# Support Documents for Significant New Use Rule (SNUR) on Premanufacture Notice (PMN) P-10-553

EPA Docket EPA

- HQ

- OPPT -2011-0577

# Index A-001 Stru cture 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

# A-001 Structure Activity Team (SAT) Report for PMN P-10-553

# A-002 Initial Review Engi neering Report for PMN P-10-553

### 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 : N o 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: N one 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: N o SAT (concerns): (9/24/2010): Migration to groundwater: N egligiblePBT rating: P 1 B 3 T 1 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: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: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? N o (b) Hazard Rating for health of 2 or greater? N o Inhalation Monitoring Data Desired? N o
Dermal: Exposure to High End: Number of workers (all sites) with Dermal exposure: Basis: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: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? N o Inhalation Monitoring Data Desired? N oP-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 SUMMARYTot. # 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? N o Inhalation Monitoring Data Desired? N o

# A-003 Initial Review Exposure Report for PMN P-10-5539/29/2010 Page 1 of 8



### INITIAL REVIEW EXPOSURE REPORT (IRExR)
Chemical ID: P-10-0553 Reviewer: Flessner/SD

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

Exposure Scenario 1 Water Landfill Stack Air Fugitive Air
Drinking Water Fish Ingestion ADR LADD ADR LADD 7Q10 4 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 exposu re calculation abbreviation. 2 Release activities are from engineering report's Manuf acturing (Mfg), Processing (Proc) and Use release activity labels. Multiple release activities are combined in one expo sure 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, tw o, or all three exposure calculations per exposure scenario. CC is the aquatic c oncentration of concern. 4 This column displays c oncentration 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:9/29/2010 Page 2 of 8

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: EPA SANITIZED9/29/2010 Page 3 of 8

INITIAL REVIEW EXPOSURE REPORT
Chemical ID: P-10-05539/29/2010 Page 4 of 8

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:9/29/2010 Page 5 of 8

INITIAL REVIEW EXPOSURE REPORT
Chemical ID: P-10-05539/29/2010 Page 6 of 8

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:9/29/2010 Page 7 of 8

INITIAL REVIEW EXPOSURE REPORT
Chemical ID: P-10-05539/29/2010 Page 8 of 8

INITIAL REVIEW EXPOSURE REPORT
Chemical ID: P-10-0553