# Support Documents for Significant New Use Rule (SNUR) on Premanufacture Notice (PMN) P-10-548

EPA Docket EPA - HQ - OPPT -2011-0577

# 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

# A-001 Structure Activity Team (SAT) Report for PMN P-10-548

# A-002 Initial R eview Engineering Report for PMN P-10-548

### 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 : 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 : - N one 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: N o SAT (concerns): (9/24/2010):Related Cases and Misc SAT Info:

. Migration to groundwater: Slow PBT rating: P 1 B 2 T 1 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: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: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: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 o

# A-003 Initial Review Exposure Report for PMN P-10-54810/6/2010 Page 1 of 4


### INITIAL REVIEW EXPOSURE REPORT (IRExR) Chemical ID: P-10-0548 Reviewer: Kwon/BC Results Table: Dose, Concentration, and Days Exceeded Results Summary Exposure Scenario 1 Water Landfill Stack Air Fugitive Air Drinking Water Fish Ingestion ADR LADD ADR LADD 7Q10 4 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 exposu re calculation abbreviation. 2 Release activities are from engineering report's Manu facturing (Mfg), Processing (Proc) and Use release activity labels. Multiple release activities are co mbined in one exposure scenario if their releases occur at same location. 3 Exposure calculations are Acute Dose Rate (ADR), Lifetime Average Daily Do se (LADD), and Probabilistic Dilution Model (PDM). There may be on e, two, or all three exposure calcu lations per exposure scenario. CC is the aquatic c oncentration 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)10/6/2010 Page 2 of 4

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:10/6/2010 Page 3 of 4

INITIAL REVIEW EXPOSURE REPORT Chemical ID: P-10-054810/6/2010 Page 4 of 4