# Support Documents for Significant New Use Rule (SNUR) on Premanufacture Notice (PMN) P-10-550

EPA Docket EPA - HQ - OPPT -2011-0577

# Index A-001 Stru cture Activity Team (SAT) Report for PMN P-10-550 A-002 Initial Review Engineering Report for PMN P-10-550 A-003 Initial Review Exposure Report for PMN P-10-550

# A-001 Structure Activity Team (SAT) Report for PMN P-10-550

# A-002 Initial Review Engi neering Report for PMN P-10-550

### INITIAL REVIEW ENGINEERING REPORT P-10-0550 Focus Ready Draft 9/30/2010 ENGINEER: Hall \ JAS PV (kg/yr): Revision Notes/Assessment Overview: SUBMITTER: USE:

OTHER USES:

MSDS: Yes LABEL : N o Gen Eqpt: Impervious gloves recommended / safety glasses with side shields or chemical goggles / good general room ventilation should be adequate under normal conditions. If use generates significant airborne vapor or mist, mechanical ventilation such as local exhaust may be needed / impervious clothing as needed to avoid skin contact. Respirator: N one needed with adequate ventilation. If the occupational exposure limit is exceeded, use an approved respirator with an organic vapor cartridge or a supplied air respirator. Selection of respiratory protection depends on the contaminant type, form and concentration Select in accordance with OSHA 1910.134 or other applicable regulations and good Industrial Hygiene practice. Health Effects: May cause eye and skin irritation / Inhalation of vapors or mists may cause respiratory irritation, headache and nausea / May be harmful if swallowed. TLV/PEL : - none established. CRSS: (9/23/2010): Chemical Name: S-H2O: 0.024 g/L @ VP: MW: 184 0.0%<500 0.0%<1000 Physical State and Misc CRSS Info: Neat: Mfg: Proc/Form: End Use: . The molecular formula and molecular weight are given for the low weight material, . For the structures drawn, Estimates for the low weight and representative high weight components are given below. Submitted data: The submitter provided estimated data: See page 6 for a description of the compounds that are expected to be present in the PMN material. Estimated data
water sol. 1.5 E-05 mg/L. Consumer Use: N o SAT (concerns): (9/24/2010): Migration to groundwater: N egligiblePBT rating: P 1 B 1 T 1 Health: 1-2, Inhalation Eco: 3, Water (All releases to water with a CC = 8 ppb.) OCCUPATIONAL EXPOSURE RATING: 2-3B NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER.

POLLUTION PREVENTION CONSIDERATIONS: P2 Claim:

P2 REC: EXPOSURE-BASED REVIEW:P-10-0550
Manufacturing: 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. In addition to the releases assessed below, the submission estimates:

Output 2: to: from: basis:

Conservative : to: from: basis:

Output 2: to: from: basis:

Typical: Worst Case: to: from: basis:
Deepwell Injection Output 2: to: from:basis:



## RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: Basis:

Inhalation: Exposure to Worst Case: Typical: 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? Yes (b) Hazard Rating for health of 2 or greater? N o Inhalation Monitoring Data Desired? N o Inhalation: Exposure to Worst Case: Typical: 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? Yes (b) Hazard Rating for health of 2 or greater? N o Inhalation Monitoring Data Desired? N oP-10-0550

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.



## RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: Basis:

# A-003 Initial Review Exposure Report for PMN P-10-550

# Exposure Report
PMN No. P-10-0550 Report Status: Status Date: 09/29/2010 Exposure Specialist : Flessner/SD Drop Criteria:

Drop Criteria: EAB Drop Criteria Reasoning:

Uses:

Engineering Use:

Other Uses:

Ratings and Concerns: Health Concerns: Inhalation Override Health Tesing: Eco Concerns: Water All releases to water with a CC = 8 ppb. Override Eco: 1
P B Rates 1; 1 Most recent CoC value: 8 Health Rating: 1 2 Eco Rating: 3 Non Occupational: NR Environmental: NR Production Volume: 776000 CRSS Descriptor:

Persistence Bioaccumulation Toxicity PBT Comments (1) 1 (1) 1 (1) 1 (2) (2) (2) (3) (3) (3) (3) (4) (4) (4) (4) (5) (5) (5) (5)

Consumer Use:

Consumer Use? Yes No

Releases:Scenario 1. Scenario 2. Scenario 3. Release 4. Release 5. Release 6. Release 7. Release

Recalc Table Water landfill (non-sludge) stack fugitive Max/site over scenarios (chronic doses inputs) Total over scenarios by medium (water is YX table value) Maximum possible total (sum of maximum scenario releases, YX table total)

Exposure Based Information/PBT Review:

Exposure Based Review (Health): Exposure Based Review (Eco): Exposure Based (Non-Occupational)? Exposure Based (Environmental)? Exposure Based (PBT)? Exposure Parameter Exposure-Based Persistent/Bioaccum Exposure Value Surface DW: Yes No Yes No Fish Ingestion: Yes No Yes No Ground DW: Yes No Yes No Inhalation: Yes No Yes No Water Releases: Yes No Yes No Total Releases: Yes No Yes No Consumer Exposure: Yes No Yes No

Attachments

Initial Review Reports