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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-day over 30 days/yr from 1 site 

or 6.3E+0 kg/site-yr from 1 site or 6.3E+0 kg/yr-all 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, all of which are routed 

to a scrubber (total air release = 0.21 kg/bt). 

Incineration 

Conservative: 5.0E+0 kg/site-day 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 the waste is transported 

off-site to a federally permitted haz. waste TSDF. 

RELEASE TOTAL 

1.6E+2 kg/yr - all sites 

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OCCUPATIONAL 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. 

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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-Hand Dermal Contact 

with Liquids Model. 

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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-day 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-site hazardous waste 

TSDF. 

RELEASE TOTAL 

4.5E+2 kg/yr - all sites 

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 3

Basis: CEB default minimum of 3 workers/site.

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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. 

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