# Support Docu ments for

Significant New Use Rule (SNUR) on

Premanufacture Notice (PMN)

P-09-546

EPA Docket EPA

- HQ

- OPPT -2011-0577

# Index

A-001 Structure Activity Team (SAT) Report for

PMN P-09-546

A-002 Initial Review Engineering Report for

PMN P-09-546

A-003 Initial Review Exposure Report for

PMN P-09-546

# A-001

Structure Activity Team (SAT) Report

for PMN P-09-546

# A-002

Initial Review Engineering Report

for PMN P-09-546Support - P-09-0546 Engineering.2.txt

INITIAL REVIEW ENGINEERING REPORT

PMN: 09-0546

Post-Focus Draft Revision 2 3/1/2011

ENGINEER: Arnold \ CPW\CLM

PV (kg/yr):

Revision Notes / Assessment Overview: Updated to reflect

10/6/2010 amendment from submitter. --

SUBMITTER:

USE:

OTHER USES:

MSDS: Yes Label: No

Gen Eqpt: Use only in chemical fume hood. Additional

ventilation or exhaust may be required to maintain air

concentrations below recommended exposure limits. /

chemical protective gloves if contact with chemical may

occur/ safety glasses or goggles/ coveralls, apron, boots

Respirator: Under normal use conditions, respirator is

not usually required. Use NIOSH/MSHA approved disposable

dust/mist mask if recommended exposure limit is exceeded.

Health Effects: harmful if inhaled/ harmful if absorbed

through skin/ may be harmful if swallowed/ may cause

allergic skin reaction

TLV/PEL:

none established

CRSS :

Chemical Name:

S-H20: 0.00292 g/L @

VP: 1.0E-6 torr @

MW: 380.00 %<500 %<1000 Physical State and Misc CRSS Info:

Neat: Solid (powder) Mfg: Proc/Form: End Use:

The top structure drawn and the MW and MF

above represent the low molecular weight species; no

distribution of molecular weights for the PMN material is

provided. Submitted data: powder; MP = ca. 50

¦C; ; ; insoluble in

water; ;

; ;

Page 1Support - P-09-0546 Engineering.2.txt

submitted IR, 13C NMR, and 1H NMR

spectra are in agreement with the structure provided.

EPI estimated data for low molecular weight structure as

drawn: BP = 579 ¦C; VP = 9.36E-13 torr; WS = 2.919 mg/L;

log P = 3.68.

Consumer Use: No

SAT (concerns) (08/21/2009):

Migration to groundwater: Negligible

PBT rating: P2B1T1

Health: 1-2 Dermal, Inhalation,

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

OCCUPATIONAL EXPOSURE RATING: 1A

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

POLLUTION PREVENTION CONSIDERATIONS:

None.

EXPOSURE-BASED REVIEW:

INITIAL REVIEW ENGINEERING REPORT

PMN: 09-0546

Manufacturing

Number of Sites/ Location:

Days/yr:

Basis:

Page 2Support - P-09-0546 Engineering.2.txt

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.

Conservative:

to:

from:

basis:

Output 2:

to:

from:

basis:

Output 2:

to:

from:

basis:

RELEASE TOTAL

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

Basis:

Page 3Support - P-09-0546 Engineering.2.txt

Inhalation:

negligible (VP < 0.001 torr).

Dermal:

Exposure to High End:

Number of workers (all sites) with dermal exposure:

Basis:

INITIAL REVIEW ENGINEERING REPORT

PMN: 09-0546

Use:

Number of Sites/ Location:

Days/yr:

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.

Output 2:

to:

from:

basis:

Output 2:

to:

from:

basis:

Page 4Support - P-09-0546 Engineering.2.txt

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 0

Basis:

Inhalation:

negligible (VP < 0.001 torr).

Dermal:

Page 5

# A-003

Initial Review Exposure Report

for PMN P-09-546