file:///J|/INITENG/P12%20cases/p120414.eng.txt[12/6/2012 9:11:17 AM] 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 tofile:///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.file:///J|/INITENG/P12%20cases/p120414.eng.txt[12/6/2012 9:11:17 AM] EXPOSURE -BASED REVIEW: No

INITIAL REVIEW ENGINEERING REPORT PMN: 12-0414

Processing:

Number of Sites/ Location: 10 Unknown Sites Days/yr: 250file:///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 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/yrfile:///J|/INITENG/P12%20cases/p120414.eng.txt[12/6/2012 9:11:17 AM] 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 sitesfile:///J|/INITENG/P12%20cases/p120414.eng.txt[12/6/2012 9:11:17 AM]file:///J|/INITENG/P12%20cases/p120414.eng.txt[12/6/2012 9:11:17 AM] INITIAL REVIEW ENGINEERING REPORT PMN: 12-0414

Processing 2:

Number of Sites/ Location: 10 Unknown Sites Days/yr: 250file:///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 sitesfile:///J|/INITENG/P12%20cases/p120414.eng.txt[12/6/2012 9:11:17 AM]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/yrfile:///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 sitesfile:///J|/INITENG/P12%20cases/p120414.eng.txt[12/6/2012 9:11:17 AM]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