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INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0414

Focus Ready Draft 7/9/2012

ENGINEER: Hall \ AG

PV (kg/yr): 

SUBMITTER: Kowa America Corp.

MSDS: Yes Label: No

Gen Eqpt: Eye/Face Protection: Chemical safety goggles

meeting the specifications of ANSI| Standard Z87.1 are to

be worn whenever there is the possibility of contact with

the eyes. Spectacle type safety glasses do not provide

satisfactory protection. Wear plastic face shield in

addition to safety goggles where there is a danger of|

splashing. // Protective Gloves: Wear chemical

resistant gloves appropriate to the conditions to prevent

dermal exposure. Glove material comparisons indicate that

gloves of butyl rubber are anticipated to afford adequate

hand protection. (Gloves made of PVC, nitrile, and

neoprene are not expected to provide adequate hand|

protection.) Rinse and remove gloves immediately after

use, and wash hands thoroughly with soap and water.

Gloves should be removed and replaced immediately if

there are any signs of degradation or breakthrough. //

Protective Clothing: Wear chemical resistant protective

clothing and footwear impervious to the product for the

duration of the anticipated exposure if there is a

potential for skin contact // Good general ventilation

should be sufficient to control low airborne levels of

the product. If the product is present above low levels,

local exhaust or other measures may be necessary to
file:///J|/INITENG/P12%20cases/p120414.eng.txt[12/6/2012 9:11:17 AM]

control worker exposure. Engineering controls may be

necessary during heating operations where irritating

vapors may evolve or be released.

Respirator: Wear adequate respiratory protection in the

case where there is a potential for inhalation exposure

during use or handling operations. Respirators equipped

with organic vapor cartridges are anticipated to provide

adequate respiratory protection during short-term

exposures to low vapor concentrations of the product.

Workers should wear a supplied-air respirator or

self-contained breathing apparatus| any time exposure is

above low levels or during extended exposure periods. Use

NIOSH-approved respiratory equipment. Respirators should

be selected based on the form and concentration of the

contaminant in the air and in accordance with OSHA (29

CFR 1910.134). Handle only in the presence of adequate

ventilation.

Health Effects: Eyes: This product (including its vapors)

may be irritating to the eyes. More serious effects,

including corneal damage and permanent injury, may result

if exposure is not treated. // Skin

Irritation/Sensitization/Absorption: This product may be

slightly irritating to the skin. The irritancy of this

product varies from person to person and may be the

result of the substance

In susceptible individuals with heightened skin

sensitivity, the product is a potential skin sensitizer

and may cause allergic reactions and contact dermatitis

resulting in severe irritation,| dryness, and cracking of

the skin. Irritation or allergic reactions may not

necessarily be immediately apparent effects may be

delayed. This product is not expected to be| absorbed

through the skin. // Ingestion : This product is not

expected to be harmful by ingestion. Over ingestion of

this product may result in adverse effects.| Inhalation :

The vapors of this product may be slightly irritating to

the upper respiratory tract (including nasal tissues).

Prolonged (hours) exposure may be harmful and cause

adverse effects including labored breathing and

drowsiness, as well as damage to the upper respiratory

tract.

TLV/PEL:

none established.
file:///J|/INITENG/P12%20cases/p120414.eng.txt[12/6/2012 9:11:17 AM]

Consumer Use: No

SAT (concerns) (06/29/2012):

Related Cases and Related Cases and Misc SAT Info:

Ecotox Related Cases: 

 / Human Health Related Cases: 

Migration to groundwater: Rapid

PBT rating: P1B1T2 .

Health: 2 Dermal, Drinking Water, Inhalation

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

OCCUPATIONAL EXPOSURE RATING: 1-2D

NOTES & KEY ASSUMPTIONS:

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

 
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EXPOSURE-BASED REVIEW: No

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0414

Processing: 

Number of Sites/ Location: 10

Unknown Sites

Days/yr: 250
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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 or Incineration or Landfill

High End: 6.2E+0 kg/site-day over 19 days/yr from 10 sites

or 1.2E+3 kg/yr

Water or Incineration or Landfill

Output 2: 1.0E-1 kg/site-day over 250 days/yr from 10

sites

or 2.5E+2 kg/yr

Water or Incineration or Landfill

Output 2: 1.0E+0 kg/site-day over 250 days/yr from 10

sites

or 2.5E+3 kg/yr
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Air

Typical: 4.0E-6 kg/site-day over 250 days/yr from 10 sites

Worst Case: 8.1E-6 kg/site-day over 250 days/yr from 10

sites

Air

Output 2: 1.3E-7 kg/site-day over 250 days/yr from 10

sites

Air

Typical: 2.4E-6 kg/site-day over 250 days/yr from 10 sites

Worst Case: 1.9E-5 kg/site-day over 250 days/yr from 10

sites

Air

Typical: 4.0E-6 kg/site-day over 250 days/yr from 10 sites

Worst Case: 8.1E-6 kg/site-day over 250 days/yr from 10

sites

Air

Output 2: 2.6E-2 kg/site-day over 250 days/yr from 10

sites

RELEASE TOTAL

4.0E+3 kg/yr - all sites
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INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0414

Processing 2:

Number of Sites/ Location: 10

Unknown Sites

Days/yr: 250
file:///J|/INITENG/P12%20cases/p120414.eng.txt[12/6/2012 9:11:17 AM]

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 or Incineration or Landfill

High End: 6.2E+0 kg/site-day over 5 days/yr from 10 sites

or 3.1E+2 kg/yr

Air

Typical: 1.0E-6 kg/site-day over 250 days/yr from 10 sites

Worst Case: 2.0E-6 kg/site-day over 250 days/yr from 10

sites

Air

Output 2: 3.4E-8 kg/site-day over 250 days/yr from 10

sites

RELEASE TOTAL

3.1E+2 kg/yr - all sites
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file:///J|/INITENG/P12%20cases/p120414.eng.txt[12/6/2012 9:11:17 AM]

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0414

USE: 

Number of Sites/ Location: 40

Unknown Sites

Days/yr: 250

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. Releases are estimated for the

unloading and filter media changeout steps for the sole

purpose of obtaining a vapor generation rate.

Water or Incineration or Landfill

High End: 1.2E+0 kg/site-day over 24 days/yr from 40 sites

or 1.2E+3 kg/yr

Water or Incineration or Landfill

Output 2: 2.0E-1 kg/site-day over 250 days/yr from 40

sites

or 2.0E+3 kg/yr
file:///J|/INITENG/P12%20cases/p120414.eng.txt[12/6/2012 9:11:17 AM]

Air

Typical: 5.1E-6 kg/site-day over 250 days/yr from 40 sites

Worst Case: 1.0E-5 kg/site-day over 250 days/yr from 40

sites

Air

Output 2: 1.7E-7 kg/site-day over 250 days/yr from 40

sites

Air

Output 2: 2.6E-2 kg/site-day over 250 days/yr from 40

sites

RELEASE TOTAL

3.5E+3 kg/yr - all sites
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file:///J|/INITENG/P12%20cases/p120414.eng.txt[12/6/2012 9:11:17 AM]

MEMORANDUM of CBI TELEPHONE CONVERSATION

CALL BY: Anthony Gaglione

Organization: ERG for CEB

CALL TO: 

Date: 07/02/2012

Time: 1:30 PM

Phone: 

Concerning what TSCA CBI?

PMN: 12-0414