# Support Documents for

Significant New Use Rule (SNUR) on

Premanufacture Notice (PMN)

P-09-139

EPA Docket EPA-HQ-OPPT-2010-1075

# 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

# A-001

Structure Activity Team (SAT) Report

for PMN P-09-139

## 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: N o

Routes of exposure : Health: Dermal, inhalation

Ecotox: N o 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 ( N OMO5) 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

### *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;

p ositive 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); p H7; 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 ( p pb) 1000

SARs

SAR Class

Ecotox Factors Comments:

SAT Chair: L Keifer 564-8916

# A-002

Initial Review Engineering Report

for PMN P-09-139

### 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 : N o

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: N K 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. N OMO 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: N o

SAT (concerns):

Migration to groundwater: N egligible PBT rating: P 1 B 1 T 1

Health: 2, Dermal, Inhalation,

Eco: 1, N o releases to Water,OCCUPATIONAL EXPOSURE RATING: 2-3D

NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER

POLLUTION PREVENTION CONSIDERATIONS:

N one.

P2 REC:

EXPOSURE-BASED REVIEW: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/y r
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/y r
to: air

Air Typical: 3.7E-2 kg/site-day over 1 day/yr from 1 sites or 3.7E-2 kg/y r Worst Case: 7.4E-2 kg/site-day over 1 day/yr from 1 sites or kg/y r
to: air



## RELEASE TOTAL

1.0E+3 kg/y r - all sites



## OCCUPATIONAL EXPOSURES ESTIMATE SUMMARYP-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/y r Worst Case: 1.5E-2 kg/site-day over 5 day/yr from 1 sites or kg/y r
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/y r
to: uncertain

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

Air Output 2: 9.7E-3 kg/site-day over 5 day/yr from 1 sites or 4.9E-2 kg/y r
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/y r
to: uncertainAir Typical: 2.1E-2 kg/site-day over 5 day/yr from 1 sites or 1.0E-1 kg/y r Worst Case: 4.1E-2 kg/site-day over 5 day/yr from 1 sites or kg/y r
to: air



## RELEASE TOTAL

4.0E+3 kg/y r - all sites



## OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: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 /y r Worst Case: 6.6E-6 kg/site-day over 250 day/yr from 108 sites or kg/y r
to: Air

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

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



## RELEASE TOTAL

1.0E+5 kg/y r - all sites

## OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

# A-003

Initial Review Exposure Report

for PMN P -09-1391/16/09 Page of

INITIAL REVIEW EXPOSU RE REPORT (IRExR)

Chemical ID: P090139 Reviewer: Sherer

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

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 μ g/l # Days mg/kg/day mg/kg/day mg/kg/day mg/kg/day mg/kg/day1/16/09 Page of

INITIAL REVIEW EXPOSURE REPORT

Chemical ID: P090139 Assessor: Sherer1/16/09 Page of

INITIAL EXPOSURE REVIEW REPORT

Chemical ID: P090139

RELEASE DESCRIPTION:1/16/09 Page of1/16/09 Page of



## LEGEND FOR NEW CHEMICAL S EXPOSURE REPORT

This new chemicals exposure report wa s 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 calcula te 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 abbreviati ons on the Release Activity line, e.g., (1) max ADR , (2) max LADD , (3) max PDM . Depending on the release inputs, these e ndpoints 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 cal culated 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 proce ssing 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 dir ects 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) chemical s of P2B2 rating or hi gher 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 th at are also health or eco concerns are bolded.7/1/09

POSTFOCUS EXPOSURE REPORT7/1/097/1/097/1/097/1/09



## 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 (p rotective) 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 proce ssing releases that occurred at the same site.

For each consumer product use exposure scenario, whether e xposure 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 dir ects that exposure and release values be compared to criteria threshold values for Exposur e-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) chemical s of P2B2 rating or hi gher 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.