# Support Documents for

Significant New Use Rule (SNUR) on

Premanufacture Notice (PMN)

P-10-200

EPA Docket EPA

- HQ

- OPPT -2011-0577

# I ndex

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

# A-001

Structure Activity Team (SAT) Report

for PMN P-10-200

# A-002

Init ial Review Engineering Report

for PMN P-10-200Support - 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:

Page 1Support - P-10-0200 engineering.5.txt

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

Page 2Support - P-10-0200 engineering.5.txt

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:

Page 3Support - P-10-0200 engineering.5.txt

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

Page 4Support - P-10-0200 engineering.5.txt

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:

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

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:

 Page 6Support - P-10-0200 engineering.5.txt

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:

Page 7Support - P-10-0200 engineering.5.txt

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

Page 8Support - P-10-0200 engineering.5.txt

Page 9

# A-003

Initial Review Exposure Report

for PMN P-10-20010/29/10 page of



## This report was revised using the Standard Review Dr aft 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 Scenario 1 Water Landfill Stack Air Fugitive Air

Drinking Water Fish Ingestion

ADR LADD ADR LADD 7Q10 4

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 Manuf acturing (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 (A DR), 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 7Q 10 streamflow, which is defined as the average daily

streamflow

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

Remarks:10/29/10 page of

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:10/29/10 page of

POST FOCUS EXPOSURE REPORT

Chemical ID: P-10-020010/29/10 page of

POST FOCUS EXPOSURE REPORT

Chemical ID: P-10-0200 Assessor: Cinalli/SS10/29/10 page of

POST FOCUS EXPOSURE REPORT

Chemical ID: P-10-020010/29/10 page of

POST FOCUS EXPOSURE REPORT

Chemical ID: P-10-0200