INITIAL REVIEW ENGINEERING REPORT PMN: 14-0518 Manufacturing

Gelest Morrisville PA 19067 Number of Sites / Location: 1

Days / yr: 90

Basis: Per submission: 1 site, 500 kg/bt PMN, 72 hr/bt, and 30 bt/yr. CS calculates 90 day/yr operation.

Process Description: Raw materials

- - > reaction

- - > stripping

- - > PMN product (liquid, 100%) packaged (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.

Air Output 2: 2.1E-1 kg / site- d ay over 30 days / yr from 1 site or 6.3E+0 kg/site-yr from 1 site or 6.3E+0 kg/yr

- a ll sites to: Stack or fugitive air (submission) from: Process Air Emissions basis: User-Defined Loss Rate Model. Submission estimates 0.1 kg release from reaction to stack air, 0.1 kg release from filtration to fugitive air, and 0.01 kg release to fugitive air, a ll of which are routed to a scrubber (total air release = 0.21 kg/bt).

Incineration Conservative: 5.0E+0 kg / site

- d ay over 30 days / yr from 1 site or 1.5E+2 kg/site-yr from 1 site or 1.5E+2 kg/yr-all sites to: Off-site incineration (submission) from: Equipment Cleaning Losses of Liquids from a Single, Large Vessel
basis: EPA/OPPT Single Vessel Residual Model, CEB standard 1% residual. Submission did not quantify equipment cleangin releases but states any residual material from reactor is rinsed and th e waste is transported off-site to a federally permitted haz. waste TSDF.

RELEASE TOTAL 1.6E+2 kg / yr - all sitesOCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 3 Basis: Submission estimates 1 worker for reaction, 1 worker for filtration / distillation, and 1 worker for packaging, for a total of 3 workers for this operation.Inhalation: negligible (VP < 0.001 torr)

Dermal:
Exposure to Liquid at 100.00% concentration High End: > Potential Dose Rate: 2.2E+3 mg / day over 30 days / yr > Lifetime Average Daily Dose: 1.5E+0 mg / day over 30 days / yr > Average Daily Dose: 2.6E+0 mg / day over 30 days / yr > Acute Potential Dose: 3.2E+1 mg / day over 30 days / yr Number of workers (all sites) with dermal exposure: 3 Basis: Loading Liquid Product into Drums; EPA/OPPT 2

- H and Dermal Contact with Liquids Model.INITIAL REVIEW ENGINEERING REPORT PMN: 14-0518 Use: Site-Limited Chemical Intermediate

Gelest Morrisville PA 19067 Number of Sites / Location: 1

Days / yr: 50

Basis: Per submission for the subsequent chemical in the sequence, P14-0519: 1 site, 48 hr/bt, and 25 bt/yr. CS calculates 600 kg/bt and 50 operating days per year.

Process Description: PMN (liquid, 100%)

- - > unloaded into reactor

- - > reacted to form P14-0519 (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.

Incineration High End: 1.8E+1 kg / site- d ay over 25 days / yr from 1 site or 4.5E+2 kg/site-yr from 1 site or 4.5E+2 kg/yr-all sites to: Off-site incineration (submission) from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. Per submission, container residues are disposed to off- s ite hazardous waste TSDF.

RELEASE TOTAL 4.5E+2 kg / yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assesse d routes: 3 Basis: CEB default minimum of 3 workers/site.Inhalation: negligible (VP < 0.001 torr)

Dermal:
Exposure to Liquid at 100.00% concentration High End: > Potential Dose Rate: 2.2E+3 mg / day over 25 days / yr > Lifetime Average Daily Dose: 1.3E+0 mg / day over 25 days / yr > Average Daily Dose: 2.2E+0 mg / day over 25 days / yr > Acute Potential Dose: 3.2E+1 mg / day over 25 days / yr Number of workers (all sites) with dermal exposure: 3 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.