Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-10-88 

EPA Docket EPA-HQ-OPPT-2011-0577 

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Index

A-001 Structure Activity Team (SAT) Report for 

PMN P-10-88 

A-002 Initial Review Engineering Report for 

PMN P-10-88 

A-003 Initial Review Exposure Report for 

PMN P-10-88 

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A-001 

Structure Activity Team (SAT) Report

for PMN P-10-88 

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A-002 

Initial Review Engineering Report

for PMN P-10-88 

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Support - P-10-0088 engineering.2.txt

INITIAL REVIEW ENGINEERING REPORT 

PMN: 10-0088

Post-Focus Draft Revision 1 2/3/2010

ENGINEER: Avcin \ DDH

PV (kg/yr): 

SUBMITTER: FRX Polymers, Inc.

USE:

OTHER USES: None found.

MSDS: Yes Label: No

Gen Eqpt: heat resistant gloves when handling molten

material/ safety glasses with side shields or chemical

goggles/ when handling molten material, wear face shield

with chemical resistant goggles/ local exhaust is

recommended

Respirator: follow OSHA respirator regulations/ wear a

NIOSH approved respirator

Health Effects: eye contact with dusts may cause

mechanical irritation/ for dermal contact, no absoption

hazard when used normally/ gases and fumes evolved during

the thermal processing or decomposition may irritate the

respiratory tract

TLV/PEL:

none established.

CRSS :

Chemical Name:

S-H20: 0.000001 g/L @

VP: 1.0E-6 torr @

MW: 10000.00 0.00%<500 0.77%<1000

Physical State and Misc CRSS Info:

Neat: Solid (Yellow) Mfg: NK: Imported Proc/Form: Solid:

 End Use: Solid:

 Submitted data: NAVG MW =

10000 with 0% less than 500 and 0.766% less than 1000

(submitted GPC NAVG MW = 24090); clear, yellow solid; MP

= 220-250°C; softening point = 120°C; insoluble in water.

 The submitted TGA shows loss of mass starting at 405°C,

and accelerating above 450°C; the submitted DSC shows a

glass transition/softening point at 131°C. The submitted

1H NMR spectra is consistent with the structure provided.

GC-MS spectra of residual monomers and recovered phenol,

and MS analysis of cyclic dimer are provided. Water

solubility testing showed 0.39 mg of the substance

dissolved in 100 ml water (= 0.0039 g/L); this is most

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Support - P-10-0088 engineering.2.txt

likely residual monomer/phenol. Cont'd on p.6.

Consumer Use: No

SAT (concerns) (12/08/2009):

Migration to groundwater: Negligible

PBT rating: P3B1T1

Health: 1-2 Inhalation, 

Eco: 1 No releases to Water, 

desired)

OCCUPATIONAL EXPOSURE RATING: 1C

NOTES & KEY ASSUMPTIONS:

Generated by the 06/07/2005 version of ChemSTEER. 

 

 

 

 

 

POLLUTION PREVENTION CONSIDERATIONS:

P2REC: CRSS: Forward. P2 Claim:

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EXPOSURE-BASED REVIEW: 

INITIAL REVIEW ENGINEERING REPORT 

PMN: 10-0088

Use: 

Number of Sites/ Location: 

 

 

 

 

 

 

Days/yr: 

Basis:

Process Description:

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Support - P-10-0088 engineering.2.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. Note: migration is negl, per SAT.

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: 

Basis:

Inhalation:

Dermal:

not required per SAT.

Exposure to 

High End: 

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Number of workers (all sites) with dermal exposure: 

Basis: 

Containers;

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A-003 

Initial Review Exposure Report

for PMN P-10-88 

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