# Support D ocuments for

Significant New Use Rule (SNUR) on

Premanufacture Notice (PMN)

P-10-324

EPA Docket EPA

- HQ

- OPPT -2011-0577

# 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

# A-001

Structure Activity Team (SAT) Report

for PMN P-10-324

# A-002

Initial Review Engineering Report

for PMN P-10-324Support - 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:

Page 1Support - 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:

Page 2Support - 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:

Page 3Support - 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:

Page 4Support - 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:

Page 5Support - 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.

Page 6

# A-003

Initial Review Exposure Report

for PMN P-10-324Date 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

Cycles 1 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: DtD 2

Inhalation

Air: incineration (stack)

Air: fugitive

Consumer Use: CEM 3

Dermal

Consumer Use: CEM

Eco

Surface water: ADR

conc and/or PDM 4

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).