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:

Page 1Consumer 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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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: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: Page 4Exposure 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: Page 5Initial 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: Page 6Initial 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 Page 7Initial 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

Page 8Initial 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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