Supporting Documents for 

Significant New Use Notice (SNUN) 

S-08-07 for SNUR at 

40 CFR 721.5185 

EPA Docket: EPA-HQ-OPPT-2009-0669 

September 2008 

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Index: 

A-1 Significant New Use Notice (SNUN) 

S-08-07 for SNUR at 40 CFR 721.5185 

B-1 Structure Activity Team (SAT) Report 

for S-08-07 

B-2 Initial Review Engineering Report (IRER) 

for S-08-07 Post Focus Version 

B-3 Initial Review Exposure Report (IRExR) 

for S-08-07 Post-Focus Draft 

B-4 Final Risk Assessment for S-08-07

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A-1 Significant New Use Notice (SNUN) 

S-08-07 for SNUR at 40 CFR 721.5185 

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Significant New Use Notice (SNUN) 

S-08-07 

for SNUR at 

40 CFR 721.5185 

EPA Docket: EPA-HQ-OPPT-2009-0669 

June 27, 2008 

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B-1 Structure Activity Team (SAT) Report 

 for S-08-07 

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STRUCTURE ACTIVITY TEAM REPORT 07/11/08 

CASE NUMBER: S08-0007

RELATED CASES: 

CONCLUSIONS/DISCUSSIONS 

TYPE OF CONCERN: HEALTH ECOTOX 

LEVEL OF CONCERN: 2-3 2 

KEYWORDS: NEURO DEVEL 

 IRR-E MUTA 

 ONCO LIVER 

 KIDNEY SENS 

 AQUATOX (A,C) 

SUMMARY OF ASSESSMENT 

FATE: Liquid with MP = -35 ̊C (M) 

log Kow = -0.52 (E); 

S > 10 g/L at 25 ̊C (E) 

VP = 4.1E-2 torr at 25 ̊C (NOMO5) 

BP = 240 ̊C (M) 

H < 1.00E-8 (E) 

log Koc = 1.00 (E) 

log Fish BCF = 0.50 (E) 

POTW removal (%) = 0-50 via stripping, and biodeg 

Time for complete ultimate aerobic biodeg = wk to mo 

Sorption to soils/sediments = low 

PBT Potential: P1B1T2 

*CEB FATE: Migration to ground water = rapid 

HEALTH: Absorption good all routes based on analogs and 

test data submitted for ; 

the portion can under Michael addition; 

submitted test data from were: 

rat acute oral LD50 = 588 mg/kg with possible neurotoxic 

signs, such as, clonic convulsions, body tremors, and 

decreased respiratory rate; 

rat acute dermal LD50 = 1.26 g/kg with liver effects; 

rat acute inhalation LC50 = 0.9 mg/L, LC100 = 1.79 mg/L; 

lung congestion in rats that died; 

moderate eye irritation in rabbits; 

slight skin irritation in rabbits; 

Ames test was negative; 

chromosome aberration test in human cells in culture was 

positive; 

mouse micronucleus (ip) test was negative; 

moderate (60%) skin sensitization in guinea pigs (M&K); and 

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rat 28-d subchronic (oral-gavage) NOAEL = 15 mg/kg/d, LOEL = 

50 mg/kg/d with effects to the liver with blood chemistry 

changes which was significantly lowered total protein 

indicating perturbed hepatic functions; microscopic 

examinations indicated hepatotoxicity; 

submitted test data from were: 

rat acute oral LD50 = 520 mg/kg; 

test data for analogs: 

mouse lymphoma forward mutation test was positive ( ); 

chromosome aberration test with CHO cells was positive 

( ); 

positive eye irritation and 3 of 6 rabbits died when 

chemical was applied to the skin ( ); 

rat acute dermal LD50 = 540 •L/kg ( ); 

rat 13-wk dermal toxicity test showed lethality at 500 

mg/kg/d, kidney toxicity at 75 mg/kg/d, and NOEL = 10 

mg/kg/d ( ); 

concerns for acute toxicity, neurotoxicity, eye irritation, 

mutagenicity, skin sensitization, and liver toxicity based 

on submitted test data from ; 

concern for neurotoxicity, developmental toxicity, and 

oncogenicity and uncertain concern for immunotoxicity based 

on . 

 *CEB HEALTH: Moderate high concern (Dermal, 

inhalation, drinking water) 

ECOTOX: Predicted (P) and measured (M) toxicity values in 

mg/L (ppm) are: 

fish 96-h LC50 = 180.0 P 

fish 96-h EC29 = 222.0 M SR24,M 

daphnid 48-h LC50 = 170.0 P 

daphnid 48-h LC50 = 120.0 M S,M 

green algal 96-h EC50 > 100.0 P 

green algal 72-h EC50 > 120.0 M S,M 

fish ACR >= 20.0 

fish chronic value = 10.0 P 

daphnid ACR >= 18.0 

daphnid ChV = 7.0 P 

algal ChV > 10.0 P 

algal ChV > 120.0 M S,M 

Predictions are based on SARs for ; 

SAR chemical class = ; log Kow = -0.54 

(CLOGP); ; pH7; 100% active ingredients and mean 

measured concentrations; hardness <180.0 mg/L as CaCO3; 

and TOC <2.0 mg/L; 

moderate concern for chronic toxicity; 

assessment factor = 10.0 

concern concentration = 0.700 

*CEB ECOTOX: All releases to surface water with CC = 700 

ppb 

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SAT Co-chair: Leonard Keifer 564-8916

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B-2 Initial Review Engineering Report (IRER) 

for S-08-07 Post Focus Version 

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s080007.en1

INITIAL REVIEW ENGINEERING REPORT CBI: 

Other New Chem:08-0007

Post-Focus Draft Revision 1 9/18/2008

ENGINEER: Macek \ DDH\CLM

PV (kg/yr): 

Revision Notes / Assessment Overview:

SUBMITTER:

USE: 

OTHER USES: 

MSDS: Label: No

TLV/PEL:

None provided

CRSS (07/10/2008):

 

 

Consumer Use: No

SAT (concerns) (07/11/2008):

Migration to groundwater: Rapid

PBT rating: P1B1T2

Health: 2-3 Dermal, Drinking Water, Inhalation

Eco: 2 Water (All releases to water with a CC = 700 ppb)

OCCUPATIONAL EXPOSURE RATING: 2-3B

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s080007.en1

NOTES & KEY ASSUMPTIONS:

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

 

 

 

 

 

 

 

 

 

 

 

 

POLLUTION PREVENTION CONSIDERATIONS:

None.

EXPOSURE-BASED REVIEW: No

INITIAL REVIEW ENGINEERING REPORT CBI: 

Other New Chem:08-0007

Number of Sites/ Location: 

Days/yr: 

Basis: 

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s080007.en1

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.

 

 

 

 

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

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s080007.en1

Inhalation:

 

 

 

Dermal:

INITIAL REVIEW ENGINEERING REPORT CBI: 

Other New Chem:08-0007

 

 

 

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OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

Inhalation:

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Process Description:

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

 

 

 

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s080007.en1



CBI: Yes

MEMORANDUM of CBI TELEPHONE CONVERSATION

CALL BY: Daryl Hudson

Organization: ERG for CEB

CALL TO: 

Organization: 

Date: 07/14/2008

Time: 10:00 AM

Phone: 

Concerning what TSCA CBI?

Other New Chem: 08-0007

 

 

 

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B-3 Initial Review Exposure Report (IRExR) 

for S-08-07 Post-Focus Draft 

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INITIAL REVIEW EXPOSURE REPORT (IRExR) 

 Chemical ID: S080007 Reviewer: Sherer 

 

Results Table: Dose, Concentration, and Days Exceeded Results Summary 

Exposure 

Scenario1 Water Landfill Water Concentration* Fugitive Air 

Drinking Water Fish Ingestion 

ADR LADD ADR LADD 

7Q10 

CC=? 

PDM 

Days 

Exceeded

LADD Acute Chronic 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 μg/day μg/day mg/kg/day mg/kg/day 

--- --- --- --- --- --- --- 5.30E-03 1.40E-03 --- --- 

--- --- --- --- --- --- --- 4.08E-03 1.08E-03 --- --- 

--- --- --- --- --- --- --- 3.08E-03 8.12E-04 --- --- 

4.46E-07 1.52E-09 --- --- 8.57E-03 1 --- --- --- --- --- 

1

 Exposure scenario titles consist of release activity followed by exposure calculation abbreviation. 2 Release activities are from engineering report's Manufacturing (Mfg), Processing (Proc) and Use release activity 

labels. 

Multiple release activities are combined in one exposure scenario if their releases occur at same location. 3

 Exposure calculations are Acute Dose Rate (ADR), Lifetime Average Daily Dose (LADD), and Probabilistic 

Dilution Model (PDM). There may be one, two, or all three exposure calculations per exposure scenario. 

CC is the aquatic concentration of concern. 

Remarks: 

Fate test recommendations?: (default is NA) 

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INITIAL REVIEW EXPOSURE REPORT (IRExR) 

Summary Table: Endpoints assessed 

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 

Threshold5

Release 

Below 

Chronic 

Threshold5

Other 

Ingestion 

 Surface water Y 

 Ground water (landfill) N 

 Consumer Use: DtD2 N 

Inhalation 

 Air: incineration (stack) N 

 Air: fugitive N 

 Consumer Use: CEM3 N 

Dermal 

 Consumer Use: CEM N 

Eco 

 Surface water: ADR 

conc and/or PDM4

Y 

 Consumer Use: DtD N 

1

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

2

Down-the-Drain Module 

3

Consumer Exposure Module 

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: 

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 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: S080007 Assessor: Sherer 

ENVIRONMENTAL RELEASES 

 Scenario#:1 Number of Release Sites: 

 Release Activity: 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 

 (kg/yr) (kg/yr) (kg/yr) (kg/yr) 

 

 Non-sludge/Sludge 

Release Days/yr: 

Per Site Release: 

 (kg/site/day) (kg/site/day) (kg/site/day) (kg/site/day) 

Remarks: 

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INITIAL REVIEW EXPOSURE REPORT 

CHEMICAL ID: S080007 

SITE-SPECIFIC HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES: 

LAKES, BAYS, ESTUARIES, AND OCEANS 

SCENARIO #: 1 RELEASE ACTIVITY: 

FACILITY NAME: 

FACILITY LOCATION: 

RECEIVING WATER NAME: 

REACH NUMBER: FACILITY ON REACH: Yes DISCHARGE TYPE: Direct 

NPDES PERMIT #: EXPOSED POPULATION: Adult 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PLANT FLOW 

(MLD) 

PRETREAT 

RELEASE 

(kg/site/day) 

POST-TREAT 

RELEASE 

(kg/site/day) 

BCF 

(L/kg) 

 

AQUATIC EXPOSURE ESTIMATES 

MIXING ZONE DILUTION FACTOR WATER CONCENTRATION (ug/L)

ACUTE SCENARIO 5.30E-03 

CHRONIC SCENARIO 1.40E-03 

FISH INGESTION EXPOSURE ESTIMATES 

ASSUMPTIONS 

Exposure Units Results ED 

(years) 

AT 

(years) 

BW 

(kg) 

IR 

 (g/day) 

Cancer 

LADDpot (mg/kg/day) 0.00 30.00 75.00 71.80 6.00 

LADCpot (mg/kg) 0.00 30.00 75.00 NA NA 

Acute 

ADRpot (mg/kg/day) 0.00 NA 1 day 71.80 129.00 

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 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: S080007 Assessor: 

ENVIRONMENTAL RELEASES 

 Scenario#:2 Number of Release Sites: 

 Release Activity: 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 

 (kg/yr) (kg/yr) (kg/yr) (kg/yr) 

 

 Non-sludge/Sludge 

Release Days/yr: 

Per Site Release: 

 (kg/site/day) (kg/site/day) (kg/site/day) (kg/site/day) 

Remarks: 

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INITIAL REVIEW EXPOSURE REPORT 

CHEMICAL ID: S080007 

SITE-SPECIFIC HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES: 

LAKES, BAYS, ESTUARIES, AND OCEANS 

SCENARIO #: 2 RELEASE ACTIVITY: 

FACILITY NAME: 

FACILITY LOCATION: 

RECEIVING WATER NAME: 

REACH NUMBER: FACILITY ON REACH: Yes DISCHARGE TYPE: Direct 

NPDES PERMIT #: EXPOSED POPULATION: Adult 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PLANT FLOW 

(MLD) 

PRETREAT 

RELEASE 

(kg/site/day) 

POST-TREAT 

RELEASE 

(kg/site/day) 

BCF 

(L/kg) 

 

AQUATIC EXPOSURE ESTIMATES 

MIXING ZONE DILUTION FACTOR WATER CONCENTRATION (ug/L)

ACUTE SCENARIO 4.08E-03 

CHRONIC SCENARIO 1.08E-03 

FISH INGESTION EXPOSURE ESTIMATES 

ASSUMPTIONS 

Exposure Units Results ED 

(years) 

AT 

(years) 

BW 

(kg) 

IR 

 (g/day) 

Cancer 

LADDpot (mg/kg/day) 0.00 30.00 75.00 71.80 6.00 

LADCpot (mg/kg) 0.00 30.00 75.00 NA NA 

Acute 

ADRpot (mg/kg/day) 0.00 NA 1 day 71.80 129.00 

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 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: S080007 Assessor: 

ENVIRONMENTAL RELEASES 

 Scenario#:3 Number of Release Sites: 

 Release Activity: 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 

 (kg/yr) (kg/yr) (kg/yr) (kg/yr) 

 

 Non-sludge/Sludge 

Release Days/yr: 

Per Site Release: 

 (kg/site/day) (kg/site/day) (kg/site/day) (kg/site/day) 

Remarks: 

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INITIAL REVIEW EXPOSURE REPORT 

CHEMICAL ID: S080007 

SITE-SPECIFIC HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES: 

LAKES, BAYS, ESTUARIES, AND OCEANS 

SCENARIO #: 3 RELEASE ACTIVITY: 

FACILITY NAME: 

FACILITY LOCATION: 

RECEIVING WATER NAME: 

REACH NUMBER: FACILITY ON REACH: Yes DISCHARGE TYPE: Direct 

NPDES PERMIT #: EXPOSED POPULATION: Adult 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PLANT FLOW 

(MLD) 

PRETREAT 

RELEASE 

(kg/site/day) 

POST-TREAT 

RELEASE 

(kg/site/day) 

BCF 

(L/kg) 

 

AQUATIC EXPOSURE ESTIMATES 

MIXING ZONE DILUTION FACTOR WATER CONCENTRATION (ug/L)

ACUTE SCENARIO 3.08E-03 

CHRONIC SCENARIO 8.12E-04 

FISH INGESTION EXPOSURE ESTIMATES 

ASSUMPTIONS 

Exposure Units Results ED 

(years) 

AT 

(years) 

BW 

(kg) 

IR 

 (g/day) 

Cancer 

LADDpot (mg/kg/day) 0.00 30.00 75.00 71.80 6.00 

LADCpot (mg/kg) 0.00 30.00 75.00 NA NA 

Acute 

ADRpot (mg/kg/day) 0.00 NA 1 day 71.80 129.00 

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 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: S080007 Assessor: 

ENVIRONMENTAL RELEASES 

 Scenario#:4 Number of Release Sites: 

 Release Activity: 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 

 (kg/yr) (kg/yr) (kg/yr) (kg/yr) 

 

 Non-sludge/Sludge 

Release Days/yr: 

Per Site Release: 

 (kg/site/day) (kg/site/day) (kg/site/day) (kg/site/day) 

Remarks: 

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INITIAL EXPOSURE REVIEW REPORT 

 Chemical ID: S080007 

SITE-SPECIFIC HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

SCENARIO NUMBER:4 RELEASE ACTIVITY: 

FACILITY NAME: 

FACILITY LOCATION: 

RECEIVING WATER NAME: 

REACH NUMBER: FACILITY ON REACH: Yes DISCHARGE TYPE: Direct 

NPDES PERMIT #: EXPOSED POPULATION: Adult 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PRETREATMENT 

RELEASE 

(kg/site/day) 

POSTTREATMENT 

RELEASE 

(kg/site/day) 

DWT 

(%) BCF 

(L/kg) 

 

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER 

FLOW DESCRIPTOR Harmonic Mean 30Q5 7Q10 1Q10 PLANT 

FLOW (MLD) 

CONCENTRATION (μg/L) 3.55E-03 5.34E-03 8.57E-03 8.57E-03 NA 

DRINKING WATER INGESTION AND FISH INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water 

Results 

Drinking Water 

Units 

Fish Ingestion 

Results 

Fish Ingestion 

Units 

Cancer 

LADDpot 1.52E-09 mg/kg/day 0.00 mg/kg/day 

LADCpot 7.78E-08 mg/L 0.00 mg/kg 

Acute 

ADRpot 4.46E-07 mg/kg/day 0.00 mg/kg/day 

 

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INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: S080007 

SITE-SPECIFIC HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

SCENARIO NUMBER: 4 RELEASE ACTIVITY: 

FACILITY NAME: 

FACILITY LOCATION: 

RECEIVING STREAM NAME: 

REACH NUMBER: FACILITY ON REACH: Yes DISCHARGE TYPE: Direct 

NPDES PERMIT NUMBER: GAGING STATION ID: 

GAGING STATION 

PERIOD OF RECORD: 

GAGING STATION 

NUMBER OF 

OBSERVATIONS: 

NUMBER OF STATIONS ON 

REACH: 

50 %ile FLOW (MLD): N/A 10 %ile FLOW (MLD): N/A EFFLUENT FLOW (MLD)

 

RESULTS 

COC (μg/L) 

Percent of Year 

COC Exceeded 

Number of Days 

COC Exceeded 

Release 

days/year 

Pre-treatment 

Loading 

(kg/site/day) 

Waste Water 

Treatment (%) 

700.00 0 1 

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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. 

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B-4 Final Risk Assessment for S-08-07

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Briefing Paper

Case Number: S08-0007 

Limited Standard Review 

PART I: BACKGROUND DATA

Program Manager: Tracey Pennington 

CCD Disposition Date: October 2, 2008 

Day 90: October 8, 2008 

A. Submitter: 

B. Chemical Identity: 

2-Propen-1-one, 1-(4-morpholinyl)- CASRN: 5117-12-4 

C. Physical Form: 

F. Molecular Weight: 

G. Volume: 

H. Use: 

I. Test Data Submitted with PMN: 

J. MSDS: Yes, 

K. SAT Ratings: Human Health: 2-3 Environment: 2 PBT: P1B1T2 

L. Focus Results: At Focus on 07/28/08, S08-0007 was placed into limited standard review 

to validate its consistency with the PMN because that is the end product of this 

substance. Potential risks to human health were low based on adequate respiratory 

protection. The Inhalation Monitoring Criteria for the Pilot Program were met for 

inhalation exposures from use. No Inhalation Monitoring was requested. Potential risks 

to the environment were low based on EPA believes that 

the new use is the residual content in the , so it is not "completely 

reacted and cured". 

PART II: NEW INFORMATION

After discussing the case further with the submitter, S08-0007 was submitted pursuant to 40 CFR 

721.5185 for the significant new use of releases to water of the chemical substance. Further, the 

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substance is not being completely reacted and cured as there is a 0.04% residual in the 

accompanying PMN submission 

The SNUR as currently written stipulates: 

 Protection in the workplace: §721.63 (a)(1), (a)(2)(i), (a)(2)(iv), (a)(3)(i), (a)(3)(ii), 

(a)(4), (a)(5)(i), (a)(5)(ii), (a)(5)(iii), (a)(5)(xii), (a)(5)(xiii), (a)(5)(xiv), (a)(5)(xv), 

(a)(6)(v), (b) (concentration set at 0.1 percent), and (c). 

 Hazard Communication: §721.72 (a), (b), (c), (d), (e) (concentration set at 0.1 

percent), (f), (g)(1)(iii), (g)(1)(iv), (g)(1)(v), (g)(1)(vi), (g)(1)(vii), (g)(1)(ix), 

(g)(2)(ii), (g)(2)(iv), (g)(2)(v), (g)(3)(i), (g)(3)(ii), (g)(4)(i), and (g)(5). 

 Industrial, commercial, and consumer activities: §721.80 (a), (c), (f), (p): First trigger 

(1year), second (1,500,000), and third (2,000,000) or 1 year whichever is greater then 

7,750,000 or 5 years after the commencement of commercial manufacture, whichever 

comes later and §721.80(y)(1). 

 Disposal: §721.85 (a)(1), (a)(2), (b)(1), (b)(2), (c)(1), and (c)(2). Disposal by landfill 

must go to a RCRA hazardous waste landfill. 

 Release to water: §721.90 (a)(i), (b)(1), and (c)(1). 

Based on a modification to the Consent Order in May 2006, the SNUR needed to be modified to 

reflect: 

 Removal of Disposal: §721.85 (a)(1), (a)(2), (b)(1), (b)(2), (c)(1), and (c)(2). 

Disposal by landfill must go to a RCRA hazardous waste landfill. 

 Removal of Release to water: §721.90 (a)(i), (b)(1), and (c)(1). 

The following is a summary of the additional information submitted for review: 

 Further clarification of residual handling practices from 

 Submission of an MSDS 

Based upon this information, revised engineering and exposure reports were placed 

EPA SANITIZED Page 65 of 66
 

 

PART III. RECOMMENDATION AND RATIONALE

Based on the new information provided and the previous need to modify the existing SNUR to 

comply with the modified Consent Order, the program manager recommends allowing the 

“significant new use” of releases to water. Further, the existing SNUR at 40 CFR 721.5185 

should be modified to reflect this change. 

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