Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-09-139 

EPA Docket EPA-HQ-OPPT-2010-1075 

 

EPA SANITIZED Page 1 of 28 EPA SANITIZED Page 1 of 26
Index

A-001 Structure Activity Team (SAT) Report for 

PMN P-09-139 

A-002 Initial Review Engineering Report for 

PMN P-09-139 

A-003 Initial Review Exposure Report for 

PMN P-09-139 

EPA SANITIZED Page 2 of 26
A-001 

Structure Activity Team (SAT) Report 

for PMN P-09-139 

 

EPA SANITIZED Page 3 of 28 EPA SANITIZED Page 3 of 26
SAT Report

PMN Number: P-09-0139

SAT Date: 1/9/2009

Related cases:

Health related cases: 

Ecotox related cases: 

Concern levels:

Type of Concern: Health Eco Comments

Level of Concern: 2 1

 Persistence Bioaccum Toxicity Comments

 1 1 1

Exposure Based Review:

Health: Yes

Ecotox: No

Routes of exposure: Health: Dermal, inhalation

Ecotox: No releases to water

Fate: ;

Keywords:

 Keywords: IRR-S,E, CORROS-S (chronic), SENS-S, LUNG

Summary of Assessment:

 Fate:

Fate Summary: P-09-0139

FATE: 

Liquid with MP = -45 EC (M)

log Kow = -0.97 (E); 

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

VP = 0.0757 torr at 25 EC (M)

BP = 231 EC (NOMO5) based on 25 EC @ 0.0757 mm(M)

H < 1.00E-8 (E)

log Koc = 1.0 (E)

log Fish BCF = 0.50 (E) 

POTW removal (%) = 90 via sorption and biodeg

Time for complete ultimate aerobic biodeg = wk

Sorption to soils/sediments = low

PBT Potential: P1B1

EPA SANITIZED Page 4 of 26
*CEB FATE: Migration to ground water = negl due to biodeg

 Health:

 Health Summary: Absorption good all routes based on analogs;

test data for the tetra-ether analog, were:

rat acute oral LD50 = 3.7 g/kg;

rabbit acute dermal LD0 = 8.0 g/kg and with necrosis at site of application;

mild skin irritation in rabbits;

severe eye irritation in rabbits;

positive skin sensitization in guinea pigs;

concern for irritation to eyes, corrosion to skin after long-term exposure, and skin sensitization 

based on data for a close analog;

concern for irritation to mucous membranes, lungs, and the GI tract based on analog test data

 Ecotox:

Test 

Organism

Test 

Type

Test End 

Point

Predicted Measured Comments

fish 96-h LC50 3900

daphnid 48-h LC50 200

green algal 96-h EC50 130

fish _ chronic value 400

daphnid chronic value 20

algal _ chronic value 15

Sewage Sludge 3-h EC50 _

Sewage Sludge _ Chronic Value _

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

chemical class = aliphatic amine-triether; MW177; liquid with mp = -45 C (M); log Kow = 

-0.89 (ClogP), -0.97 (EPI); S > 1000 g/L at 20 °C (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)

1000

SARs

SAR Class

Ecotox Factors Comments: 

 SAT Chair: L Keifer 564-8916

EPA SANITIZED Page 5 of 26
A-002 

Initial Review Engineering Report 

for PMN P-09-139 

 

EPA SANITIZED Page 6 of 28 EPA SANITIZED Page 6 of 26
INITIAL REVIEW ENGINEERING REPORT

P-09-0139

Focus Ready Draft 1/22/2009

ENGINEER: Austin \ JAS \ AG

PV (kg/yr): 

Revision Notes/Assessment Overview:

SUBMITTER: Huntsman Corporation (submitter)

USE:

MSDS: Yes LABEL: No

Gen Eqpt: chemical-resistant, impervious gloves complying with an approved standard should be worn at all times 

when handling chemical products if a risk assessment indicates this is necessary / safety eyewear complying with an 

approved standard should be used when a risk assessment indicates this is necessary to avoid exposure to liquid 

splashes, mists or dusts / PPE for the body should be selected based on the task being performed and the risks 

involved and should be approved by a specialist before handling this product / use local exhaust ventilation.

Respirator: use a properly-fitted, air-purifying or air-fed respirator complying with an approved standard if a risk 

assessment indicates this is necessary.

Health Effects: causes eye and skin burns / harmful if absorbed through skin / causes respiratory tract infection / 

may be harmful if swallowed / combustible liquid and vapor.

TLV/PEL: - none established

CRSS: 

Chemical Name: 1-Propanamine, 3-[2-(2-methoxyethoxy)ethoxy]-

S-H2O: 1000 g/L @ 

VP: 7.6E-2 torr @ 

MW: 177 0.0%<500 0.0%<1000

Physical State and Misc CRSS Info:

Neat: Liquid Mfg: Liquid

Proc/Form: NK End Use: Solid, Submitted data: liquid, BP > 350 °F (177 

°C); VP = 0.0757 mm Hg; partially soluble in cold water (MSDS); flash point = 141-200 °F (64-93 °C); density = 

0.9851 g/cc; viscosity = 4.7891 cSt at 20 °C; submitted IR spectrum is in agreement with the structure provided 

Data from P-06-0190: MP = -45 °C, density = 0.980 g/cc. EPI estimated data (input MP = -45 °C, VP = 0.0757 

torr): WS = 1000 g/L; log P = -0.97; BP = 239 °C; VP = 0.0487 torr. NOMO 5 estimated data (input BP = 25 °C at 

0.0757 torr): BP = 230.9 °C ACD Labs estimated data (STN pprop database): WS = 214 g/L; log P = -1.154; BP = 

243.2 °C; VP = 3.26E-02 torr.

Consumer Use: No

SAT (concerns):

Migration to groundwater: Negligible

PBT rating: P1 B1 T1

Health: 2, Dermal, Inhalation, 

Eco: 1, No releases to Water, 

EPA SANITIZED Page 7 of 28 EPA SANITIZED Page 7 of 26
OCCUPATIONAL EXPOSURE RATING: 2-3D

NOTES & KEY ASSUMPTIONS:

Generated by the 06/07/2005 version of ChemSTEER

POLLUTION PREVENTION CONSIDERATIONS:

None.

P2 REC:

EXPOSURE-BASED REVIEW:

EPA SANITIZED Page 8 of 28 EPA SANITIZED Page 8 of 26
P-09-0139

Manufacturing: 

Number of Sites/Location: 1 submitter site(s) 

Huntsman Corporation Conroe TN 77306

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.

Deepwell Injection

Conservative: 1.0E+3 kg/site-day over 1 day/yr from 1 sites or 1.0E+3 kg/yr

to: deepwell injection (per submission)

Air

Output 2: 9.7E-3 kg/site-day over 1 day/yr from 1 sites or 9.7E-3 kg/yr

to: air

Air

Typical: 3.7E-2 kg/site-day over 1 day/yr from 1 sites or 3.7E-2 kg/yr

Worst Case: 7.4E-2 kg/site-day over 1 day/yr from 1 sites or kg/yr

to: air

RELEASE TOTAL

1.0E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

EPA SANITIZED Page 9 of 28 EPA SANITIZED Page 9 of 26
EPA SANITIZED Page 10 of 28 EPA SANITIZED Page 10 of 26
P-09-0139

Processing: 

Number of Sites/Location: 1 submitter site(s) 

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.

Air

Typical: 7.4E-3 kg/site-day over 5 day/yr from 1 sites or 3.7E-2 kg/yr

Worst Case: 1.5E-2 kg/site-day over 5 day/yr from 1 sites or kg/yr

to: air

Water or Incineration or Landfill

High End: 6.0E+2 kg/site-day over 5 day/yr from 1 sites or 3.0E+3 kg/yr

to: uncertain

Air

Output 2: 2.5E-4 kg/site-day over 5 day/yr from 1 sites or 1.3E-3 kg/yr

to: air

Air

Output 2: 9.7E-3 kg/site-day over 5 day/yr from 1 sites or 4.9E-2 kg/yr

to: air

Water or Incineration or Landfill

Conservative: 2.0E+2 kg/site-day over 5 day/yr from 1 sites or 1.0E+3 kg/yr

to: uncertain

EPA SANITIZED Page 11 of 28 EPA SANITIZED Page 11 of 26
Air

Typical: 2.1E-2 kg/site-day over 5 day/yr from 1 sites or 1.0E-1 kg/yr

Worst Case: 4.1E-2 kg/site-day over 5 day/yr from 1 sites or kg/yr

to: air

RELEASE TOTAL

4.0E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

EPA SANITIZED Page 12 of 28 EPA SANITIZED Page 12 of 26
P-09-0139

Use: 

Number of Sites/Location: 1 

 

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. 

Air

Typical: 3.3E-6 kg/site-day over 250 day/yr from 108 sites or 8.9E-2 kg/yr

Worst Case: 6.6E-6 kg/site-day over 250 day/yr from 108 sites or kg/yr

to: Air

Air

Output 2: 1.1E-7 kg/site-day over 250 day/yr from 108 sites or 3.0E-3 kg/yr

to: Air

Water or Incineration or Landfill

High End: 1.1E-1 kg/site-day over 250 day/yr from 108 sites or 3.0E+3 kg/yr

to: uncertain

Air

Output 2: 3.6E+0 kg/site-day over 250 day/yr from 108 sites or 9.7E+4 kg/yr

to: Air

RELEASE TOTAL

1.0E+5 kg/yr - all sites

EPA SANITIZED Page 13 of 28 EPA SANITIZED Page 13 of 26
OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

EPA SANITIZED Page 14 of 28 EPA SANITIZED Page 14 of 26
 

EPA SANITIZED Page 15 of 28 EPA SANITIZED Page 15 of 26
A-003 

Initial Review Exposure Report

for PMN P-09-139 

EPA SANITIZED Page 16 of 26
1/16/09 Page of 

INITIAL REVIEW EXPOSURE REPORT (IRExR) 

 Chemical ID: P090139 Reviewer: Sherer 

 

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 

7Q10 

CC=? 

PDM 

Days 

Exceeded

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 

 

EPA SANITIZED Page 18 of 28 EPA SANITIZED Page 17 of 26
1/16/09 Page of 

 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P090139 Assessor: Sherer 

 

 

 

 

EPA SANITIZED Page 19 of 28 EPA SANITIZED Page 18 of 26
1/16/09 Page of 

INITIAL EXPOSURE REVIEW REPORT 

Chemical ID: P090139 

RELEASE DESCRIPTION: 

 

 

 

 

 

 

 

 

 

EPA SANITIZED Page 20 of 28 EPA SANITIZED Page 19 of 26
1/16/09 Page of 

 

 

 

 

 

 

 

 

EPA SANITIZED Page 21 of 28 EPA SANITIZED Page 20 of 26
1/16/09 Page of 

LEGEND FOR NEW CHEMICALS EXPOSURE REPORT 

This new chemicals exposure report was prepared by the Exposure Assessment Branch (EAB) of the Economics, 

Exposure and Technology Division, Office of Pollution Prevention and Toxics, USEPA. 

The goals of these reports are to calculate conservative (protective) estimates of exposure endpoints for consumers, 

the general population, and the environment. 

For each exposure scenario to industrial releases, the following three endpoints are calculated: 

(1) maximum possible acute concentrations and doses 

(2) maximum possible chronic concentrations and doses 

(3) for water releases ≥ 20 days, the probability of exceedence of the aquatic concentration of concern 

These endpoints are identified by abbreviations on the Release Activity line, e.g., (1) max ADR, (2) max 

LADD, (3) max PDM. Depending on the release inputs, these endpoints may be calculated and presented on 

the same page or different pages. That is, a release activity ID of mfg; max ADR, max PDM, max LADD

indicates that all the exposure endpoints were calculated from common manufacturing release values; 

conversely, a release activity ID of mfg &proc; max ADR indicates that only the maximum acute exposure 

values were calculated for manufacturing and processing releases that occurred at the same site. 

For each consumer product use exposure scenario, whether exposure is to the user directly or to the general 

population/environment, the maximum exposure values are calculated and presented together. 

In addition to the exposure values above, EPA policy directs that exposure and release values be compared to 

criteria threshold values for Exposure-based and PBT Exposure-based cases. 

Exposure-based (YX) cases (those with ≥ 100,000 kg/yr production volume) 

Criteria are exceeded under the following conditions: 

 Presence in consumer product with likely exposure 

≥ 3E-3 mg/kg/d exposure via air, fish ingestion or drinking water 

≥ 10,000 kg/yr release to environment (post-treatment) 

≥ 1,000 kg/yr release to water (post-treatment) 

Persistent, Bioaccumulative, Toxic (PBT) chemicals of P2B2 rating or higher and production volume ≥ 20,000 kg/yr 

Criteria are exceeded as for YX cases, with the following differences: 

≥ 2,000 kg/yr release to environment (post-treatment) 

≥ 200 kg/yr release to water (post-treatment) 

Bolding rules in the Report: Values for endpoints above that are also health or eco concerns are bolded. 

EPA SANITIZED Page 22 of 28 EPA SANITIZED Page 21 of 26
7/1/09 

POSTFOCUS EXPOSURE REPORT 

 

 

 

 

 

EPA SANITIZED Page 24 of 28 EPA SANITIZED Page 22 of 26
7/1/09 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

EPA SANITIZED Page 25 of 28 EPA SANITIZED Page 23 of 26
7/1/09 

 

 

 

 

 

 

 

 

EPA SANITIZED Page 26 of 28 EPA SANITIZED Page 24 of 26
7/1/09 

 

 

 

 

 

 

 

EPA SANITIZED Page 27 of 28 EPA SANITIZED Page 25 of 26
7/1/09 

LEGEND FOR NEW CHEMICALS EXPOSURE REPORT 

This new chemicals exposure report was prepared by the Exposure Assessment Branch (EAB) of the Economics, 

Exposure and Technology Division, Office of Pollution Prevention and Toxics, USEPA. 

The goals of these reports are to calculate conservative (protective) estimates of exposure endpoints for consumers, 

the general population, and the environment. 

For each exposure scenario to industrial releases, the following three endpoints are calculated: 

(1) maximum possible acute concentrations and doses 

(2) maximum possible chronic concentrations and doses 

(3) for water releases ≥ 20 days, the probability of exceedence of the aquatic concentration of concern 

These endpoints are identified by abbreviations on the Release Activity line, e.g., (1) max ADR, (2) max 

LADD, (3) max PDM. Depending on the release inputs, these endpoints may be calculated and presented on 

the same page or different pages. That is, a release activity ID of mfg; max ADR, max PDM, max LADD

indicates that all the exposure endpoints were calculated from common manufacturing release values; 

conversely, a release activity ID of mfg &proc; max ADR indicates that only the maximum acute exposure 

values were calculated for manufacturing and processing releases that occurred at the same site. 

For each consumer product use exposure scenario, whether exposure is to the user directly or to the general 

population/environment, the maximum exposure values are calculated and presented together. 

In addition to the exposure values above, EPA policy directs that exposure and release values be compared to 

criteria threshold values for Exposure-based and PBT Exposure-based cases. 

Exposure-based (YX) cases (those with ≥ 100,000 kg/yr production volume) 

Criteria are exceeded under the following conditions: 

 Presence in consumer product with likely exposure 

≥ 3E-3 mg/kg/d exposure via air, fish ingestion or drinking water 

≥ 10,000 kg/yr release to environment (post-treatment) 

≥ 1,000 kg/yr release to water (post-treatment) 

Persistent, Bioaccumulative, Toxic (PBT) chemicals of P2B2 rating or higher and production volume ≥ 20,000 

kg/yr 

Criteria are exceeded as for YX cases, with the following differences: 

≥ 2,000 kg/yr release to environment (post-treatment) 

≥ 200 kg/yr release to water (post-treatment) 

Bolding rules in the Report: Values for endpoints above that are also health or eco concerns are bolded. 

EPA SANITIZED Page 28 of 28 EPA SANITIZED Page 26 of 26