# Supp ort Documents for

Significant New Use Rule (SNUR) on

Premanufacture Notice (PMN)

P-10-313

EPA Docket EPA

- HQ

- OPPT -2011-0577

# 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

# A-001

Structure Activity Team (SAT) Report

for PMN P-10-313

# A-002

Initial Review Engineering Report

for PMN P-10-313Support - 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),

Page 1Support - 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

Page 2Support - P-10-0313 engineering.1.txt

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

Page 3Support - P-10-0313 engineering.1.txt

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:

Page 4Support - P-10-0313 engineering.1.txt

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:

Page 5Support - P-10-0313 engineering.1.txt

Solid High End:

Page 6

# A-003

Initial Review Exposure Report

for PMN P-10-31310/29/10 page of



## This report was revised using the po st-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 Scenario 1 Water Landfill Stack Air Fugitive Air

Drinking Water Fish Ingestion

ADR LADD ADR LADD 7Q10 4

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 Manuf acturing (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 (A DR), 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 7Q 10 streamflow, which is defined as the average daily

streamflow

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

Remarks:10/29/10 page of



### Fate test recommendations?: (default is NA)10/29/10 page of

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:10/29/10 page of

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

SLUDGE 1

AND DAYS OF

RELEASE

(kg/site/day)/(days) MIGRATION

DESCRIPTOR 2 ADSORPTION

TO

WASTEWATER

SLUDGE

(%) DRINKING

WATER

TREATMENT

(%)

ASSUMPTIONS

Exposure Units Results ED

(years) AT

(years) BW

(kg) IR

(L/day)

Cancer

LADD pot (mg/kg/day)

LADC pot (mg/L)

REMARKS:10/29/10 page of

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:10/29/10 page of

POST FOCUS EXPOSURE REPORT

Chemical ID: P-10-0313

REMARKS: