Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-11-33 

EPA Docket EPA-HQ-OPPT-2011-0942 

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Index 

A-001 Structure Activity Team (SAT) Report for 

 PMN P-11-33 

A-002 Initial Review Engineering Report for 

 PMN P-11-33 

A-003 Initial Review Exposure Report for 

 PMN P-11-33 

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A-001 

Structure Activity Team (SAT) Report 

 for PMN P-11-33 

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SAT Report

PMN Number: P-11-0033

SAT Date: 10/29/2010

Print Date: 8/31/2011

Related cases:

Health related cases: 

Ecotox related cases: 

Concern levels:

Type of Concern: Health Eco Comments

Level of Concern: 2 2

 Persistence Bioaccum Toxicity Comments

3 11

Exposure Based Review:

Health:

Ecotox: No

Routes of exposure: Health: Dermal Inhalation 

Ecotox: All releases to water

Fate: ;

Keywords:

 Keywords: IRR/CORR-E,S,MM,L; SENS-S; AQUATOX

Summary of Assessment:

 Fate:

Fate Summary: P-11-0033

FATE: Estimations for low weight with one equivalent of each monomer MW 291 C17H29N3O

Liquid with MP < 25 C (E)

log Kow = 2.04 (E) 

S > 10 g/L at 25 C (E)

VP < 1.0E-6 torr at 25 C (E)

BP > 400 C (E)

H < 1.00E-8 (E)

log Koc = 4.21 (E)

log Fish BCF = 1.01 (E)

log Fish BAF = 0.86 (E) 

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POTW removal (%) = 90 via sorption

Time for complete ultimate aerobic biodeg > mo

Sorption to soils/sediments = v.strong

PBT Potential: P3B1

*CEB FATE: Migration to ground water = negl

 Health:

 Health Summary: Not absorbed from the skin, poor absorption from the GI 

tract and good absorption from the lung (pchem). Concern for irritation and possible corrosion 

to all tissues and dermal sensitization.

 Ecotox:

Test 

Organism

Test 

Type

Test End 

Point

Predicted Measured Comments

fish 96-h LC50 5.8 phenol-amine SAR

daphnid 48-h LC50 1.2 phenol-amine SAR

green algal 96-h EC50 1.2 aliphatic amine SAR

fish _ chronic value 0.19 phenol-amine SAR

daphnid _ chronic value 0.17 phenol-amine SAR

algal _ chronic value 0.41 aliphatic amine SAR

Sewage Sludge 3-h EC50 _

Sewage Sludge _ Chronic Value _

Ecotox Values Comments: Predictions are based on SARs for aliphatic amines and 

phenol-amines; SAR chemical class = aliphatic amine, phenol-amine; MW 209 with 100% < 

500; log Kow = 2.55 (EPI, representative structure); liquid (M); S = 122 g/L (P); pH7; 

effective concentrations based on 100% active ingredients and mean measured concentrations; 

hardness <150.0 mg/L as CaCO3; and TOC <2.0 mg/L;

Factors Values Comments

Assessment Factor 10

Concentration of Concern 

(ppb)

17 phenol-amine SAR

SARs aliphatic amines and 

phenol-amines

SAR Class aliphatic amine, phenol-amine

Ecotox Factors Comments: 

 SAT Chair: L Keifer 564-8916

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A-002 

Initial Review Engineering Report 

 for PMN P-11-33 

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file:///J|/SNURS/SNUR%20SANITIZATION/AUG%202011/P-11-0033/p110033en1.txt[9/12/2011 9:53:07 AM]

INITIAL REVIEW ENGINEERING REPORT 

PMN: 11-0033

Post-Focus Draft Revision 1 7/27/2011

ENGINEER: Prothero \ JAS

PV (kg/yr): 9,860 Import Only

SUBMITTER: 

USE:

OTHER USES:

MSDS: Label: 

TLV/PEL:

none established.

CRSS :

Chemical Name: Formaldehyde, polymer with 4-(1,

1-dimethylethyl)phenol, reaction products with

1-piperazineethanamine (TMR)

S-H20: 122 g/L @

VP: 1.0E-6 torr @

MW: 209.00 100.00%<500 100.00%<1000

Physical State and Misc CRSS Info:

Neat: Liquid Mfg: NK: Import Proc/Form: Solution: 50-55%

PMN material, then Solution: 13.6% PMN material End Use:

Destroyed. NAVG = 209 with 100% < 500 and 100% < 1000 by

GPC. Submitted Data: Viscosity = 400 Ps; Relative

Density = 1.0. Estimated Data: BP = 411 °C (EPI); VP = 8.

7E-7 torr (EPI); WS = 122 g/L (EPI); logP = 2.04 (EPI).

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The EPI estimations were performed on the component

consisting of one equivalent of each feedstock, having a

molecular weight of 291 g/mole and a molecular formula of

C17 H29 O. Amine FGEW = [(129.21)(100)]/[(51)(3)] = 84.

Consumer Use: No

SAT (concerns) (10/29/2010):

Related Cases and Related Cases and Misc SAT Info:

Analogs: 

Migration to groundwater: Negligible

PBT rating: P3B1T1 '

Health: 2 Dermal, Inhalation

Eco: 2 Water (All releases to water with a CC = 17 ppb.)

OCCUPATIONAL EXPOSURE RATING: 1C

NOTES & KEY ASSUMPTIONS:

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

POLLUTION PREVENTION CONSIDERATIONS:

None.

EXPOSURE-BASED REVIEW: No

INITIAL REVIEW ENGINEERING REPORT 

PMN: 11-0033

Use: 

Number of Sites/ Location: 

Days/yr: 

Basis: 

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Process Description: 

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

Air: not expected (low VP); IRER Note: The submission

estimates that there will be releases from cleaning

brushes or rollers, mixing blades or mixing pails (0.03

kg/batch). In the case of helical paint mixers, a small

amount of solvent is used to wipe on the cloth. The

submission indicates that the resin is allowed to cure in

the air over several days so that the PMN no longer

exists at the time it is sent off for waste. These

releases, which are far below assessment thresholds for

incineration and land, are not assessed below (consistent

with same-submitter past case P10-0566).

Incineration or Landfill

High End: 3.4E+0 kg/site-day over 9 days/yr from 10 sites

or 3.1E+2 kg/yr

to: incineration or landfill (July 2011 amend - LM

Windpower disposes via hazardous waste handler and Vestas

Blade via land or incineration - and future SNUR)

from: Cleaning Liquid Residuals from Drums Used to

Transport the Raw Material

basis: EPA/OPPT Drum Residual Model, CEB standard 3%

residual. The submission indicated that the residue in

the shipping container is less than 1.6%. The submission

estimatesd 3.19 kg/day total from all sites (media of

release not indicated). CEB std model assessed as

conservative.

RELEASE TOTAL

3.1E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

Inhalation:

Dermal:

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A-003 

Initial Review Exposure Report 

 for PMN P-11-33 

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7/27/2011 Page of 

POSTFOCUS EXPOSURE REPORT 

Case Number: P110033 Assessor: Delpire 

ENVIRONMENTAL RELEASES 

Scenario#: Number of Release Sites: 

Release Activity: 

Release Description: WATER LANDFILL INCINER LAND/INCIN FUGITIVE 

Total Releases: 

 

(kg/yr) (kg/yr) (kg/yr) (kg/yr) (kg/yr) 

Release Days/yr: 

 

Per Site Release: 

(kg/day) (kg/yr) (kg/yr) (kg/yr) (kg/day) 

Remarks: EAB DROP: Release information for this compound does not meet criteria for preparation 

of an exposure assessment in the Exposure Assessment Branch’s (EAB) Initial Review 

Exposure Report (this report). 

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