Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-10-200 

EPA Docket EPA-HQ-OPPT-2011-0577 

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Index

A-001 Structure Activity Team (SAT) Report for 

PMN P-10-200 

A-002 Initial Review Engineering Report for 

PMN P-10-200 

A-003 Initial Review Exposure Report for 

PMN P-10-200 

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A-001 

Structure Activity Team (SAT) Report

for PMN P-10-200 

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A-002 

Initial Review Engineering Report

for PMN P-10-200 

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Support - P-10-0200 engineering.5.txt

INITIAL REVIEW ENGINEERING REPORT 

PMN: 10-0200

Standard Review Draft 10/22/2010

ENGINEER: Prothero \ AH/CM

PV (kg/yr): 

Revision Notes / Assessment Overview: 10/22/10 SRER draft:

SUBMITTER: 

USE:

OTHER USES:

 

MSDS: Yes Label: No

Gen Eqpt: chemical resistant gloves and splash goggles,

clothing suitable to prevent skin contact,

local/mechanical ventilation.

Respirator: if airborne concentrations pose a health

hazard, become irritating, or exceed recommended limits,

use a NIOSH approved respirator in accordance with OSHA

respiratory protection requirements under 29 CFR1910.134

Health Effects: may cause skin and eye irritation;

harmful if inhaled, swalowed, or absorbed through skin;

may cause respiratory tract irritation upon inhalation of

mist

TLV/PEL:

None established for the PMN

CRSS :

Chemical Name:

S-H20: 

VP: 1.0E-6 torr @

MW: Physical State and Misc CRSS Info:

Neat: Liquid Mfg: 

 Proc/Form: 

 End Use:

The submitter

provided 2 GPC spectra for the PMN material:

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Consumer Use: No

SAT (concerns) (02/23/2010):

Migration to groundwater: Slow

PBT rating: P2B1T1

Health: 1-2 Dermal, Inhalation

Eco: 2 Water (All releases to water with a CC = 155 ppb)

OCCUPATIONAL EXPOSURE RATING: 1B

NOTES & KEY ASSUMPTIONS:

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

POLLUTION PREVENTION CONSIDERATIONS:

None.

EXPOSURE-BASED REVIEW: 

INITIAL REVIEW ENGINEERING REPORT 

PMN: 10-0200

Manufacturing

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Number of Sites/ Location: 

Days/yr: 

Basis:

Process Description:

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

 

Conservative: 

to:

from:

basis:

Output 2: 

to: 

from: 

basis:

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

 

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

Exposure to on

High End: 

Number of workers (all sites) with dermal exposure: 

Basis:

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INITIAL REVIEW ENGINEERING REPORT 

PMN: 10-0200

Processing (formulation)

Number of Sites/ Location: 

 Days/yr: 

Basis: 

Process Description:

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

PROBABLY DO NOT coincide with daily releases from the

other sources to the same medium.

Conservative: 

to:

from:

basis: 

 

Conservative: 

to:

from:

basis: 

 

RELEASE TOTAL

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OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

Exposure to 

High End: 

Number of workers (all sites) with dermal exposure: 

Basis:

INITIAL REVIEW ENGINEERING REPORT 

PMN: 10-0200

Use: 

Number of Sites/ Location: 

Days/yr: 

Basis: 

 

Process Description: 

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

Output 2: 

to:

from: 

basis: 

 

 

 

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Output 2: 

to:

from: 

basis: 

 

 

Output 2: 

to:

from: 

basis: 

 

 

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

Exposure to 

High End: 

Number of workers (all sites) with dermal exposure: 

Basis:



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CALL BY: Scott Prothero

Organization: US EPA/ OPPT/ CEB

CALL TO: 

Organization: 

Date: 03/16/2010

Time: 1:50 pm

Phone: 

PMN: 10-0200

CALL BY: Scott Prothero

Organization: US EPA/ OPPT/ CEB

CALL TO: 

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Organization: 

Date: 03/26/2010

Time: 1:45 pm

Phone: 

PMN: 10-0200

 

 

 

 

CALL BY: 

Organization: 

CALL TO: Scott Prothero

Organization: US EPA/ OPPT/ CEB

Date: 05/18/2010

Time: 1:00 pm

Phone: 

PMN: 10-0200

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A-003 

Initial Review Exposure Report

for PMN P-10-200 

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10/29/10 page of 

This report was revised using the Standard Review Draft engineering 

report dated 10/22/2010. 

POST FOCUS EXPOSURE REPORT 

 Chemical ID: P-10-0200 Reviewer: Cinalli/SS 

 

 

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

Exposure Scenario1 Water Landfill Stack Air Fugitive Air 

Drinking Water Fish Ingestion 

ADR LADD ADR LADD 7Q104 

CC = 155 

PDM 

Days 

Exceede

d 

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 μg/l # Days mg/kg/day mg/kg/day mg/kg/day mg/kg/day mg/kg/day 

PROC: max acute 

eco 

PROC: PDM1 

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. 

4 This column displays concentration values for the 7Q10 streamflow, which is defined as the average daily 

streamflow 

 of the seven consecutive days of lowest flow within a ten year period. 

Remarks: 

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 POST FOCUS EXPOSURE REPORT 

Chemical ID: P-10-0200 Assessor: Cinalli/SS 

ENVIRONMENTAL RELEASES 

 Scenario#:1 Number of Release Sites: 

 Release Activity: PROC: Max ADR 

 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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POST FOCUS EXPOSURE REPORT 

 Chemical ID: P-10-0200 

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 POST FOCUS EXPOSURE REPORT 

Chemical ID: P-10-0200 Assessor: Cinalli/SS 

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POST FOCUS EXPOSURE REPORT 

 Chemical ID: P-10-0200 

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POST FOCUS EXPOSURE REPORT 

 Chemical ID: P-10-0200 

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