Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-10-554 

EPA Docket EPA-HQ-OPPT-2011-0577 

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Index

A-001 Structure Activity Team (SAT) Report for 

PMN P-10-554 

A-002 Initial Review Engineering Report for 

PMN P-10-554 

A-003 Initial Review Exposure Report for 

PMN P-10-554 

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A-001 

Structure Activity Team (SAT) Report

for PMN P-10-554 

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A-002 

Initial Review Engineering Report

for PMN P-10-554 

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TEST DATA REVIEW ENGINEERING REPORT

P-10-0554

Post-Focus Draft Revision 1 1/13/2011

ENGINEER: Hall \ JAS

PV (kg/yr): 

Revision Notes/Assessment Overview: The submitter has provided new information (fax dated December 16, 

2010) regarding disposal practices and site information.

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, 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 list of the specific components that 

may be present in the PMN material. Estimated data 

 Estimated data 

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-10-0554

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: 

Typical:

Worst Case: 

to: 

from:

basis:

Output 2: 

to:

from:

basis:

Conservative:

to: 

from:

basis:

Output 2: 

to: 

from:

basis:

RELEASE TOTAL

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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-10-0554

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.

Typical:

Worst Case: 

to: 

from:

basis:

High End: 

to: 

from:

basis:

Output 2: 

to:

from:

basis:

Conservative:

to: 

from:

basis:

Output 2: 

to: 

from:

basis:

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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? 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-10-554 

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Date 1/21/11 

POST FOCUS EXPOSURE REPORT 

Summary Page 

Chemical ID: P-10-0554 Reviewer: Delpire 

Endpoints-Assessed Table 

Endpoints/Assessment 

Cycles1

Releases

Assessed

in

NCEM2? 

Reasons for not assessing releases 

No XB 

Testing

Required

No

Hazard

Concern

No

Releases

Release

Below

Acute

Threshold5

Release

Below

Chronic

Threshold5

Other

Ingestion

 Surface water No 

 Ground water (landfill) No 

 Consumer Use: DtD2 No

Inhalation

 Air: incineration (stack) No 

 Air: fugitive No

 Consumer Use: CEM3 No

Dermal 

 Consumer Use: CEM No 

Eco

 Surface water: ADR 

conc and/or PDM4

No

 Consumer Use: DtD No

1

Assessment cycles are endpoint concentrations and dose calculations within the NCEM2 model. 

2

Down-the-Drain

3

Consumer Exposure Model 

4

Probabilistic Dilution Model 

5

The threshold values for assessing endpoints are 1 mg/day for acute doses and 1 mg/year for chronic doses. 

EAB DROP: Release information for this compound does not meet criteria for preparation of an exposure 

assessment in the Exposure Assessment Branch=s (EAB) Initial Review Exposure Report (this report). 

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