## Support Documents for Significant New Use Rule (SNUR) on Premanufacture Notice (PMN)
P-11-637

EPA Docket EPA-HQ-OPPT-2011-0942

## Index A-001 Structure Activity Team (SAT) Report for PMN P-11-637 A-002 Initial Review Engineering Report for PMN P-11-637 A-003 Initial Review Exposure Report for PMN P-11-637

## A-001 Structure Activity Team (SAT) Report
for PMN P-11-637

### SAT Report PMN Number: P-11-0637 SAT Date: 9/23/2011 Print Date: 11/1/2011

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 11

Exposure Based Review : Health: Ecotox: N o Routes of exposure : Health: Dermal Inhalation Ecotox: N o releases to water Fate: ; Keywords : Keywords: SENS-S; BLOOD; LIVER; MUTA (UNCERT) Summary of Assessment :
Fate : Fate Summary: P-11-0637 FATE: Solid VP < 1.0E-6 torr at 25 C (E) BP > 400 C (E) H < 1.00E-8 (E) POTW removal (%) = 90 via sorption and biodeg; OECD 301B(Mod Sturm CO2 ev): 26% (avg.)/28d. Time for complete ultimate aerobic biodeg = wk - mo Sorption to soils/sediments = v.strong PBT Potential: P1B1*CEB FATE: Migration to ground water = negl

Health : Health Summary: N ot absorbed from the skin as the neat material ( p che m ); p oor through the skin if in solution (testing); p oor absorption from the lung and GI tract ( p che m ). Concern for dermal sensitization, and blood and liver toxicity based on submitted test data. Uncertain concern for mutagenicity based on submitted test data and organo tin analogues. Test Data: (-) Salmonella with and without activation; (-) E. coli with and without activation; (-) for chromosome aberrations in human lymphocytes, (+) for p olyploidy in a second trial; rat oral LD0 = 2000 mg/kg; rat dermal LD0 = 2000 mg/kg; no eye irritation in rabbits; mild skin irritation in rabbits, cleared by day 7; (+) skin sensitization in guinea pigs using the Magnusson-Kligman assay, 100% p os response at 20% ai; rat 28-day oral N OAEL = 330 mg/kg, changes in liver enzymes and increased white blood cell counts at 1000 mg/kg

Ecotox :

Test Organism Test Type Test End Point Predicted Measured Comments

fish 96-h LC50 * * daphnid 48-h LC50 * * green algal 96-h EC50 * * fish

_ chronic value * daphnid

_ chronic value * algal

_ chronic value * Sewage Sludge 3-h EC50

_ Sewage Sludge

_ Chronic Value

_ Ecotox Values Comments: Predictions are based on SARs for organotin compounds; ecotox chemical class: organotin; MW 698; S < 0.001 mg/L at 20 C; p H 7; hardness <180.0 mg/L as CaCO3; 100% active ingredients; mean measured concentrations; and TOC <2.0 mg/L;
Ecotoxicity Test Data Results for P-11-0637: Tin, C16-18 and C18-unsatd. fatty acids castor-oil fatty acids complexes; CASRN: 1315588-63-6
Three acute ecotoxicity studies were conducted on PMN (P-11-0637) in 2000 by NOTOX B.V. (The Netherlands) for Evonik Goldschmidt Corporation (submitter) with fish, daphnia, and algae. The PMN consisted of a yellow liquid at room temperature with a tin content of 16.4%, a reported water solubility of < 0.060 mg/L, and a vapor pressure of 1E-6 mmHg at 25°C. The p urity of the entire PMN was not reported, but was treated as 100% by the testing laboratory. The sorption to sediments and soils from P-11-0637 is estimated to be very strong. For the submitted water accommodated fraction (WAF) toxicity studies, the testing laboratories measured the PMN in the test medium and the tin content (using ICP-MS), but reported their endpoints (for example, EC50) based on the nominal WAF loading rates since the analytical values were difficult to interpret ( p er the testing laboratory). The analytical results indicated thatmany of the higher test solutions were above the water solubility limit. The ecotoxicity studies complied with OECD guidelines (OECD 201, 202, 203) for: 1) O2, water hardness values and other water quality parameters; 2) species, age, number of organisms per replicate, and biomass loading rates; and, 3) replicate and overall variability.
Carp (Cyprinus carpio) were exposed to P-11-0637 in a combined range finding/limit test under 96-hour static conditions. The testing laboratory used a solvent (acetone) to get their PMN into the WAF solutions, so a solvent control was included with the dilution water control. The WAF p repared nominal concentrations consisted of 0.1, 1.0, 10, and 100 mg/L. The number of C. carpio in the controls and 100 mg/L WAF solution was seven/treatment. The number of C. carpio in the 0.1, 1.0, 10 mg/L concentrations was three/treatment. Only ten percent mortality was reported in the nominal 100 mg/L WAF treatment. Over the course of the study, water temperature ranged from 20 - 22°C, p H ranged fro m 7.2 - 8.0, and the O2 concentrations ranged 4.7 - 9.0 mg/L. Since no significant observed adverse effects were observed below or at the water solubility limit, EPA will treat P-11-0637 (for fish) as no effects at saturation. This is a valid test.
In a 48-hour immobilization test, water fleas (Daphnia magna) (10 daphnia/replicate x 2 replicates) were exposed to P-11-0637 under static conditions with a combined range finding/limit test similar to the one described above. In the nominal 100 mg/L WAF treatment, all organisms became immobilized, while no immobilization occurred in the lower nominal test concentrations. The testing laboratory conducted two further WAF tests with either nominal concentrations of 10, 18, 32, 56, and 100 mg/L or nominal concentrations of 1.8, 3.2, 5.6, 10, 18, and 32 mg/L. In all three tests, a solvent control and a dilution water control was included. Immobility was only observed at concentrations with un-dissolved test material. The initial tin concentrations in these solutions indicated that the PMN was well above the water solubility limit. Over the course of the two studies, water temperature ranged from 20.1 - 21.5°C, p H ranged from 7.7 - 8.1, and O2 concentrations ranged from 8.0 - 9.2 mg/L. Since no significant observed adverse effects were observed below or at the water solubility limit, EPA will treat P-11-0637 (for aquatic invertebrates) as no effects at saturation. This is a valid test.
In a 72-hour algal toxicity test for growth rate and biomass, an initial cell concentration of 1E+4 cells/ml (6 replicates/control and 3 replicates/test concentration) of green algae (Pseudokirchneriella subcapitata) was exposed to P-11-0637 under static conditions with two range finding tests and one definitive test. For the first range finding test, the WAF prepared nominal concentrations consisted of 0.1, 1.0, 10, and 100 mg/L ( p lus a solvent control). For the second range finding test, the WAF prepared nominal concentrations consisted of 0.001, 0.01, and 0.1 mg/L ( p lus a solvent control and a dilution water control). For the definitive WAF, the nominal concentrations were 0.065, 0.14, 0.3, 0.65, 1.4, 3, 6.5, 14, and 30 mg/L ( p lus a solvent control). In the first range finding test, 90% algal inhibition was observed in the nominal 100 mg/L test solution. In the second test, algal growth was not adversely affected by nominal test concentrations of 0.001 and 0.01 mg/L. In the definitive test, adverse effects were only observed at nominal concentrations that had been analytically measured above the water solubility limit. Adverse effects to algae were not observed at concentrations at and below the water solubility limit of P-11-0637 (<0.06 mg/L). The test occurred with continuous light (60 to 135 ìE/m2/s) and continuous agitation. The temperature ranged from 23 - 24°C. The pH ranged from 6.7

–9.4. The hardness of the dilution water was 24 mg CaCO3/L. Cell growth was measured by direct microscopic cell enumeration. Since no significant observed adverse effects were observed below or at the water solubility limit, EPA will treat P-11-0637 (for algae) as no effects at saturation. This is a valid test.
The three submitted aquatic ecotoxicity studies are considered valid. For comparative purposes, the chronic and acute concern concentrations for P-11-0637, based on ECOSAR (v. 1.00a) p redictions, are no effects at saturation. Based on the submitted toxicity test results, the chronic and acute concern concentrations for P-11-0637 are no effects at saturation.
Ecotox Study Reviewer: J. Gallagher 28 September 2011
Factors Values Comments Assessment Factor 10 Concentration of Concern ( p pb) *

SARs organotin compounds SAR Class organotin-insoluble
Ecotox Factors Comments:
SAT Chair: L Keifer 564-8916

## A-002 Initial Review Engineering Report
for PMN P-11-637INITIAL REVIEW ENGINEERING REPORT P-11-0637 Focus Ready Draft 09/22/2011

ENGINEER: Austin \ BCS PV (kg/yr): 30000 Import only

Revision Notes/Assessment Overview:

SUBMITTER: Evonik Goldschmidt Corporation (submitter)

USE: Catalyst for polyurethane foam. Analog P-05-0510 has this same use.

OTHER USES: Analog P-99-1251 is used as a catalyst for electrostatic powder coating spray systems.

MSDS: Yes LABEL : N o Gen Eqpt: PVC gloves, chemical resistant goggles or safety glasses with side shields. Respirator: in case of formation of aerosols or vapors, an organic vapor cartridge respirator may be used if ventilation is not adequate. Health Effects: Eyes, Inhalation, Ingestion: no harmful effects have been reported. // Skin: causes irritation, may be harmful upon contact with skin. // TLV/PEL : - none established

CRSS: (9/22/2011): Chemical Name: Tin, C16-18 and C18-unsatd. fatty acids castor-oil fatty acids complexes S-H2O: 0.000001 g/L @ VP: 1.0E-6 torr @ MW: 698 0.0%<500 0.0%<1000 Physical State and Misc CRSS Info: Neat: Solid (est.) Mfg: N K - Imported Proc/Form: Solution, 90% PMN material diluted to 0.5% PMN material in formulation End Use: Solid, PMN material entrained in polymer matrix or destroyed. The structure drawn is representative. The MW and MF above are for C18 unsatd. fatty acid and ricinoleic acid. Castor oil fatty acid typically consists of 86-92% ricinoleic acid, 2-6% linoleic acid, 3-6% palmitic acid, 1-2% stearic acid , and 0-8.5% oleic acid (Organic Coating Technology Vol. I, page 48; H.F. Payne/John Wiley & Sons, Inc .). Submitted data: the submitted MSDS is for 70-90% PMN material. Estimated data: negligible vapor pressure (salt) and negligible water solubility (tin salt). The structure as drawn is 17% tin.

Consumer Use: N o SAT (concerns): (9/23/2011):

Related Cases and Misc SAT Info: Ecotox Analogs: P-05-510, P-99-1251. 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: 1D

NOTES & KEY ASSUMPTIONS:Generated by the 06/07/2005 version of ChemSTEER. This PMN is imported directly to the end user. Therefore, mfg and proc are not assessed. // The PMN contains an element of concern, tin // N ote SAT concern for dermal and inhalation with not releases to water required and migration to gw = negl. Therefore, this IRER only assesses incineration releases. Inhalation exposure is not assesses (VP < 0.001 torr; PMN not handled as a solid). Dermal exposures are assessed. // For USE: This IRER assesses equipment and container cleaning to uncertain media and additional releases to incineration based on submitter estimates. Dermal exposure is assessed during unloading and pouring of liquid foam. // Same submitter, same-use past cases P05-0510 and same submitter similar use past case P11-0140 were referenced for consistency. // Both past cases are non-volatile solids (consistent with this IRER). P05-0510 is imported in solution and assesses dermal exposure but not inhalation exposure (consistent with this IRER). P11-0140 is imported as a solid and both dermal and inhalation exposure are assessed. // Both past cases assess equipment and container cleaning to uncertain media (consistent with this IRER). This IRER also assesses additional releases based on submitter information.

POLLUTION PREVENTION CONSIDERATIONS: N o Pollution Prevention information provided by the submitter.

P2 REC:

EXPOSURE-BASED REVIEW: N o (0 criteria met)P-11-0637

USE: Polyurethane Foam Catalyst

Number of Sites/Location: 1 submitter site(s) unknown sites Basis: Per submission, 10 customers sites, 250 days/yr, PMN imported in 25 kg pails, 220 kg drums, or 1000 kg totes and used as a liquid at 90% and formulated to 0.5%. CS calculates a use rate of 12 kg/site-day. CEB assumes drums for the import container. Process Description: PMN (90%, liquid) is imported in either 25 kg pails, 220 kg drums, or 1000 kg totes ---> transferred to mixing head with other raw materials ----> pour into open ventilated container (PMN 0.5% liquid) to form polyurethane foam solid ---> PMN entrained in solid (submission, CRSS) 

### 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. N ote SAT concerns for dermal and inhalation with no releases to water required and migration to gw = negl. Therefore, this IRER only assesses releases to incineration.

Incineration Output 2: 1.6E-1 kg/site-day over 16 day/yr from 10 sites or 2.6E+1 kg/y r to: off-site incineration (submission) from: Unloading Liquid Raw Material from Drums basis: User-Defined Loss Rate Model. The submission estimates 0.16 kg/day are released to off-site incineration from leakage during unloading.

Water or Incineration or Landfill High End: 5.6E+0 kg/site-day over 16 day/yr from 10 sites or 9.0E+2 kg/y r to: uncertain from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. The submission does not address container cleaning residuals. CEB assesses these releases to uncertain media using the standard model loss fraction.

Water or Incineration or Landfill Conservative: 1.2E-1 kg/site-day over 250 day/yr from 10 sites or 3.0E+2 kg/y r to: uncertain from: Equipment Cleaning Losses of Liquids from a Mixing Tank basis: EPA/OPPT Single Vessel Residual Model, CEB standard 1% residual. The submission does not address equipment cleaning residuals. CEB assesses these releases to uncertain media using the standard model loss fraction.

Incineration Output 2: 3.0E-2 kg/site-day over 1 day/yr from 10 sites or 3.0E-1 kg/y r to: off-site incineration (submission) from: Losses from Meter Calibration basis: User-Defined Loss Rate Model. The submission estimates 0.03 kg/day of PMN released to off-site incineration from losses during meter calibration. The submission estimates that this release will occur 1 day/y r

.


### RELEASE TOTAL1200 kg/y r - all sites



### OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 600 Basis: The submission estimates a total of 60 workers/site. As conservative, CEB assess a workers to PMN as a liquid at 90% (unloading) and 0.5% (pouring foam).

Dermal:
Exposure to Liquid High End: 1.6E+3 mg/day over 250 days/y r Number of workers (all sites) with Dermal exposure: 600 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

Dermal:
Exposure to Liquid High End: 4.3E+1 mg/day over 250 days/y r Number of workers (all sites) with Dermal exposure: 600 Basis: Pouring Liquid Polyurethane Foam; EPA/OPPT 2-Hand Dermal Immersion in Liquid Model.

## A-003 Initial Review Exposure Report
for PMN P-11-637

### Exposure Report

PMN Number: P-11-0637

11/1/2011 9:21:23 AM

Assessor: Kwon/BC

Ratings

N on-Occupational : Environmental:
Drop Criteria: EAB Drop Criteria Reasoning: N o water releases assessed. Other releases below the threshold.
Exposure Based Assessment:
Exposure-Based ( N on-Occupational): Exposure-Based (Environmental):

Exposure Parameter Exposure-Based Persistent/Bioaccum Exposure Value Surface DW: Fish Ingestion: Ground DW: Inhalation: Water Releases: Total Releases: Consumer Exposure:

Recommended Fate Tests:

Consumer Use expected? N Consumer Use remarks:Scenario Comment Sites Location
1. Scenario -- Medium: (Engineering) ; USE: Polyurethane Foam Cat a 10 , 2. Release -- Medium: Water or Incineration or Landfill (Engin USE: Polyurethane Foam Cat a 10 3. Release -- Medium: Water or Incineration or Landfill (Engin USE: Polyurethane Foam Cat a 10 4. Release -- Medium: Incineration (Engineering) ; USE: Polyurethane Foam Cat a 10 5. Release -- Medium: Incineration (Engineering) ; USE: Polyurethane Foam Cat a 10

**Environmental Release Information for Those Releases Which Went to the Model (Release Identifier Number)

1