Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-10-550 

EPA Docket EPA-HQ-OPPT-2011-0577 

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Index

A-001 Structure 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 

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A-001 

Structure Activity Team (SAT) Report

for PMN P-10-550 

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A-002 

Initial Review Engineering Report

for PMN P-10-550 

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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: No

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: None 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: No

SAT (concerns): (9/24/2010):

Migration to groundwater: Negligible

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PBT rating: P1 B1 T1

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: 

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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:

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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? No

Inhalation Monitoring Data Desired? No

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? No

Inhalation Monitoring Data Desired? No

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P-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:

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A-003 

Initial Review Exposure Report

for PMN P-10-550 

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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:

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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

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