# Support Documents for Significant New Use Rule (SNUR) on Premanufacture Notice (PMN) P-10-554

EPA Docket EPA
- HQ
- OPPT -2011-0577

# Index A-001 Stru cture 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

# A-001 Structure Activity Team (SAT) Report for PMN P-10-554

# A-002 Initial Review Engi neering Report for PMN P-10-554

### 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 : 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, 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: 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-10-0554

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

## 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-10-0554

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:

## 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? N o (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-10-554Date 1/21/11 

### POST FOCUS EXPOSURE REPORT Summary Page

Chemical ID: P-10-0554 Reviewer: Delpire

Endpoints-Assessed Table

Endpoints/Assessment Cycles 1 Releases Assessed in NCEM2? Reasons for not assessing releases No XB Testing Required No Hazard Concern No Releases Release Below Acute Threshold 5 Release Below Chronic Threshold 5 Other
Ingestion Surface water No Ground water (landfill) No Consumer Use: DtD 2 No Inhalation Air: incineration (stack) No Air: fugitive No Consumer Use: CEM 3 No Dermal Consumer Use: CEM No Eco Surface water: ADR conc and/or PDM 4 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).