Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-09-382 

EPA Docket EPA-HQ-OPPT-2011-0577 

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Index

A-001 Structure Activity Team (SAT) Report for 

PMN P-09-382 

A-002 Initial Review Engineering Report for 

PMN P-09-382 

A-003 Initial Review Exposure Report for 

PMN P-09-382 

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A-001 

Structure Activity Team (SAT) Report

for PMN P-09-382 

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A-002 

Initial Review Engineering Report

for PMN P-09-382 

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Support - P-09-0382 Engineering.3.txt

INITIAL REVIEW ENGINEERING REPORT 

PMN: 09-0382

Post-Focus Draft Revision 3 6/24/2010

ENGINEER: Prothero \ CPW

PV (kg/yr): 

Revision Notes / Assessment Overview: Rev 3: Revised

SUBMITTER: Lebanon Seaboard Corp 

USE:

OTHER USES:

MSDS: Yes Label: No

Gen Eqpt: rubber gloves/ safety glasses with side shields

or splash goggles/ local exhaust/ if used in manner that

creates a mist, mechanical ventilation may be necessary

Respirator: none required for normal use

Health Effects: toxic/corrosive fumes may be released if

exposed to high temperatures/ irritating to eyes, skin,

lungs, and mucous membranes

TLV/PEL:

none established for PMN

CRSS :

Chemical Name: Iron, citrate phosphate potassium complexes

S-H20: 550 g/L @

VP: 1.0E-6 torr @

MW: 877.00 %<500 %<1000

Physical State and Misc CRSS Info:

Neat: Powder Mfg: 

Proc/Form: Solution: 1.8% PMN substance in water; NA End

Use: 

The MW above is for the structure as drawn, which is

representative. The submitter does not specify the

oxidation state of the iron; in the patent example No. 47

from US. Patent 4,351,735 that is included in the

submission,

Submitted Data: None. The MSDS and Physical/Chemical

Properties worksheet are for a formulation of the PMN

substance in water. Patent Data: U.S. Patent 4,351,735

discloses that the PMN substance, when spray-dried, forms

a fine dark green powder. It is described as

water-soluble. Estimated Data: VP < 0.000001 torr (Salt);

WS = 550 g/L 

Consumer Use: No

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Support - P-09-0382 Engineering.3.txt

SAT (concerns) (06/05/2009):

Migration to groundwater: Negligible

PBT rating: P1B1T1

Health: 1 Not Required

Eco: 2 Water (All releases to water with a CC = 20 ppb.),

OCCUPATIONAL EXPOSURE RATING: NR

NOTES & KEY ASSUMPTIONS:

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

 

 

 

 

POLLUTION PREVENTION CONSIDERATIONS:

None.

EXPOSURE-BASED REVIEW: 

INITIAL REVIEW ENGINEERING REPORT 

PMN: 09-0382

Manufacturing

Number of Sites/ Location: 

Lebanon Seaboard Corp 

Days/yr: 

Basis:

.

Process Description: 

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

Landfill

Subm est: 

to: Landfill 

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from: 

basis:

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

Inhalation:

not reqd per SAT

Dermal:

not reqd per SAT

INITIAL REVIEW ENGINEERING REPORT 

PMN: 09-0382

Use: 

Number of Sites/ Location: 

Days/yr: 

Basis: Submission:

Process Description:

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

High End: 

to:

from:

basis:

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Typical: 

to: 

from: 

basis:

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 0

Basis:

Inhalation:

not reqd per SAT

Dermal:

not reqd per SAT

INITIAL REVIEW ENGINEERING REPORT 

PMN: 09-0382

Use: 

Number of Sites/ Location: 

Days/yr: 

Basis:

Process Description:

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

High End: 

to: 

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from:

basis: 

 

 

 

Typical:

to: 

from: 

basis:

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 0

Basis:

Inhalation:

not reqd per SAT

Dermal:

not reqd per SAT

INITIAL REVIEW ENGINEERING REPORT 

PMN: 09-0382

Use: 

Number of Sites/ Location: 

Days/yr: 

Basis: Submission:

Process Description:

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ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

High End: 

to:

from:

basis: 

 

 

Typical: 

to:

from: 

basis:

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 0

Basis:

Inhalation:

not reqd per SAT

Dermal:

not reqd per SAT



CALL BY: CPW

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Support - P-09-0382 Engineering.3.txt

Organization: ERG for CEB

CALL TO: Thomas Schreier

Organization: 

Date: 06/08/2009

Time: 3:30 PM

Phone: 

PMN: 09-0382

CALL TO: Scott Prothero

Organization: EPA/ OPPT/ CEB

Date: 07/16/2009

Time: 10:07 am

Phone: 

PMN: 09-0382

P-09-382

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CALL TO: Scott Prothero

Organization: EPA/ OPPT/ CEB

Date: 11/30/2009

Time:

Phone: 

PMN: 09-0382

P-09-382

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A-003 

Initial Review Exposure Report

for PMN P-09-382 

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