## Support Documents for

Significant New Us e Rule (SNUR) on

Premanufacture Notice (PMN)

P-10-424

EPA Docket EPA

- HQ

- OPPT -2011-0577

## Index

A-001 Structure Activity Team (SAT) Report for

PMN P-10-424

A-002 Initial Review Engineering Report for

PMN P-10-424

A-003 Initial Review Exposure Report for

PMN P-10-424

## A-001

Structure Activity Team (SAT) Report

for PMN P-10-424

## A-002

Initial Review Engineering Report

for PMN P-10-424TEST DATA REVIEW ENGINEERING REPORT

P-10-0424

Post-Focus Draft Revision 1 12/3/2010

ENGINEER: Choudhary \ DDH

PV (kg/yr):

Revision Notes/Assessment Overview:

SUBMITTER:

USE:

OTHER USES:

MSDS: N o LABEL : N o

CRSS: (6/28/2010):

Chemical Name:

S-H2O: 0.0015 g/L @

VP: 1.0E-6 torr @

MW: 10000 0.0%<500 0.0%<1000

Physical State and Misc CRSS Info:

Neat: Mfg:

Proc/Form: End Use:

The MW depends on the particle size; the estimated MW

above is based upon the PMN material The submitter provided the following composition

for the PMN material: The

submitter provided additional details on the anticipated production volume in attachment 3 to the PMN submission.

Submitted data: density = 5.43 g/cc; Estimated data: negligible VP

(salt); WS < 0.0015 g/L (

Consumer Use: N o

SAT (concerns): (6/29/2010):

Migration to groundwater: N egligible

PBT rating: P 3 B 1 T 1

Health: 2, Inhalation

Eco: 1, N o releases to Water

OCCUPATIONAL EXPOSURE RATING: 2B

NOTES & KEY ASSUMPTIONS:

Generated by the 06/07/2005 version of ChemSTEER. The technical contact was called; see contact report. //POLLUTION PREVENTION CONSIDERATIONS:

P2 Claim from Optional Pollution Prevention Information PMN page 11 of the submission:

P2 REC:

EXPOSURE -BASED REVIEW:P-10-0424

Manufacturing/Use 1:

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.

Output 2:

to:

from:

basis:

Output 2:

to :

from:

basis:

Output 2:

to :

from:

basis:

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:

Dermal:

Exposure

High End: 3.1E+3 mg/day

Number of workers (all sites) with Dermal exposure :

Basis:

Inhalation:

Exposure to

Submitter Data: 1.3E+0 mg /day

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): N o

2) (a) Exposure level > 1 mg/day? Yes

(b) Hazard Rating for health of 2 or greater? N o

Inhalation Monitoring Data Desired? N oP-10-0424

Manufacturing/Use 2:

Number of Sites/Location:

Basis:

Process Description:

Roll Coating operation:



### 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.

Output 2

to:

from:

basis:

Output 2

to:

from:

basis:

Output 2:

to:

from:

basis:

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:

Dermal:

Exposure to

High End:

Number of workers (all sites) with Dermal exposure:

Basis:

Inhalation :

Exposure to

Submitter Data

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): N o

2) (a) Exposure level > 1 mg/day? Yes

(b) Hazard Rating for health of 2 or greater? N o

Inhalation Monitoring Data Desired? N oP-10-0424

Manufacturing/Use 3:

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.

Output 2:

to:

from:

basis:

Output 2:

to:

from:

basis:

Output 2:

to:

from:

basis:

Output 2:

to:

from:

basis:

Output 2to:

from:

basis:

Output 2:

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

Submitter Data:

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): N o

2) (a) Exposure level > 1 mg/day? Yes

(b) Hazard Rating for health of 2 or greater? N o

Inhalation Monitoring Data Desired? N oP-10-0424

Manufacturing/Use 3:

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.

Output 2

to:

from:

basis:

Output 2:

to:

from:

basis:

Output 2:

to :

from:

basis:

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:

Dermal:

Exposure to

High End

Number of workers (all sites) with Dermal exposure:

Basis:

Inhalation :

Exposure to

Submitter Data:

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): N o

2) (a) Exposure level > 1 mg/day? Yes

(b) Hazard Rating for health of 2 or greater? N o

Inhalation Monitoring Data Desired? N oP-10-0424

Manufacturing/Use 1:

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.

Output 2:

to:

from:

basis:

Output 2:

to :

from:

basis:

Output 2:

to :

from:

basis:

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:

Dermal:

Exposure to

High End

Number of workers (all sites) with Dermal exposure:

Basis:

Inhalation :

Exposure to

Submitter Data:

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): N o

2) (a) Exposure level > 1 mg/day? Yes

(b) Hazard Rating for health of 2 or greater? N o

Inhalation Monitoring Data Desired? N oP-10-0424

Manufacturing/Use 2:

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.

Output 2:

to:

from:

basis:

Output 2:

to:

from:

basis:

Output 2

to:

from:

basis:

Output 2:

to:

from:

basis:Output 2:

to:

from:

basis:

Destroyed

Output 2:

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

Submitter Data:

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): N o

2) (a) Exposure level > 1 mg/day? Yes

(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-10-42412/15/10 page of

POST FOCUS EXPOSURE REPORT

Chemical ID: P-10-0424 Reviewer: Delpire/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 = PDM

Days

Exceede

d LADD ADR LADD ADR LADD

Release

activity(ies) 2 ;

exposure

calculation(s) 3 mg/kg/day m g/kg/day mg/kg/day mg/kg/day μg/l # Days mg/kg/day m g/kg/day mg/kg/day m g/kg/day mg/kg/day

MFG/USE2: Max

ADR

MFG/USE3: Max

ADR

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). Th ere 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:12/15/10 page of

POST FOCUS EXPOSURE REPORT

Chemical ID: P-10-0424 Assessor: Delpire/SS

ENVIRONMENTAL RELEASES

Scenario#:1 Number of Release Sites:

Release Activity: MFG/USE2: Max ADR

Release Description: WATER LANDFILL

Non-sludge/Sludge STACK FUGITIVE

Total Releases:

(k g/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:12/15/10 page of

POST FOCUS EXPOSURE REPORT

Chemical ID: P-10-042412/15/10 page of12/15/10 page of

POST FOCUS EXPOSURE REPORT

Chemical ID: P-10-0424 Assessor: Delpire/SS

ENVIRONMENTAL RELEASES

Scenario#:2 Number of Release Sites:

Release Activity: MFG/USE3: Max ADR

Release Description: WATER LANDFILL

Non-sludge/Sludge STACK FUGITIVE

Total Releases:

(k g/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:12/15/10 page of

POST FOCUS EXPOSURE REPORT

Chemical ID: P-10-042412/15/10 page of