Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-09-634 

EPA Docket EPA-HQ-OPPT-2010-1075 

 

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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 

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A-001 

Structure Activity Team (SAT) Report 

 for PMN P-09-634 

 

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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: No

Ecotox: No

Routes of exposure: Health: Dermal Drinking Water Inhalation 

Ecotox: All releases to water

Fate: ;

Keywords:

 Keywords: 

IRR-E,S

NEURO

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); 

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S = 48.7 mg/L at 25 EC (E)

VP = 6.2E-3 torr at 25 EC (NOMO5)

BP = 271 EC (NOMO5) 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;

Not 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)

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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);

Not 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 

= phenol; MW 318; log Kow = 3.82 (EPI); solid with mp = 29 C (M); pH7; 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 

(ppb)

1

SARs phenols

SAR Class phenol

Ecotox Factors Comments: 

 SAT Chair: J. Kwiat

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A-002 

Initial Review Engineering Report 

 for PMN P-09-634 

 

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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: No

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: - None 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: NK - Import

Proc/Form: NA 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. NOMO5 

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: No

SAT (concerns): (9/29/2009):

Related Cases and Misc SAT Info:

.

Migration to groundwater:

PBT rating: P1 B1 T2

Health: 2, Dermal, Drinking Water, Inhalation

Eco: 3, Water (All releases to water with a CC = 1 ppb)

OCCUPATIONAL EXPOSURE RATING: 1-2B

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NOTES & KEY ASSUMPTIONS:

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

None.

P2 REC:

EXPOSURE-BASED REVIEW: No (0 criteria met)

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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/yr

Worst Case: 4.0E-5 kg/site-day over 77 day/yr from 1 sites or kg/yr

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/yr

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/yr

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/yr

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.

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Air

Output 2: 6.6E-7 kg/site-day over 77 day/yr from 1 sites or 5.1E-5 kg/yr

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/yr

to: Air

from: Equipment Cleaning Losses of Liquids from a Single, Large Vessel

basis: EPA/OPPT Mass Transfer Coefficient Model.

RELEASE TOTAL

2100 kg/yr - 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/yr

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/yr

Worst Case: 9.5E-3 mg/day over 77 days/yr

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? No

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

Inhalation Monitoring Data Desired? No

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A-003 

Initial Review Exposure Report 

 for PMN P-09-634 

 

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10/7/09 Page of 

INITIAL REVIEW EXPOSURE REPORT (IRExR) 

 Chemical ID: P090634 Reviewer: Kwon 

 

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=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 μg/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 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 streamflow of 

the 7 consecutive days of lowest flow within a 10 year period. 

Remarks: 

Fate test recommendations: (default is NA) 

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 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: 

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INITIAL REVIEW EXPOSURE 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: Organic 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. (μg/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 INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water Results Drinking 

Water Units Fish Ingestion Results 

Fish 

Ingestion 

Units 

50% 10% 50% 10% 

Cancer 

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

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

Acute 

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

SIC Code Comments: 

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10/7/09 Page of 

INITIAL REVIEW EXPOSURE 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: Organic Chemicals Manufacture 

ASSOCIATED SIC CODES: 2865,2869 

SIC CODE RESULTS 

COC (μg/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.

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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 

SLUDGE1 

AND DAYS OF 

RELEASE 

(kg/site/day)/(days)

MIGRATION 

DESCRIPTOR2

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 

LADDpot (mg/kg/day) 2.89E-04 30.00 75.00 71.80 1.40 

LADCpot (mg/L) 1.48E-02 30.00 75.00 NA NA 

REMARKS: 

 

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10/7/09 Page of 

LEGEND FOR NEW CHEMICALS EXPOSURE REPORT 

This new chemicals exposure report was 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 calculate 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 abbreviations on the Release Activity line, e.g., (1) max ADR, (2) max 

LADD, (3) max PDM. Depending on the release inputs, these endpoints 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 calculated 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 processing 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 directs 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) chemicals of P2B2 rating or higher 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 that are also health or eco concerns are bolded. 

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