Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-10-553 

EPA Docket EPA-HQ-OPPT-2011-0577 

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Index

A-001 Structure Activity Team (SAT) Report for 

PMN P-10-553 

A-002 Initial Review Engineering Report for 

PMN P-10-553 

A-003 Initial Review Exposure Report for 

PMN P-10-553 

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A-001 

Structure Activity Team (SAT) Report

for PMN P-10-553 

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A-002 

Initial Review Engineering Report

for PMN P-10-553 

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INITIAL REVIEW ENGINEERING REPORT

P-10-0553

Focus Ready Draft 9/30/2010

ENGINEER: Hall \ JAS

PV (kg/yr): 

Revision Notes/Assessment Overview:

SUBMITTER:

USE:

OTHER USES:

MSDS: Yes LABEL: No

Gen Eqpt: Impervious gloves recommended / safety glasses with side shields or chemical goggles / Good general 

room ventilation should be adequate under normal conditions If use generates significant airborne vapor or mist, 

mechanical ventilation such as local exhaust may be needed.

Respirator: None needed with adequate ventilation. If the occupational exposure limit is exceeded, use an 

approved respirator with an organic vapor cartridge or a supplied air respirator. Selection of respiratory protection 

depends on the contaminant type, form and concentration Select in accordance with OSHA 1910.134 or other 

applicable regulations and good Industrial Hygiene practice.

Health Effects: May cause mild eye and skin irritation / Inhalation of vapors or mists may cause respiratory 

irritation, headache and nausea.

TLV/PEL: - none established.

CRSS: (9/23/2010):

Chemical Name: 

S-H2O: 0.0000138 g/L @ 

VP:

MW: 206 0.0%<500 0.0%<1000

Physical State and Misc CRSS Info:

Neat: Mfg: 

Proc/Form: End Use: The structures shown on page 1 of this report are representative. A list of 

some of the specific components in the mixture is included on page 6 of this report. The molecular weights for the 

structures shown on page 1 of this report range from 206.37 g/mole for to 332.62 g/mole for 

 The physical/chemical properties shown above are worst case for the low weight 

component Submitted Data: 

 Estimated Data for 

 Estimated Data for 

Consumer Use: No

SAT (concerns): (9/24/2010):

Migration to groundwater: Negligible

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PBT rating: P1 B3 T1

Health: 1-2, Inhalation

Eco: 3, Water (All releases to water with a CC = 1 ppb.)

OCCUPATIONAL EXPOSURE RATING: 2-3B

NOTES & KEY ASSUMPTIONS:

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

POLLUTION PREVENTION CONSIDERATIONS:

P2 Claim: 

P2 REC:

EXPOSURE-BASED REVIEW: 

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P-10-0553

Manufacturing: 

Number of Sites/Location: 

Basis:

Process Description:

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. In addition to the releases assessed below, the submission estimates: 

Typical:

Worst Case: 

to: 

from:

basis:

Conservative:

to: 

from:

basis:

Output 2

to: 

from:

basis:

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

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Inhalation:

Exposure to 

Worst Case: 3.2E-1 mg/day 

Typical: 1.3E-3 mg/day

Number of workers (all sites) with Inhalation exposure:

Basis:

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit, or data not specific to industry): Yes

2) (a) Exposure level > 1 mg/day? No

 (b) Hazard Rating for health of 2 or greater? No

Inhalation Monitoring Data Desired? No

Dermal:

Exposure to 

High End: 

Number of workers (all sites) with Dermal exposure:

Basis:

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P-10-0553

PROC: 

Number of Sites/Location: 

Basis:

Process Description:

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.

Output 2: 

to: 

from:

basis:

Typical:

Worst Case: 

to: 

from:

basis:

Conservative:

to: 

from:

basis:

Typical:

Worst Case: 

to: 

from:

basis:

High End: 

to: 

from:

basis:

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Output 2: 

to: 

from:

basis:

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

Dermal:

Exposure to 

High End: 

Number of workers (all sites) with Dermal exposure:

Basis:

Inhalation:

Exposure to

Worst Case: 

Typical:

Number of workers (all sites) with Inhalation exposure:

Basis:

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit, or data not specific to industry): Yes

2) (a) Exposure level > 1 mg/day? Yes

 (b) Hazard Rating for health of 2 or greater? No

Inhalation Monitoring Data Desired? No

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P-10-0553

USE:

Number of Sites/Location: 

Basis:

Process Description:

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.

High End: 

to: 

from:

basis:

Typical:

Worst Case: 

to: 

from:

basis:

Output 2: 

to: 

from:

basis:

Output 2: 

to:

from:

basis:

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

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Tot. # of workers exposed via assessed routes: 

Basis:

Dermal:

Exposure to 

High End: 

Number of workers (all sites) with Dermal exposure:

Basis:

Inhalation:

Exposure to

Worst Case: 

Typical:

Number of workers (all sites) with Inhalation exposure:

Basis:

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit, or data not specific to industry): Yes

2) (a) Exposure level > 1 mg/day? Yes

 (b) Hazard Rating for health of 2 or greater? No

Inhalation Monitoring Data Desired? No

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A-003 

Initial Review Exposure Report

for PMN P-10-553 

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INITIAL REVIEW EXPOSURE REPORT (IRExR) 

 Chemical ID: P-10-0553 Reviewer: Flessner/SD 

 

Results Table: Dose, Concentration, and Days Exceeded Results Summary 

Exposure 

Scenario1 

 Water Landfill Stack Air Fugitive Air 

Drinking Water Fish Ingestion 

ADR LADD ADR LADD 7Q104 

CC 1 

PDM 

Days 

Exceede

d 

LADD ADR LADD ADR LADD 

Release 

activity(ies)2

; exposure 

calculation(s)

3 

mg/kg/day mg/kg/day mg/kg/day mg/kg/day μg/l # Days mg/kg/day mg/kg/day mg/kg/day mg/kg/day mg/kg/day 

1 Exposure scenario titles consist of release activity followed by exposure calculation abbreviation. 

2 Release activities are from engineering report's Manufacturing (Mfg), Processing (Proc) and Use release 

activity labels. 

 Multiple release activities are combined in one exposure scenario if their releases occur at same location. 

3 Exposure calculations are Acute Dose Rate (ADR), Lifetime Average Daily Dose (LADD), and 

Probabilistic Dilution 

 Model (PDM). There may be one, two, or all three exposure calculations per exposure scenario. 

 CC is the aquatic concentration of concern. 

4 This column displays concentration values for the 7Q10 streamflow, which is defined as the average daily 

streamflow 

 of the seven consecutive days of lowest flow within a ten year period. 

Remarks: 

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 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P-10-0553 Assessor: Flessner/SD 

ENVIRONMENTAL RELEASES 

 Scenario#:1 Number of Release Sites: 

 Release Activity: 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 

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

 

 Non-sludge/Sludge 

Release Days/yr: 

Per Site Release: 

 (kg/site/day) (kg/site/day) (kg/site/day) (kg/site/day) 

Remarks: 

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INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P-10-0553 

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 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P-10-0553 Assessor: Flessner/SD 

ENVIRONMENTAL RELEASES 

 Scenario#:2 Number of Release Sites: 

 Release Activity: 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 

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

 

 Non-sludge/Sludge 

Release Days/yr: 

Per Site Release: 

 (kg/site/day) (kg/site/day) (kg/site/day) (kg/site/day) 

Remarks: 

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INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P-10-0553 

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 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P-10-0553 Assessor: Flessner/SD 

ENVIRONMENTAL RELEASES 

 Scenario#:3 Number of Release Sites: 

 Release Activity: 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 

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

 

 Non-sludge/Sludge 

Release Days/yr: 

Per Site Release: 

 (kg/site/day) (kg/site/day) (kg/site/day) (kg/site/day) 

Remarks: 

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INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P-10-0553 

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INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P-10-0553 

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