Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-10-548 

EPA Docket EPA-HQ-OPPT-2011-0577 

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Index

A-001 Structure Activity Team (SAT) Report for 

PMN P-10-548 

A-002 Initial Review Engineering Report for 

PMN P-10-548 

A-003 Initial Review Exposure Report for 

PMN P-10-548 

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A-001 

Structure Activity Team (SAT) Report

for PMN P-10-548 

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A-002 

Initial Review Engineering Report

for PMN P-10-548 

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INITIAL REVIEW ENGINEERING REPORT

P-10-0548

Focus Ready Draft 10/7/2010

ENGINEER: Hall \ EV

PV (kg/yr): 

Revision Notes/Assessment Overview:

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: 0.00628 g/L @ 

VP:

MW: 124 0.0%<500 0.0%<1000

Physical State and Misc CRSS Info:

Neat: Mfg: 

Proc/Form: End Use: The structures shown 

on page 1 of this report are representative. A list of some of the specific components in the mixture is included on 

page 6 of this report. The molecular weights for the structures shown on page 1 of this report range from 124.23 

g/mole for to 332.62 g/mole for The physical/chemical properties shown 

above are worst case for the Submitted Data: 

Estimated Data for 

Consumer Use: No

SAT (concerns): (9/24/2010):

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Related Cases and Misc SAT Info:

.

Migration to groundwater: Slow

PBT rating: P1 B2 T1 C9: P1B1T1, C24: P1B2T1

Health: 1-2, Inhalation

Eco: 3, Water (All releases to water with a CC = 10 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-10-0548

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. 

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

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P-10-0548

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:

Conservative:

to: 

from:

basis:

Output 2: 

to: 

from:

basis:

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

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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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A-003 

Initial Review Exposure Report

for PMN P-10-548 

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INITIAL REVIEW EXPOSURE REPORT (IRExR) 

 Chemical ID: P-10-0548 Reviewer: Kwon/BC 

 

Results Table: Dose, Concentration, and Days Exceeded Results Summary 

Exposure

Scenario1

Water Landfill Stack Air Fugitive Air 

Drinking Water Fish Ingestion 

ADR LADD ADR LADD 7Q104

CC 

10

PDM

Days 

Exceede

d

LADD ADR LADD ADR LADD

Release 

activity(ies)2

; exposure 

calculation(s)

3

mg/kg/day mg/kg/day mg/kg/day mg/kg/day μg/l # Days mg/kg/day mg/kg/day mg/kg/day mg/kg/day mg/kg/day

MFG: Max 

ADR

1 Exposure scenario titles consist of release activity followed by exposure calculation abbreviation. 

2 Release activities are from engineering report's Manufacturing (Mfg), Processing (Proc) and Use release activity 

labels. Multiple release activities are combined in one exposure scenario if their releases occur at same location. 

3 Exposure calculations are Acute Dose Rate (ADR), Lifetime Average Daily Dose (LADD), and Probabilistic 

Dilution Model (PDM). There may be one, two, or all three exposure calculations per exposure scenario. 

 CC is the aquatic concentration of concern. 

4 This column displays concentration values for the 7Q10 streamflow, which is defined as the average daily 

streamflow of the seven consecutive days of lowest flow within a ten year period. 

Remarks: 

Fate test recommendations?: (default is NA)

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 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P-10-0548 Assessor: Kwon/BC 

ENVIRONMENTAL RELEASES 

 Scenario#:1 Number of Release Sites: 

 Release Activity: MFG: Max ADR 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 

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

 

 Non-sludge/Sludge 

Release Days/yr: 

Per Site Release: 

 (kg/site/day) (kg/site/day) (kg/site/day) (kg/site/day) 

Remarks: 

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INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P-10-0548 

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