Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-10-313 

EPA Docket EPA-HQ-OPPT-2011-0577 

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Index

A-001 Structure Activity Team (SAT) Report for 

PMN P-10-313 

A-002 Initial Review Engineering Report for 

PMN P-10-313 

A-003 Initial Review Exposure Report for 

PMN P-10-313 

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A-001 

Structure Activity Team (SAT) Report

for PMN P-10-313 

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A-002 

Initial Review Engineering Report

for PMN P-10-313 

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Support - P-10-0313 engineering.1.txt

INITIAL REVIEW ENGINEERING REPORT 

PMN: 10-0313

Post-Focus Draft Revision 1 10/13/2010

ENGINEER: Arnold \ DDH

PV (kg/yr): 

SUBMITTER: ICL Performance Products LP

USE: Opacifying pigment for ceramic whiteware.

OTHER USES:

MSDS: Yes Label: No

Gen Eqpt: protective gloves (butyl rubber, nitrile rubber,

 rubber, neoprene) / safety glasses/ no specific

engineering controls provided in submission

Respirator: respiratory protection not required.

Health Effects: no irritating effects on skin and eyes/

no sensitizing effects known

TLV/PEL:

none established.

CRSS :

Chemical Name: Diphosphoric acid, calcium salt (1:1)

S-H20: 0.001 g/L @

VP: 1.0E-6 torr @

MW: 216.00 %<500 %<1000

Physical State and Misc CRSS Info:

Neat: Solid Mfg: Solid: 85% PMN material Proc/Form: Solid:

 5% PMN material End Use: Solid. Submitted Data: WS =

Partly soluble; pH = 2-4 at 100 g/L; Bulk Density = 600

kg/m^3. Estimated Data: VP < 0.000001 torr (Salt); WS <

0.001 g/L 

.

Consumer Use: No

SAT (concerns) (04/13/2010):

Migration to groundwater: Slow

PBT rating: P3B1T1

Health: 1-2 Inhalation,

Eco: 2 Water (All releases to surface waters with CC = 60

ppb), 

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Support - P-10-0313 engineering.1.txt

OCCUPATIONAL EXPOSURE RATING: 2A

NOTES & KEY ASSUMPTIONS:

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

 

 

 

 

 

 

 

 

POLLUTION PREVENTION CONSIDERATIONS:

None.

EXPOSURE-BASED REVIEW: 

INITIAL REVIEW ENGINEERING REPORT 

PMN: 10-0313

Manufacturing

Number of Sites/ Location: 1

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ICL Performance Products LP St. Louis MO 63111

Days/yr: 

Basis: 

 

Process Description:

(Submission)

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. CEB used conservative models for

equipment cleaning an

Landfill

Output 2:

to: 

from:

basis:

Landfill

Outpu

to: 

from: 

basis:

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

Inhalation:

Exposure to 

Output 2: 

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? No

 OR

 b) Hazard Rating for health of 2 or greater? 1-2 No

Inhalation Monitoring Data Desired? No

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Dermal:

Exposure to 

Output 

Number of workers (all sites) with dermal exposure: 

Basis:

Solid

High End:

INITIAL REVIEW ENGINEERING REPORT 

PMN: 10-0313

Use: Ceramic whiteware

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. Submission also estimates 0.1 kg/bt

to dust collector and approved chemical landfill from

dust collectors for process.

Output

to: 

from:

basis:

Output

to: 

from:

basis:

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Output 2:

to:

from:

basis:

RELEASE TOTAL

4.2E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

Inhalation:

Exposure to Vapor 

Output 2: 

Number of workers 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? No

 OR

 b) Hazard Rating for health of 2 or greater? 1-2 No

Inhalation Monitoring Data Desired? No

Exposure to 

Upper Bound: 

Number of workers 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

 OR

 b) Hazard Rating for health of 2 or greater? 1-2 No

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Exposure to 

Output 1: 

Output 2: 

Number of workers with dermal exposure: 

Basis:

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Solid

High End:

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A-003 

Initial Review Exposure Report

for PMN P-10-313 

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This report was revised using the post-focus engineering report dated 

10/13/2010. According to this report there are no longer water releases 

from manufacturing operations and all releases are going to landfill. No 

exposure based criteria are met with these release estimates. 

POST FOCUS EXPOSURE REPORT 

 Chemical ID: P-10-0313 Reviewer: Cinalli/SS 

 

 

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 = 60 

PDM 

Days 

Exceede

d 

LADD ADR LADD ADR LADD 

Release 

activity(ies)2; 

exposure 

calculation(s)3 

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

MFG: Max LADD --- --- --- --- --- --- --- --- --- --- 

USE: Max LADD 

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: 

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Fate test recommendations?: (default is NA)

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 POST FOCUS EXPOSURE REPORT 

Chemical ID: P-10-0313 Assessor: Cinalli/SS 

ENVIRONMENTAL RELEASES 

 Scenario#:1 Number of Release Sites: 

 Release Activity: MFG: Max LADD 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 

 (k g/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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POST FOCUS EXPOSURE REPORT 

Chemical ID: P-10-0313 

DRINKING WATER EXPOSURE ESTIMATES FROM LANDFILL RELEASES 

SCENARIO #: 1 ACTIVITY: MFG: Max LADD 

RELEASE DESCRIPTION: 

EXPOSED POPULATION: Adult 

NUMBER 

OF 

SITES 

NON-SLUDGE 

LANDFILL 

RELEASE AND 

DAYS OF 

RELEASE 

(kg/site/day)/(days) 

 LANDFILLED 

SLUDGE1 

AND DAYS OF 

RELEASE 

(kg/site/day)/(days)

MIGRATION 

DESCRIPTOR2

ADSORPTION 

TO 

WASTEWATER 

SLUDGE 

 (%) 

DRINKING 

WATER 

TREATMENT 

 (%) 

 

 

ASSUMPTIONS 

 Exposure Units Results ED 

(years) 

AT 

(years) 

BW 

(kg) 

IR 

 (L/day) 

Cancer 

LADDpot (mg/kg/day) 

LADCpot (mg/L) 

REMARKS: 

 

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 POST FOCUS EXPOSURE REPORT 

Chemical ID: P-10-0313 Assessor: Cinalli/SS 

ENVIRONMENTAL RELEASES 

 Scenario#:2 Number of Release Sites: 2. 

 Release Activity: USE: Max LADD 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 

 (k g/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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POST FOCUS EXPOSURE REPORT 

Chemical ID: P-10-0313 

REMARKS: 

 

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