Initial Review Engineering Report for Premanufacture Notice (PMN) P-08-0611.txt

INITIAL REVIEW ENGINEERING REPORT 

PMN: 08-0611

Post-Focus Draft Revision 3 9/8/2009

ENGINEER: Prothero \ DDH

PV (kg/yr): 

Revision Notes /

SUBMITTER: 

USE:

OTHER USES: 

MSDS: Yes Label: No

CRSS (08/14/2008):

 

 

Physical State and Misc CRSS Info:

 

 

 

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Consumer Use: 

SAT (concerns) (08/15/2008):

Migration to groundwater: Negligible

PBT rating: P2B2T1

Health: 1-2 Dermal, Inhalation, )

Eco: 3 Water (All releases to water with a CC = 2 ppb), 

OCCUPATIONAL EXPOSURE RATING: 2-3B

NOTES & KEY ASSUMPTIONS:

Generated by the 06/07/2005 version of ChemSTEER.

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.txt

volatilized at lower temperatures.

EXPOSURE-BASED REVIEW: 

1) # of workers exposed: >1000? No

2) >100 workers with >10 mg/day inhalation exposure: 

3) (a) >100 workers w/1-10 mg/day inh. exp. & >100 days/yr: 

 (b) Routine Dermal Cont: >250 workers & >100 days/yr: 

INITIAL REVIEW ENGINEERING REPORT 

PMN: 08-0611

Manufacturing

Number of Sites/ Location: 

 

 

Days/yr: 

Basis: Submission:

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. Water - not expected.

Output 2: 

to: 

from: 

basis:

n

Output 2:

to: 

from: 

basis:

Output 2:

to: 

from: 

basis: 

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Output 2:

to: 

from: 

basis:

RELEASE TOTAL

 kg/yr - 

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

Inhalation:

Exposure to 

Typical: 

Worst Case: 

Number of workers (all sites) with inhalation exposure: 

Basis:

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory l

 or data not specific to industry): 

2)a) Exposure level > 1 mg/day? 

 OR

 b) Hazard Rating for health of 2 or greater? 1-2 

Inhalation Monitoring Data Desired? 

Exposure to 

Upper Bound: 

Number of workers (all sites) with inhalation exposure: 

Basis:

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit,

 or data not specific to industry): 

2)a) Exposure level > 1 mg/day? 

 OR

 b) Hazard Rating for health of 2 or greater? 1-2 

Inhalation Monitoring Data Desired? 

Dermal:

Exposure to 

High End: 

Number of workers (all sites) with dermal exposure: 

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Exposure to 

High End: 

Number of workers (all sites) with dermal exposure:

Basis:

INITIAL REVIEW ENGINEERING REPORT 

PMN: 08-0611

Use 1: 

Number of Sites/ Location: 

Days/yr: 

Basis: Subm: 

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. IBCs returned to non-domestic site without cleaning.

Conservative:

to:

from: 

basis:

ndfill

High End:

to:

basis:

RELEASE TOTAL

 kg/yr -

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

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Initial Review Engineering Report for Premanufacture Notice (PMN) P-08-0611.txt

Inhalation:

Dermal:

Exposure to 

High End: 

Number of workers (all sites) with dermal exposure: 

Basis:

INITIAL REVIEW ENGINEERING REPORT 

PMN: 08-0611

Use 2: 

Number of Sites/ Location: 

Days/yr: 

Basis: 

 

 

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.

Output 2:

to:

from: 

basis:

Output 2:

to:

from: 

basis: 

 

Output 2:

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Initial Review Engineering Report for Premanufacture Notice (PMN) P-08-0611.txt

to:

from:

basis:

RELEASE TOTAL

 kg/yr - 

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

Inhalation:

Exposure to 

Upper Bound: 

Number of workers (all sites) with inhalation exposure: 

Basis:

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit,

 or data not specific to industry): 

2)a) Exposure level > 1 mg/day? 

 OR

 b) Hazard Rating for health of 2 or greater? 1-2

Inhalation Monitoring Data Desired? 

Dermal:

Exposure to 

High End: 

Number of workers (all sites) with dermal exposure: 

Basis:



MEMORANDUM of TELEPHONE CONVERSATION

CALL BY: Daryl Hudson

Organization: ERG for CEB

CALL TO: 

Organization: 

Date: 08/18/2008

Time: 12:30 PM

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Initial Review Engineering Report for Premanufacture Notice (PMN) P-08-0611.txt

Phone: 

Concerning what 

PMN: 08-0611

Q1: 

MEMORANDUM of TELEPHONE CONVERSATION

CALL BY: 

Organization: 

CALL TO: Scott Prothero

Organization: EPA/ OPPT/ CEB

Date: 09/12/2008

Time: 2:20 PM

Phone: 

Concerning what 

PMN: 08-0611

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Initial Review Engineering Report for Premanufacture Notice (PMN) P-08-0611.txt

MEMORANDUM of TELEPHONE CONVERSATION

CALL BY: 

Organization: 

CALL TO: Scott Prothero

Organization: EPA/ OPPT/ CEB

Date: 09/17/2008

Time: 1:00 PM

Phone: 

Concerning what 

PMN: 08-0611

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