# Support Documents for

Significant New Use Rule (SNUR) on

Premanufacture Notice (PMN)

P-07-351

EPA Docket EPA

- HQ

- OPPT -2011-0577

# Index

A-001 Structure Activity Team (SAT) Report for

PMN P-07-351

A-002 Initial Review Engineering Report for

PMN P-07-351

A-003 Initial Review Exposure Report for

PMN P-07-351

# A-001

Structure Activity Team (SAT) Report

for PMN P-07-351

# A-002

Initial Review Engineering Report

for PMN P-07-351P07-0351 ETD IRER.EN1.txt

INITIAL REVIEW ENGINEERING REPORT

PMN: 07-0351

Post-Focus Draft Revision 1 6/28/2007

ENGINEER: Austin \ DTN

PV (kg/yr):

SUBMITTER:

USE:

OTHER USES:

MSDS: Yes Label: No

Gen Eqpt: local exhaust at generation points; chem.

worker goggles; natrual rubber or nitrile rubber gloves.

Respirator: any dust, mist or fume respirator except

single use or disposable respirator or appropriate

particle filter as defined in 42 CFR 84 depending on the

potential for the presensce of oil particle in air and

the filter eficiency neeed.

Health Effects: may cause eye irritation, harmful if

swallowed.

TLV/PEL:

not established.

CRSS (04/16/2017):

Chemical Name:

S-H20: 0.000003 g/L @

VP: 1.0E-6 torr @

MW: 318.42 %<500 %<1000 Physical State and Misc CRSS Info:

Neat: Solid Mfg: Proc/Form:

End Use:

Submitted data: The PMN material is

a solid with a MP = 170-173 °C by DSC. The PMN material

loses 94% of its mass between 200-380 °C as determined by

TGA. The submitter does not indicate if this is boiling

or decomposition. The DSC measurement does not reach a

high enough temperature to tell the difference. The

submitted IR, 1HNMR, and mass spectra are in agreement

with the structure provided. A UV spectrum was submitted.

Estimated data: With an input MP = 170 °C, EPI estimated

the following data for the PMN material: BP = 425 °C, VP

= 6.36e-8 torr, WS = 2.9e-3 mg/L, log P = 6.66. As listed

in the prop field in File Registry on STN, ACD labs

estimated the following data for the PMN material: BP =

467.2 °C, VP = 1.86E-08 torr, WS = 0.0010 g/L, log P = 6.

28.

Page 1P07-0351 ETD IRER.EN1.txt

Consumer Use:

SAT (concerns) (04/17/2007):

Migration to groundwater: Negligible

PBT rating: P2B3T1

Health: 1 Not Required

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

OCCUPATIONAL EXPOSURE RATING: 2-3B

NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER.

POLLUTION PREVENTION CONSIDERATIONS:

None.

EXPOSURE-BASED REVIEW:

INITIAL REVIEW ENGINEERING REPORT

PMN: 07-0351

MFR

Number of Sites/ Location:

Days/yr:

Basis: Per submission,

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:

Page 2P07-0351 ETD IRER.EN1.txt

n Output 2:

to:

from:

basis:

Conservative:

to:

from:

basis:

RELEASE TOTAL

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

Basis:

Inhalation:

Exposure to Upper Bound:

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

OR b) Hazard Rating for health of 2 or greater? 1 No

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Exposure to High End:

Number of workers (all sites) with dermal exposure:

Basis:

Page 3P07-0351 ETD IRER.EN1.txt

INITIAL REVIEW ENGINEERING REPORT

PMN: 07-0351

PROC1:

Number of Sites/ Location:

Days/yr:

Basis: Per submission,

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:

Conservative:

to:

from:

basis:

RELEASE TOTAL

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

Page 4P07-0351 ETD IRER.EN1.txt

Basis:

Inhalation:

negligible (VP < 0.001 torr )

Exposure to Upper Bound:

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

OR b) Hazard Rating for health of 2 or greater? 1 No

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Exposure to High End:

Number of workers (all sites) with dermal exposure:

Basis:

Exposure to High End:

Number of workers (all sites) with dermal exposure:

Basis:

Exposure to High End:

Number of workers (all sites) with dermal exposure:

Basis:

INITIAL REVIEW ENGINEERING REPORT

PMN: 07-0351

PROC2:

Number of Sites/ Location:

Days/yr:

Basis: Per submission,

Process Description:

Page 5P07-0351 ETD IRER.EN1.txt

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: Incineration

from:

basis:

Conservative:

to:

from:

basis:

Output 2:

to:

from:

basis:

High End:

to:

from:

basis:

RELEASE TOTAL

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

Basis:

Inhalation:

negligible (VP < 0.001 torr )

Dermal:

Page 6P07-0351 ETD IRER.EN1.txt

Exposure to High End:

Number of workers (all sites) with dermal exposure:

Basis:

Exposure to High End:

Number of workers (all sites) with dermal exposure:

Basis:

Page 7

# A-003

Initial Revi ew Exposure Report

for PMN P-07-351