Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-10-324 

EPA Docket EPA-HQ-OPPT-2011-0577 

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Index

A-001 Structure Activity Team (SAT) Report for 

PMN P-10-324 

A-002 Initial Review Engineering Report for 

PMN P-10-324 

A-003 Initial Review Exposure Report for 

PMN P-10-324 

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A-001 

Structure Activity Team (SAT) Report

for PMN P-10-324 

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A-002 

Initial Review Engineering Report

for PMN P-10-324 

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Support - P-10-0324 engineering.2.txt

INITIAL REVIEW ENGINEERING REPORT 

PMN: 10-0324

Post-Focus Draft Revision 2 7/13/2010

ENGINEER: Jon \ AH

PV (kg/yr): 

Revision Notes / Assessment Overview:

SUBMITTER: 

USE:

OTHER USES: None found.

MSDS: Yes Label: No

Gen Eqpt: 

Respirator: 

Health Effects: 

irritant; 

TLV/PEL:

no information provided

CRSS :

Chemical Name:

S-H20: Dispersible g/L @

VP: 1.0E-6 torr @

MW: 

Physical State and Misc CRSS Info:

Neat: Solid Mfg: Proc/Form: 

End Use: 

 Submitted data: mp >250°C, ws = insoluble,

 particle size = 15 μm. The IR spectrum is consistent with the structure

provided. Estimated data: vp <1E-6 torr , ws = dispersible (worst case,

structure). 

 

 

Consumer Use: No

SAT (concerns) (04/16/2010):

Migration to groundwater: negligible - slow

PBT rating: P1B1T1

Health: 1-2 Inhalation

Eco: 3 Water (All releases to water with a CC = 43ppb)

OCCUPATIONAL EXPOSURE RATING: 2-3B

NOTES & KEY ASSUMPTIONS:

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Support - P-10-0324 engineering.2.txt

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

 

 

 

POLLUTION PREVENTION CONSIDERATIONS:

None.

EXPOSURE-BASED REVIEW: No

INITIAL REVIEW ENGINEERING REPORT 

PMN: 10-0324

Manufacturing

Number of Sites/ Location: 

 

Days/yr: 

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. The PMN is a molten

solid during MFG; dust releases not expected.

Output 

to: 

from: 

basis:

Output 2: 

to: 

from: 

basis: 

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Support - P-10-0324 engineering.2.txt

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 0

Basis:

Inhalation:

Dermal:

Not required, per SAT.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 10-0324

Processing: 

Number of Sites/ Location: 

Days/yr: 

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: 

 

Output 2: 

to: 

from:

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Support - P-10-0324 engineering.2.txt

Output 2: 5.0E+0 kg/site-day 

to: 

from: 

basis: 

 

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

Inhalation:

Exposure to 

Upper Bound: 

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

 OR

 b) Hazard Rating for health of 2 or greater? 1-2 No

Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal:

Not required, per SAT.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 10-0324

Use: 

Number of Sites/ Location: 

Days/yr: 

Basis:

Process Description:

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Support - P-10-0324 engineering.2.txt

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: 

Output 2: 

to: 

from:

basis:

Conservative: 

to: 

from: 

basis: 

 

 

High End: 

to: 

from: 

basis:

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

Inhalation:

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Support - P-10-0324 engineering.2.txt

Exposure to 

Upper Bound: 

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

 OR

 b) Hazard Rating for health of 2 or greater? 1-2 No

Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal:

Not required, per SAT.

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A-003 

Initial Review Exposure Report

for PMN P-10-324 

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Date 7/30/10 Page of 

POST FOCUS EXPOSURE REPORT 

Summary Page 

Chemical ID: P-10-0324 Reviewer: Sherer 

Endpoints-Assessed Table 

Reasons for not assessing releases 

Endpoints/Assessment 

Cycles1

Releases 

Assessed 

in 

NCEM2? 

No XB 

Testing 

Required 

No 

Hazard 

Concern 

No 

Releases 

Release 

Below 

Acute 5

Release 

Below 

Chronic 5

Other 

Ingestion 

 Surface water 

 Ground water (landfill) 

 Consumer Use: DtD2

Inhalation 

 Air: incineration (stack) 

 Air: fugitive 

 Consumer Use: CEM3

Dermal 

 Consumer Use: CEM 

Eco 

 Surface water: ADR 

conc and/or PDM4

 Consumer Use: DtD

1

Assessment cycles are endpoint concentrations and dose calculations within the NCEM2 model. 2

Down-the-Drain 

3

Consumer Exposure Model 

4

Probabilistic Dilution Model 

5

The threshold values for assessing endpoints are 1 mg/day for acute doses and 1 mg/year for chronic doses. 

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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