Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-12-326 

EPA Docket EPA-HQ-OPPT-2012-0740 

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Index 

A-001 Structure Activity Team (SAT) Report for

 PMN P-12-326 

A-002 Initial Review Engineering Report for 

 PMN P-12-326 

A-003 Initial Review Exposure Report for 

 PMN P-12-326 

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A-001 

Structure Activity Team (SAT) Report 

 for PMN P-12-326 

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SAT Report

PMN Number: P-12-0326

SAT Date: 5/8/2012

Print Date: 5/31/2012

Related cases:

Health related cases: 

Ecotox related cases: Analogs: 

Concern levels:

Type of Concern: Health Eco Comments

Level of Concern: 1 1

 Persistence Bioaccum Toxicity Comments

3 1 1 PMN+

Exposure Based Review:

Health: No

Ecotox: No

Routes of exposure: Health: No exposures needed

Ecotox: No releases to water

Fate: ;

Keywords:

 Keywords: LOW CONCERN

Summary of Assessment:

 Fate:

Fate Summary: P-12-0326

FATE: 

Liquid with MP < 25 C (E)

S = Reacts

Hydrolysis half-life > mo

VP < 1.0E-6 torr at 25 C (E)

BP > 400 C (E)

H < 1.00E-8 (E)

POTW removal (%) = PMN 90 via sorption

Time for complete ultimate aerobic biodeg > mo

Sorption to soils/sediments = v.strong

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PBT Potential: P3B1

*CEB FATE: Migration to ground water = negl

 Health:

 Health Summary: Absorption is nil all routes based on physical/chemical 

properties. No significant health concerns. 

 . Low concern. 

 Ecotox:

Test Organism Test 

Type

Test End 

Point

Predicted Measured Comments

fish 96-h LC50 *

daphnid 48-h LC50 *

green algal 96-h EC50 *

fish _ chronic value *

daphnid _ chronic 

value

*

algal _ chronic 

value

*

Sewage Sludge 3-h EC50 _

Sewage Sludge _ Chronic 

Value

_

Ecotox Values Comments: Predictions are based on SARs for nonionic polymers; SAR 

chemical class = polymer-nonionic- liquid (P); S = reacts with 

water at 25 C (P); pH7; effective concentrations based on 100% active ingredients and nominal 

concentrations; hardness <150.0 mg/L as CaCO3; and TOC <2.0 mg/L;

Factors Values Comments

Assessment Factor 10

Concentration of Concern 

(ppb)

*

SARs nonionic polymers

SAR Class polymer-nonionic

Ecotox Category Nonionic Polymers

Ecotox Factors Comments: 

 SAT Chair: Becky Jones

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A-002 

Initial Review Engineering Report 

 for PMN P-12-326 

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INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0326

Focus Ready Draft 5/14/2012

ENGINEER:

PV (kg/yr): 0 Binding PV Import Only

Revision Notes / Assessment Overview: CEB D1 DROP

SUBMITTER:

USE:

OTHER USES:

MSDS: No Label: No

TLV/PEL:

none established

CRSS :

Chemical Name:

S-H20: g/L @

VP: 0.0E+0 torr @

MW: %<500 %<1000

Physical State and Misc CRSS Info:

Consumer Use: No

SAT (concerns) (04/27/2012):

Related Cases and Related Cases and Misc SAT Info:

Ecotox Analog: L-08-218.

Migration to groundwater: Negligible

PBT rating: P3B1T1 LVE: P3B1T1 // Incin Pdt: P3B1T2

Health: 1 Not Required

Eco: 1 No releases to Water

OCCUPATIONAL EXPOSURE RATING: NR

NOTES & KEY ASSUMPTIONS:

Generated by the 06/07/2005 version of ChemSTEER. D1

DROP. Health and Eco are 1 and no releases to water

required per SAT. PB rating is not P2B2 or higher.

POLLUTION PREVENTION CONSIDERATIONS:

EXPOSURE-BASED REVIEW: No

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INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0326

Number of Sites/ Location: 3

Unknown Sites

Days/yr: 360

Basis: Per submission, 3 sites and LVE imported and used

as 2% liquid. 2008 ESD assumes 360 days/yr of operation.

CS calculates a use rate of 0.9259 kg/site-day.

Process Description: Imported photoresist product

(solution, 2% LVE) --> Coating/Heating --> Exposing -->

Developing/Etching --> Removing of Excess --> Electronic

Device (per submission, consistent with September 2008

ESD on Photoresist Use in Semiconductor Manufacturing)

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. // Releases to water not required

per SAT. Fugitive air releases not expected. Total

amount incinerated < 28,000 kg/site-day. Migrationto gw =

negl.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 0

Basis:

Inhalation:

Inhalation exposures not expected per ESD.

Dermal:

Dermal exposures not required per SAT.

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A-003 

Initial Review Exposure Report 

 for PMN P-12-326 

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Page 1 of 1 

 

POST FOCUS EXPOSURE REPORT 

Release information for this compound does not meet criteria for preparation of an exposure assessment; 

were eliminated and the were below the threshold for exposure 

assessment 

Assessor: 

 

ENVIRONMENTAL RELEASES 

Scenario#: Number of Release Sites: 

Release Activity: 

Release Description: WATER LANDFILL INCINER LAND/INCIN FUGITIVE 

Total Releases: 

 

(kg/yr) (kg/yr) (kg/yr) (kg/yr) (kg/yr) 

Release Days/yr: 

 

Per Site Release: 

(kg/day) (kg/yr) (kg/yr) (kg/yr) (kg/day) 

Remarks: 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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