Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-10-436 

EPA Docket EPA-HQ-OPPT-2011-0577 

EPA SANITIZED Page 1 of 15
Index

A-001 Structure Activity Team (SAT) Report for 

PMN P-10-436 

A-002 Initial Review Engineering Report for 

PMN P-10-436 

A-003 Initial Review Exposure Report for 

PMN P-10-436 

EPA SANITIZED Page 2 of 15
A-001 

Structure Activity Team (SAT) Report

for PMN P-10-436 

EPA SANITIZED Page 3 of 15
EPA SANITIZED Page 4 of 15
 

 

EPA SANITIZED Page 5 of 15
 

Page 6 of 15 EPA SANITIZED Page 6 of 15
 

 

EPA SANITIZED Page 7 of 15
 

 

 

EPA SANITIZED Page 8 of 15
A-002 

Initial Review Engineering Report

for PMN P-10-436 

EPA SANITIZED Page 9 of 15
INITIAL REVIEW ENGINEERING REPORT

P-10-0436

Focus Ready Draft 7/22/2010

ENGINEER: Arnold \ EV

PV (kg/yr): 

Revision Notes/Assessment Overview:

SUBMITTER: Scott Bader Inc. (submitter)

USE:

OTHER USES:

MSDS: Yes LABEL: No

Gen Eqpt: Provide adequate ventilation. Use protective gloves made of neoprene, nitrile, or rubber (natural latex); 

splash-proof eye goggles; and appropriate clothing to prevent possible skin contact.

Respirator: Wear mask supplied with: gas cartridge suitable for organic substances.

Health Effects: Harmful by inhalation. Iritating to eyes, skin and respiratory system. Limited evidence of 

carcinogenic effect. High inhalation concentrations are narcotic and may cause headache, fatigue, dizzinies and 

nausea. Product is flammable and heating may generate vapors which may form explosive vapor/air mixtures.

TLV/PEL: - Styrene - 430 mg/m3 - Workplace Exposure Limit - Unspecified - Unspecified - Styrene - 1,080 

mg/m3 - STEL - Unspecified - Unspecified

CRSS: (7/15/2010):

Chemical Name: 

S-H2O: 3.53 g/L @ 

VP: 1.0E-6 torr @ 

MW: 

Physical State and Misc CRSS Info:

Neat: Solid Mfg: 

Proc/Form: End Use: 

Submitted Data: None, the MSDS is for formulated material. Estimated Data for n=0: BP = 

455 °C (EPI); VP = 1.6E-9 torr (EPI); WS = 3.53 g/L (EPI); logP = 1.45 (EPI). These EPI estimations were 

performed for the case where n=0, having a molecular weight of and a molecular formula of 

Estimated Data for m=0: BP = 518 °C (EPI); VP = 1.6E-11 torr (EPI); WS = 0.0091 g/L (EPI); logP = 3.77 (EPI). 

These EPI estimations were performed for the case where m=0, having a molecular weight of and a molecular 

formula of 

Consumer Use: No

SAT (concerns): (7/16/2010):

Related Cases and Misc SAT Info:

Migration to groundwater: Negligible

PBT rating: P3 B1 T2 .

Health: 1-2, Dermal, Inhalation

Eco: 2, Water (All releases to water with a CC = 55 ppb)

EPA SANITIZED Page 10 of 15
OCCUPATIONAL EXPOSURE RATING: 2-3B

NOTES & KEY ASSUMPTIONS:

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

POLLUTION PREVENTION CONSIDERATIONS:

None.

P2 REC:

EXPOSURE-BASED REVIEW: 

EPA SANITIZED Page 11 of 15
P-10-0436

Use: Resin or Additive for Fire Retardant Coatings

Number of Sites/Location: 

 

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. 

Conservative:

to: 

from: 

basis: 

High End

to: 

from: 

basis: 

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis: 

Dermal:

Exposure to 

High End: 

Number of workers (all sites) with Dermal exposure:

Basis: 

Inhalation:

Exposure to 

Upper Bound: 

EPA SANITIZED Page 12 of 15
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

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

Inhalation Monitoring Data Desired? No

EPA SANITIZED Page 13 of 15
A-003 

Initial Review Exposure Report

for PMN P-10-436 

EPA SANITIZED Page 14 of 15
Date 7/21/10 Page of 

INITIAL REVIEW EXPOSURE REPORT 

Summary Page 

Chemical ID: P-10-0436 Reviewer: Flessner 

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 

 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. 

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). 

EPA SANITIZED Page 15 of 15