Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-10-458

EPA Docket EPA-HQ-OPPT-2011-0577
Index

A-001 Structure Activity Team (SAT) Report for 

PMN P-10-458

A-002 Initial Review Engineering Report for 

PMN P-10-458

A-003 Initial Review Exposure Report for 

PMN P-10-458
A-001

Structure Activity Team (SAT) Report

for PMN P-10-458

 

 

 
 

 

 

 

 

 
 

 

 
 
 

 

 

 
 
 
A-002

Initial Review Engineering Report

for PMN P-10-458
INITIAL REVIEW ENGINEERING REPORT

P-10-0458

Focus Ready Draft 8/12/2010

ENGINEER: Arnold \ BCS

PV (kg/yr): 

Revision Notes/Assessment Overview:

SUBMITTER: Cognis Corporation (submitter)

USE:

OTHER USES:

MSDS: Yes LABEL: No

Gen Eqpt: 

Respirator:

Health Effects:

TLV/PEL: 

CRSS: (8/5/2010):

Chemical Name:

S-H2O: Dispersible g/L @ 

VP: 1.0E-6 torr @ 

MW: 

Physical State and Misc CRSS Info:

Neat: Liquid Mfg: 

Proc/Form: End Use: 

Submitted Data: WS = Emulsifies; pH = 2.5-3.5 at 5%; Flash Point > 

200 °F. Estimated Data: VP < 0.000001 torr 

Consumer Use: No

SAT (concerns): (8/6/2010):

Related Cases and Misc SAT Info:

Migration to groundwater: Slow to moderate

PBT rating: P1 B1 T1 .

Health: 1-2, Dermal, Inhalation

Eco: 3, Water (All releases to water with a CC = 3 ppb)

OCCUPATIONAL EXPOSURE RATING: 1-2C
NOTES & KEY ASSUMPTIONS:

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

 

POLLUTION PREVENTION CONSIDERATIONS:

P2 Claim: 

P2 REC:

EXPOSURE-BASED REVIEW: 
P-10-0458

PROC/USE: 

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. Note SAT concerns for dermal, 

inhalation, and all releases to water with CoC = 3 ppb. 

Output 2: 

to: 

from: 

basis:

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:

Exposure to 

Upper Bound: 

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? No

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

Inhalation Monitoring Data Desired? No

Dermal:

Exposure to 

High End: 

Number of workers (all sites) with Dermal exposure:

Basis:

Inhalation:

Exposure to 

High End of Range: 

Low End of Range: 

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? No

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

Inhalation Monitoring Data Desired? No
A-003

Initial Review Exposure Report

for PMN P-10-458
8/11/10 page of 

INITIAL REVIEW EXPOSURE REPORT (IRExR) 

 Chemical ID: P-10-0458 Reviewer: Flessner/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 = 3 

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/USE: 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: 
8/11/10 page of 

 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P-10-0458 Assessor: Flessner/SS 

ENVIRONMENTAL RELEASES 

 Scenario#:1 Number of Release Sites: 

 Release Activity: PROC/USE: PDM1 

 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: 
8/11/10 page of 

INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P-10-0458 
8/11/10 page of 

INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P-10-0458