OPPT Solid Residuals in Transport Containers Model, CEB standard 1% residual. Technical contact indicates wet solid PMN stored in plastic drums, which could be reused in the process and are sent to a drum reconditioner at end of life. CEB assesses release to water, incineration, or landfill based on uncertainty (drum| reconditioner operations unknown).

Page 4p090636.eng.txt Air or Incineration Output 2: 7.0E+0 kg/site-day over 77 days/yr from 1 site or 5.4E+2 kg/yr to: Air or off-site incineration from: Unloading Solid Raw Material from Transport Containers basis: User-Defined Loss Rate Model. EPA/OPPT Dust Emissions from Transferring Solids Model (revised Nov 2006) estimates 0.5% of the quantity transferred is released to water, incineration, land or air. Technical contact indicates all waste from the process is sent to off-site incineration (RCRA incinerator or kiln, 99.99% eff.). CEB assesses release to air or incineration (i.e., if PMN dust is captured it will be sent to incineration). Note dust release may be mitigated by transfer as wet solid rather than as a dry solid.

RELEASE TOTAL 1.6E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 12 Basis: Submission estimates 12 workers exposed to wet solid that is 95% PMN.

Inhalation: Potential inhalation exposure assessed due to chance of airborn PMN (submission indicates that air purifying respirator is called for)

Exposure to Particulate (Class I) Upper Bound: 1.4E+2 mg/day over 77 days/yr Number of workers (all sites) with inhalation exposure: 12 Basis: Unloading Solid Raw Material from Transport Containers; OSHA PNOR PEL-Limiting Model. 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

OR b) Hazard Rating for health of 2 or greater? 1-2 No Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal:

Exposure to Solid at 95.00% concentration High End: 2.9E+3 mg/day over 77 days/yr Number of workers (all sites) with dermal exposure: 12 Basis: Unloading Solid Raw Material from Transport Containers; EPA/OPPT Direct 2-Hand Dermal Contact with Solids Model.



MEMORANDUM of TELEPHONE CONVERSATION

CALL BY: Dan Roper Organization: ERG, for EPA/OPPT/CEB

Page 5p090636.eng.txt CALL TO: Larry McDermott

Organization: Fujifilm Hunt Chemicals USA, Inc.

Date: 10/13/2009

Time: 10:20 am

Phone: 423-285-1031

Concerning what TSCA ?

PMN: 09-0636

Q1: Is there a difference between BEHTA-pTSA and BEHTA*pTSA (- vs. *)? A1: No, same chemical (PMN), our terminology is still in flux. /// Q2: The description on p. 8 states the PMN is formed in Reactor E, but the diagram on p. 8a indicates some of the reactants are added to Reactor D. Clarify? A2: The PMN is formed in Reactor D. We've been revising the process , and neither the description nor the diagram are the final version. /// Q3: Are the seed crystals added to Reactor D or F? A3: Reactor D. Reactor F will only be used for cooling. /// Q4: Are the transfers between reactors manual or piped? A4: All the connections and transfers between vessels are piped. PMN is only transferred manually as the wet cake from the centrifuge. /// Q5: What type of containers are used to store the wet cake and how are they cleaned/disposed of? A5: Plastic drums, they may be reused several times, they are sent to a drum reconditioner at end of life. /// Q6: Does the PMN completely react in the use? A6: Yes the PMN is just the salt form of and is easily disassociated. /// Q7: Are all wastes incinerated or do you send any waste streams to WWT? A7: All waste is incinerated off site. Don't have an on-site WWTP and don't discharge to POTW. Do send non-hazardous waste from other processes at plant to off-site, non-hazardous WWTP, but nothing is sent from this process to the non-hazardous WWTP.

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