# Support Documents for Significant New Use Rule (SNUR) on Premanufacture Notice (PMN)

P-09-634

EPA Docket EPA-HQ-OPPT-2010-1075

# Index

A-001 Structure Activity Team (SAT) Report for PMN P -09-634

A-002 Initial Review Engineering Report for PMN P -09-634

A-003 Initial Review Exposure Report for PMN P -09-634

# A-001 Structure Activity Team (SAT) Report

for PMN P-09-634

## SAT Report PMN Number: P-09-0634 SAT Date: 9/29/2009

Related cases : Health related cases: Ecotox related cases:

Concern levels : 

### Type of Concern: Health Eco Comments Level of Concern: 2 3

Persistence Bioaccum Toxicity Comments 1 1 2
Exposure Based Review : Health: N o Ecotox: N o
Routes of exposure : Health: Dermal Drinking Water Inhalation Ecotox: All releases to water Fate: ;
Keywords : Keywords: IRR-E,S N EURO DEVEL BLOOD LIVER REPRO MUTA UNCERT SENS-S UNCERT ONCO AQUATOX-A,C
Summary of Assessment :

Fate : Fate Summary: P-09-0634 FATE: Solid with MP = 27-29 EC (M) log Kow = 3.80 (E);

### S = 48.7 mg/L at 25 EC (E) VP = 6.2E-3 torr at 25 EC ( N OMO5) BP = 271 EC ( N OMO5) based on 97 EC @ 1 mm Hg (M) H = 1.81E-5 (E) log Koc = 3.31 (E) log Fish BCF = 2.19 (E) log Fish BAF = 2.01 (E) POTW removal (%) = 23 via sorption and possible partial biodeg Time for complete ultimate aerobic biodeg = wk-mo Sorption to soils/sediments = moderate - strong Volatilization half-life from a standard river = 47 hrs Volatilization half-life from a standard lake = 26 da Atmospheric Oxidation Half-life = 23 hr via OH radical PBT Potential: P1B1 *CEB FATE: Migration to ground water = slow

Health : Health Summary: Absorption is poor through the skin, and moderate through the lung and GI tract, based on analogs. Expect reduction of the nitro group to an amine within the digestive system. There are concerns for: irritation to the eye and skin; neurotoxicity; developmental, liver, blood, and reproductive toxicities; mutagenicity; uncertain dermal sensitization; and uncertain oncogenicity, based on analogs and submitted test data. Test Data: Submitted with the PMN:

Salmonella assay negative with and without activation; E. coli assay negative with and positive without activation; Rat (F) oral (gavage) LD50 >2000 mg/kg; Slight dermal sensitizer in guinea pigs; Slight dermal irritant in rabbits; Eye irritant in male rabbits

Submitted with :

Rat (F) oral NOEL 5000 mg/kg (only dose tested); Slight eye irritant in rabbits; Slight dermal irritant in rabbits

Submitted with :

Salmonella assay positive with and without activation; Rat oral LD50 1345 mg/kg, with weakness and ataxia; Guinea pig dermal LD50 >1g/kg, with severe irritation; Severe eye irritant in rabbits; N ot a dermal sensitizer in guinea pigs; Rat oral subchronic toxicity test: 0.1% in diet, with hemoglobin concentration decreases, skin discoloration, and spleen congestion (LOEL, not listed)

### Submitted with (2-aminophenol):

Twelve-day dietary study in rats (0.1%, 1%): blood cell and hemoglobin changes at 1%, changes to stomach and spleen, with major mesenteric fat loss, at 1%, increased liver weights at 0.1%; Slight skin irritant (species unspecified); Slight eye irritant (species unspecified); N ot a dermal sensitizer in guinea pigs; Rat oral LD50 951 mg/kg; Mouse oral LD50 800 mg/kg

Ecotox :

Test Organism Test Type Test End Point Predicted Measured Comments

fish 96-h LC50 1.4 daphnid 48-h LC50 0.95 green algal 96-h EC50 3.7 fish chronic value 0.18/0.006 30-day/60-day daphnid

_ chronic value 0.18 algal

_ chronic value 1.7 Sewage Sludge 3-h EC50

_ Sewage Sludge

_ Chronic Value

_ Ecotox Values Comments: Predictions are based on SARs for phenols; SAR chemical class

= p henol; MW 318; log Kow = 3.82 (EPI); solid with mp = 29 C (M); p H7; effective concentrations based on 100% active ingredients and mean measured concentrations; hardness <150.0 mg/L as CaCO3; and TOC <2.0 mg/L;

Factors Values Comments Assessment Factor 10 Concentration of Concern ( p pb) 1

SARs p henols SAR Class p henol

Ecotox Factors Comments:

SAT Chair: J. Kwiat

# A-002 Initial Review Engineering Report

for PMN P-09-634

### INITIAL REVIEW ENGINEERING REPORT P-09-0634 Focus Ready Draft 10/8/2009

ENGINEER: Avcin \ DTN / DGR PV (kg/yr): 47000 Import only

Revision Notes/Assessment Overview:

SUBMITTER: FUJIFILM Hunt Chemicals USA (submitter)

USE: Chemical intermediate for a photographic chemical. Synthetic sequence

OTHER USES:

MSDS : Yes LABEL : N o
Gen Eqpt: protective gloves/clothing / tightly fitting safety goggles / adequate ventilation Respirator: In case of insufficient ventilation wear suitable respiratory equipment. Health Effects: May be harmful by inhalation, in contact with skin and if swallowed. Irritant to eyes, skin, mucous membranes, respiratory system. Dangerous for the environment. Toxic to aquatic organisms, may cause long-term adverse effects in the aquatic environment. TLV/PEL : - N one established for PMN chemical

CRSS: (9/28/2009): Chemical Name: Phenol, 4-(1,1-dimethylethyl)-2-nitroS-H2O: 0.049 g/L @ VP: 6.2E-3 torr @ MW: 195 0.0%<500 0.0%<1000 Physical State and Misc CRSS Info: Neat: Low melting solid Mfg: N K - Import Proc/Form: N A End Use: Destroyed. Submitted data: liquid; MP = 27-29 °C; BP = 97 °C at 1 torr; flash point = 113 °C; density = 1.12 g/cc. An HPLC chromatograph was provided. Literature data (STN eprop database): BP = 197 °C , 97 °C at 1 torr, 115-116 °C at 8 torr, 136-138 torr at 15-16 torr; MP = 26-26.5 °C, 70-73 °C. N OMO5 estimated data for BP = 97 °C at 1 torr (Class 3): BP = 271.1 °C, VP = 0.0062 torr. EPI estimated data (input MP = 27 °C): BP = 308 ° C; VP = 3.93E-4 torr; WS = 48.66 mg/L; log P = 3.82. ACD Labs estimated data (STN pprop database): BP = 262.6 °C; VP = 6.63E-3 torr; WS = 0.41 g/L; log P = 3.397.

Consumer Use: N o
SAT (concerns): (9/29/2009):

Related Cases and Misc SAT Info:

. Migration to groundwater: PBT rating: P 1 B 1 T 2 Health: 2, Dermal, Drinking Water, Inhalation Eco: 3, Water (All releases to water with a CC = 1 ppb)

OCCUPATIONAL EXPOSURE RATING: 1-2BNOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER. N ote: technical contact called for additional information but could not be reached. See contact report for additional details. This chemical is imported only, therefore domestic manufacturing activities were not assessed. The chemical is used as a raw material to manufacture an intermediate used in a photographic chemical and is site-limited. The chemical is reacted out of the process in Reactor B and no further assessments were made beyond that point in the process. The chemical is a volatile liquid (VP=0.0064); therefore inhalation exposures were assessed along with dermal exposures. Equipment and container cleaning wastes were assessed to uncertain media. Wastes from the phase cuts containing NTBP will be incinerated;

ecause this PMN is a liquid dust releases and exposures to particulates were not assessed. All past cases assessed releases to incineration. /// Follow-up 10/5/2009: Technical contact returned call, see contact report for details. Mass balance parameters clarified (see operation basis). Release media clarified for container residue (uncertain due to unknown drum reconditioner operations) and equipment cleaning (off-site incineration only). PMN is an excess reactant, but all excess PMN is removed from product and released as a waste to off-site incineration. MSDS notes updated.

POLLUTION PREVENTION CONSIDERATIONS: N one.

P2 REC:

EXPOSURE-BASED REVIEW: N o (0 criteria met)P-09-0634

PROC/USE: Chemical intermediate

Number of Sites/Location: 1 submitter site(s) FUJIFILM Hunt Chemicals USA, Inc Dayton TN 37321 Basis: Per submission, 1 site, 1400 kg/bt, 24 hr/bt, 80 bt/yr. This does not equate to the PV of 47,000 kg/yr. Technical contact indicates 1400 kg/bt is product not PMN. Correct PMN batch size is 1344 lb/bt (or 610.9 kg/bt). This value was used to calculate the number of batches (77 bt/yr) Process Description: Imported (100% liquid, drums) --> charge to Reactor B via dip tube with other ingredients --> perform 3 phase cuts of aqueous phase of product --> destroyed (reacted to form another intermediate used for photographic chemical)


## 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. Water - assessed based on uncertainty. Incineration - expected per submission, also assessed based on uncertainty. Landfill - assessed based on uncertainty (note drinking water concern and migration to groundwater is not negligible). Air - expected to be negligible (<0.54 kg/site-day), but assessed to obtain vapor generation rates.

Air Typical: 2.0E-5 kg/site-day over 77 day/yr from 1 sites or 1.5E-3 kg/y r Worst Case: 4.0E-5 kg/site-day over 77 day/yr from 1 sites or kg/y r to: Air from: Unloading Liquid Raw Material from Drums basis: EPA/OAQPS AP-42 Loading Model.

Water or Incineration or Landfill High End: 1.8E+1 kg/site-day over 77 day/yr from 1 sites or 1.4E+3 kg/y r to: Uncertain from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. Submission did not estimate drum residual release. Technical contact indicates empty, plastic, 55-gal drums are sent to a drum reconditioner. CEB assesses std. 3% loss, release to water, incineration, or landfill based on uncertainty (drum reconditioner operations unknown).

Incineration Conservative: 6.1E+0 kg/site-day over 77 day/yr from 1 sites or 4.7E+2 kg/y r to: Off-site incineration (technical contact) from: Equipment Cleaning Losses of Liquids from a Single, Large Vessel basis: EPA/OPPT Single Vessel Residual Model, CEB standard 1% residual. Submission did not provide equipment cleaning release estimate. Technical contact indicates all waste from the process is sent to off-site incineration. CEB assesses std. 1% release for single vessel (PMN only charged to reactor B).

Incineration Output 2: 3.0E+0 kg/site-day over 77 day/yr from 1 sites or 2.3E+2 kg/y r to: Off-site incineration (submission) from: Aqueous Phase Cuts in Reactor B basis: User-Defined Loss Rate Model. Submission estimates 3 kg/bt released to off-site incineration from the disposal of the aqueous phase cuts. Technical contact indicates this release accounts for excess PMN reactant.Air Output 2: 6.6E-7 kg/site-day over 77 day/yr from 1 sites or 5.1E-5 kg/y r to: Air from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: EPA/OPPT Penetration Model.

Air Output 2: 8.6E-4 kg/site-day over 77 day/yr from 1 sites or 6.6E-2 kg/y r to: Air from: Equipment Cleaning Losses of Liquids from a Single, Large Vessel basis: EPA/OPPT Mass Transfer Coefficient Model.



## RELEASE TOTAL 2100 kg/y r - all sites



## OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 12 Basis: Per submission, 12 workers exposed during unloading activities.

Dermal:

Exposure to Liquid High End: 1.8E+3 mg/day over 77 days/y r Number of workers (all sites) with Dermal exposure: 12 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

Inhalation:

Exposure to Vapor Typical: 5.7E-1 mg/day over 77 days/y r Worst Case: 9.5E-3 mg/day over 77 days/y r Number of workers (all sites) with Inhalation exposure: 12 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT Mass Balance Model.



## 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? N o (b) Hazard Rating for health of 2 or greater? N o Inhalation Monitoring Data Desired? N o

# A-003 Initial Review Exposure Report

for PMN P-09-63410/7/09 Page of

INITIAL REVIEW EXPOSU RE REPORT (IRExR)

Chemical ID: P090634 Reviewer: Kwon

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=1 PDM Days Exceeded 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 μ g/l # Days mg/kg/day mg/kg/day mg/kg/day mg/kg/day mg/kg/day PROC/USE: max ADR, LADD, PDM/acute eco. 0.12 4.49E-04 7.51E-02 2.95E-04 2553.60 77 2.89E-04 --- --- --- ---

1 Exposure scenario titles consist of release activ ity followed by exposure calculation abbreviation.
2 Release activities are from engineering report's Manufactur ing (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 streamflow of the 7 consecutive days of lowest flow within a 10 year period.

Remarks:

Fate test recommendations: (default is NA)10/7/09 Page of

INITIAL REVIEW EXPOSURE REPORT

Chemical ID: P090634 Assessor: Kwon

ENVIRONMENTAL RELEASES

Scenario#:1 Number of Release Sites: 1. Release Activity: PROC/USE: max ADR, LADD, PDM/acute eco.
Release Description: WATER LANDFILL Non-sludge/Sludge STACK FUGITIVE

Total Releases: 1386.00 1386.00 N/A N/A
(kg/yr) (kg/yr) (kg/yr) (kg/yr)

Non-sludge/Sludge
Release Days/yr: 77.00 1.00/0.00 N/A N/A

Per Site Release: 18.00 1386.00/0.00 N/A N/A
(kg/site/day) (kg/site/day) (kg/site/day) (kg/site/day)

Remarks:10/7/09 Page of

INITIAL REVIEW EX POSURE REPORT

Chemical ID: P090634

SIC-CODE BASED HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES

SCENARIO #: 1 Number of Sites: 1 RELEASE ACTIVITY:PROC/USE: max ADR, LADD, PDM/acute eco.
SIC-CODE DESCRIPTION: Orga nic Chemicals Manufacture
SIC-CODE (S): 2865,2869 EXPOSED POPULATION: Adult

WWT REMOVAL (%) RELEASE DAYS PRETREATMENT RELEASE (kg/site/day) POSTTREATMENT RELEASE (kg/site/day) DWT (%) BCF (L/kg)

23.25 77. 18. 13.81 0.00 153.00

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER

PLANT TYPE % ILE FACILITY STREAM FLOW (MLD) STREAM CONC. ( μ g/l)

Harmonic

Mean 30Q5 7Q10 1Q10 Harmonic Mean 30Q5 7Q10 1Q10

ALL 50 2825.61 935.49 634.16 514.20 4.89 14.77 21.78 26.87

ALL 10 50.57 9.38 5.41 4.53 273.19 1472.81 2553.60 3049.67

DRINKING WATER AND FISH IN GESTION EXPOSURE ESTIMATES

Exposure Units Drinking Water Results Drinking Water Units Fish Ingestion Results Fish Ingestion

Units
50% 10% 50% 10%

Cancer

LADD pot 8.04E-06 4.49E-04 mg/kg/day 5.27E-06 2.95E-04 mg/kg/day

LADC pot 4.13E-04 2.31E-02 mg/L 6.31E-02 3.53 mg/kg

Acute

ADR pot 1.23E-03 0.12 mg/kg/day 1.34E-03 7.51E-02 mg/kg/day

SIC Code Comments:10/7/09 Page of

INITIAL REVIEW EX POSURE REPORT

Chemical ID: P090634

SIC CODE EXPOSURES TO SURFACE WATER RELEASES

SCENARIO #: 1 RELEASE ACTIVITY: PROC /USE: max ADR, LADD, PDM/acute eco.
SIC CODE DESCRIPTION: Orga nic Chemicals Manufacture
ASSOCIATED SIC CODES: 2865,2869

SIC CODE RESULTS

COC ( μ g/L) Percent of Year COC Exceeded Number of Days COC Exceeded Release days/year Loading (kg/site/day) Waste Water Treatment (%) High/Avg Analysis

1.00 21 77 77.00 18.00 23.25 High

Remarks: COC exceeded for > 20 days.10/7/09 Page of

INITIAL EXPOSURE REVIEW REPORT Chemical ID: P090634

DRINKING WATER EXPOSURE ESTIMATES FROM LANDFILL RELEASES

SCENARIO #: 1 ACTIVITY: PROC/USE: max ADR, LADD, PDM/acute eco.

RELEASE DESCRIPTION:

EXPOSED POPULATION: Adult

NUMBER OF SITES NON-SLUDGE LANDFILL RELEASE AND DAYS OF RELEASE (kg/site/day)/(days) LANDFILLED SLUDGE 1
AND DAYS OF RELEASE (kg/site/day)/(days) MIGRATION DESCRIPTOR 2 ADSORPTION TO WASTEWATER SLUDGE (%) DRINKING WATER TREATMENT (%)

1. 1386.00/1.00 0.00/0.00 Slow 0.00 0.00

1 Landfilled sludge equals the fraction adsorbed to wastewater treatment sludge times the surface water pre-treatment release.

2 Migration Descriptor Log Koc Groundwater Concentration (GWC) (mg/L per kg release) Negligible no migration None Negligible to slow > 4.5 3.21E-6 Slow <4.5 to 3.5 2.67E-5 Moderate <3.5 to 2.5 5.95E-5 Rapid <2.5 7.55E-5

ASSUMPTIONS Exposure Units Results ED (years) AT (years) BW (kg) IR (L/day)
Cancer
LADD pot (mg/kg/day) 2.89E-04 30.00 75.00 71.80 1.40
LADC pot (mg/L) 1.48E-02 30.00 75.00 NA NA

REMARKS:10/7/09 Page of



## LEGEND FOR NEW CHEMICAL S EXPOSURE REPORT

This new chemicals exposure report wa s 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 calcula te 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 abbreviati ons on the Release Activity line, e.g., (1) max ADR , (2) max LADD , (3) max PDM . Depending on the release inputs, these e ndpoints 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 cal culated 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 proce ssing 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 dir ects 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) chemical s of P2B2 rating or hi gher 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 th at are also health or eco concerns are bolded.