Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-09-552 

EPA Docket EPA-HQ-OPPT-2010-1075 

 

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Index

A-001 Structure Activity Team (SAT) Report for 

PMN P-09-552 

A-002 Initial Review Engineering Report for 

PMN P-09-552 

A-003 Initial Review Exposure Report for 

PMN P-09-552 

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A-001 

Structure Activity Team (SAT) Report 

 for PMN P-09-552 

 

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SAT Report

PMN Number: P-09-0552

SAT Date: 8/21/2009

Related cases:

Health related cases: 

Ecotox related cases: 

Concern levels:

Type of Concern: Health Eco Comments

Level of Concern: 2-3 3

 Persistence Bioaccum Toxicity Comments

 2 2 2

Exposure Based Review:

Health:

Ecotox: No

Routes of exposure: Health: Dermal Drinking Water Inhalation 

Ecotox: All releases to water

Fate: ;

Keywords:

 Keywords: MUTA; ONCO; DEVEL; SENS-L,S; CORR-E,S,MM,L; AQUATOX

Summary of Assessment:

 Fate:

Fate Summary: P-09-0552

FATE: 

Liquid with MP < 20 EC (E)

log Kow = 5.34 (E); 

S = 1.61 mg/L at 25 EC (E)

VP = 2.6E-2 torr at 25 EC (E)

BP = 251 EC (E)

H = 2.53E-3 (E)

log Koc = 3.84 (E)

log Fish BCF = 3.19 (E)

log Fish BAF = 4.16 (E) 

POTW removal (%) = 75-90 via sorption and stipping

Time for complete ultimate aerobic biodeg > mo

Sorption to soils/sediments = strong

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Volatilization half-life from a standard river = 2 hrs

Volatilization half-life from a standard lake = 6 da

Atmospheric Oxidation Half-life = 13 hr via OH radical

PBT Potential: P2B2

*CEB FATE: Migration to ground water = moderate

 Health:

 Health Summary: Expect moderate absorption via all routes (pchem); 

expected to react with all tissues. Concern for corrosion to all tissues from the reactivity of the 

PMN substance. Concern for mutagenicity, oncogenicity, developmental toxicity and respiratory 

and dermal sensitization as a potential alkylating agent.

 Ecotox:

Test 

Organism

Test 

Type

Test End 

Point

Predicted Measured Comments

fish 96-h LC50 0.096 or *

daphnid 48-h LC50 0.096 or *

green algal 96-h EC50 1.0

fish _ chronic value 0.002

daphnid chronic value 0.002

algal _ chronic value 1.0

Sewage Sludge 3-h EC50 _

Sewage Sludge _ Chronic Value _

Ecotox Values Comments: Predictions are based on SARs for benzyl halides; SAR chemical 

class = benzyl halide; MW 231; liquid with unknown mp (M); log Kow = 5.34 (EPI); S = 1.6 

mg/L at 20 °C (P); pH7; effective concentrations based on 100% active ingredients and mean 

measured concentrations; hardness <150.0 mg/L as CaCO3; and TOC <2.0 mg/L;

Factors Values Comments

Assessment Factor 10

Concentration of Concern 

(ppb)

1

SARs benzyl halides

SAR Class benzyl halide

Ecotox Factors Comments: 

 SAT Chair: L Keifer 564-8916

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A-002 

Initial Review Engineering Report 

 for PMN P-09-552 

 

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INITIAL REVIEW ENGINEERING REPORT

P-09-0552

Focus Ready Draft 8/27/2009

ENGINEER: Jon \ AH

PV (kg/yr): 10000 

Revision Notes/Assessment Overview:

SUBMITTER: Henkel Corporation (submitter)

USE: Site-limited chemical intermediate for polymer synthesis. 

OTHER USES:

MSDS: Yes LABEL: No

Gen Eqpt: permeation resistant gloves (butyl rubber, nitrile rubber, polyvinyl alcohol), safety goggles or safety 

glasses with side shields, full face protection should be used if the potential for splashing or spraying of product 

exists

Respirator: NIOSH approved air-purifying respirator with an organic vapor cartridge

Health Effects: causes eye, skin, digestive tract, and respiratory tract burns // harmful if swallowed or inhaled

TLV/PEL: - none

CRSS: (8/20/2009):

Chemical Name: Benzene, 1,3-bis(1-chloro-1-methylethyl)-

S-H2O: 0.00161 g/L @ 

VP: 2.6E-2 torr @ 

MW: 231 0.0%<500 0.0%<1000

Physical State and Misc CRSS Info:

Neat: Liquid Mfg: Liquid

Proc/Form: NA End Use: Destroyed. Submitted Data: Colorless liquid; density = 1.097 g/cm3. The submitted 

FTIR and 1H NMR spectra are consistent with the structure of the PMN substance. The BP of 48-50¦C in the MSDS 

is most likely that of a solvent in a formulation. Estimated Data (EPI with MP = 20¦C): BP = 250.79¦C; VP = 

0.0261 torr; WS = 0.00161 g/L; log P = 5.34. Estimated Data (STN/ACD Labs): BP = 273.7¦C; VP = 0.00943 torr; 

WS = 0.0058 g/L; log P = 4.15.

Consumer Use: No

SAT (concerns): (8/21/2009):

Migration to groundwater:

PBT rating: P2 B2 T2

Health: 2-3, Dermal, Drinking Water, Inhalation

Eco: 3, Water (All releases to water with a CC = 1ppb)

OCCUPATIONAL EXPOSURE RATING: 1-2A

NOTES & KEY ASSUMPTIONS:

Generated by the 06/07/2005 version of ChemSTEER. The PB rating is P2B2; therefore, a full assessment has been 

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performed. An attempt was made to contact the submitter regarding end use information but he was unavailable (see 

contact report). The PMN is a site-limited intermediate and is destroyed during use. Releases to incineration and 

air (volatilization) is expected. Additionallly, this IRER provides both dermal and inhalation exposure assessments 

during MFG and USE although exposure may be mitigated (PMN causes burns according to the MSDS). 

POLLUTION PREVENTION CONSIDERATIONS:

None.

P2 REC:

EXPOSURE-BASED REVIEW: No (0 criteria met)

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P-09-0552

Manufacturing

Number of Sites/Location: 1 submitter site(s) 

Henkel Corporation Rocky Hill CT 06067

Basis: Submission states 1 site, 100 kg/batch PMN, 8 hrs/batch, and 100 batches/yr.

Process Description: Raw materials --> 50 gallon pressure vessel --> vacuum, stripped --> 100% liquid PMN product 

transferred to drums (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. Submission states any residual product left in solvent wastes are drummed for off-site 

incineration, and estimates a total of 0.3 kg/batch PMN released during MFG/USE (0.3%). CEB standard models 

are used to estimate release, as conservative.

Incineration

Conservative: 1.0E+0 kg/site-day over 100 day/yr from 1 sites or 1.0E+2 kg/yr

to: off-site incineration (submission)

from: Equipment Cleaning Losses of Liquids from a Single, Large Vessel

basis: EPA/OPPT Single Vessel Residual Model, CEB standard 1% residual.

Air

Output 2: 4.1E-3 kg/site-day over 100 day/yr from 1 sites or 4.1E-1 kg/yr

to: Air

from: Equipment Cleaning Losses of Liquids from a Single, Large Vessel

basis: EPA/OPPT Mass Transfer Coefficient Model.

Air

Typical: 1.6E-5 kg/site-day over 100 day/yr from 1 sites or 1.6E-3 kg/yr

Worst Case: 3.2E-5 kg/site-day over 100 day/yr from 1 sites or kg/yr

to: Air

from: Loading Liquid Product into Drums

basis: EPA/OAQPS AP-42 Loading Model.

RELEASE TOTAL

1.0E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 3

Basis: Submission indicates 2 workers at the submitter site. CEB assesses exposure for a default minimum of 3 

workers. Note exposure may be mitigated since the PMN causes skin and eye burns, per MSDS.

Dermal:

Exposure to Liquid 

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High End: 1.8E+3 mg/day over 100 days/yr

Number of workers (all sites) with Dermal exposure: 3

Basis: Loading Liquid Product into Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

Inhalation:

Exposure to Vapor 

Typical: 4.7E-1 mg/day over 100 days/yr

Worst Case: 7.8E-3 mg/day over 100 days/yr

Number of workers (all sites) with Inhalation exposure: 3

Basis: Loading Liquid Product into Drums; EPA/OPPT Mass Balance Model.

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

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

Inhalation Monitoring Data Desired? No

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P-09-0552

Use: Site-Limited Intermediate

Number of Sites/Location: 1 submitter site(s) 

Henkel Corporation Rocky Hill CT 06067

Basis: Submission indicates 1 site, 100 kg/batch, and 100 batches/yr for both MFG and USE.

Process Description: PMN charged to reactor (liquid, 100%) --> reaction, PMN destroyed 

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 provides no additional information on the use of PMN except for its use as a site 

limited intermediate. CEB assumes some release may occur to from volatilization and container cleaning.

Air

Typical: 1.6E-5 kg/site-day over 100 day/yr from 1 sites or 1.6E-3 kg/yr

Worst Case: 3.2E-5 kg/site-day over 100 day/yr from 1 sites or kg/yr

to: Air

from: Unloading Liquid Raw Material from Drums

basis: EPA/OAQPS AP-42 Loading Model.

Incineration

High End: 6.2E+0 kg/site-day over 48 day/yr from 1 sites or 3.0E+2 kg/yr

to: off-site incineration (submission)

from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material

basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. Submission states that wastes are incinerated 

off-site.

Air

Output 2: 5.3E-7 kg/site-day over 100 day/yr from 1 sites or 5.3E-5 kg/yr

to: Air

from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material

basis: EPA/OPPT Penetration Model.

RELEASE TOTAL

3.0E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 3

Basis: CEB assesses exposure to a default minimum of 3 workers/site. Note these may be the same workers who are 

exposed during MFG.

Dermal:

Exposure to Liquid 

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High End: 1.8E+3 mg/day over 100 days/yr

Number of workers (all sites) with Dermal exposure: 3

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

Inhalation:

Exposure to Vapor 

Typical: 4.7E-1 mg/day over 100 days/yr

Worst Case: 7.8E-3 mg/day over 100 days/yr

Number of workers (all sites) with Inhalation exposure: 3

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT Mass Balance Model.

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

 (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-09-552 

 

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8/26/09 Page of 

INITIAL REVIEW EXPOSURE REPORT (IRExR) 

 Chemical ID: P090552 Reviewer: Kwon 

 

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=1 

PDM 

Days 

Exceeded

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/USE: max ADR --- --- --- --- --- --- --- 8.92E-06 --- 1.04E-04 --- 

MFG/USE: max 

LADD --- --- --- --- --- --- --- --- 1.08E-07 --- 9.19E-07

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 streamflow of 

the 7 consecutive days of lowest flow within a 10 year period. 

Remarks: 

Exposure Based Criteria 

Parameter Exp Based Persistent Exceedance Value 

Drinking (Surface) Water Dose (mg/kg/day) N/A No 

Fish Ingestion Dose (mg/kg/day) N/A No 

Inhalation Dose (mg/kg/day) N/A No 

Groundwater Dose (mg/kg/day) N/A No 

Surface Water Release After Treatment (kg/yr) N/A No 

Total Release After Treatment (kg/yr) N/A No 

Fate test recommendations: (default is NA) 

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 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P090552 Assessor: Kwon 

ENVIRONMENTAL RELEASES 

 Scenario#:1 Number of Release Sites: 1. 

 Release Activity: MFG/USE: max ADR 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: N/A N/A 345.60 0.42 

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

 

 Non-sludge/Sludge 

Release Days/yr: N/A 0.00/0.00 48.00 100.00 

Per Site Release: N/A N/A/0.00 7.20 4.16E-03 

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

Remarks: 

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INITIAL EXPOSURE REVIEW REPORT 

Chemical ID: P090552 

INHALATION EXPOSURE ESTIMATES (POST-TREATMENT) 

SCENARIO #: 1 RELEASE ACTIVITY:MFG/USE: max ADR 

RELEASE DESCRIPTION: 

METHOD OF CALCULATION: Screen3 

EXPOSED POPULATION: Adult 

Number of Sites: 1. 

Per Site Fugitive Release: 4.16E-03 kg/site/day 

Fugitive Release Days per Year: 100.00 days 

% Removal via Fugitive Release: 0.00 % 

Total Fugitive Release: 0.42 kg/yr 

Max Annual Average Air Concentration 

(Fugitive): 

1.25E-02 μg/m3

Max 24 Hour Average Air 

Concentration(Fugitive): 

0.57 μg/m3

Per Site Stack Release: 7.20 kg/site/day 

Stack Release Days per Year: 48.00 days 

% Removal via Stack Release: 99.90 % 

Total Stack Release: 345.60 kg/yr 

Max Annual Average Air Concentration (Stack): 1.28E-03 μg/m3

Max 24 Hour Average Air Concentration (Stack): 4.85E-02 μg/m3

ASSUMPTIONS 

Exposure Units 

Results 

(Stack) 

Results 

(Fugitive) ED 

(years) 

AT 

(years) 

BW 

(kg) 

Inh. Rate 

(m3/hr) 

Cancer 

LADDpot (mg/kg/day) 9.41E-08 9.19E-07 30.00 75.00 71.80 0.55 

LADCpot (mg/m3) 5.12E-07 5.00E-06 30.00 75.00 NA NA 

Acute 

ADRpot (mg/kg/day) 8.92E-06 1. 04E-04 NA 1 day 71.80 0.55 

Inhalation Comments: 

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 Stack Parameter Data Fugitive Parameter Data 

Stack Height 10.00 m Release Height: 3.00 m 

Inside Stack 

Diameter: 

0.10 m Length of Release 

Opening: 

10.00 m 

Stack Gas Exit 

Velocity: 

0.10 m/sec Width of Release 

Opening: 

10.00 m 

Stack Gas 

Temperature: 

293.00 K 

 

 Meteorological and Terrain Information: 

Surrounding Land Use: Rural 

Terrain Height: 0.00 m 

Distance to Residence of Interest: 100.00 m 

Meteorological Class: Full 

Stability Class: NA 

Wind Speed: NA 

 

 Downwash Information: 

Facility Length: NA m 

Facility Width: NA m 

Facility Height: NA m 

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 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P090552 Assessor: 

ENVIRONMENTAL RELEASES 

 Scenario#:2 Number of Release Sites: 1. 

 Release Activity: MFG/USE: max LADD 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: N/A N/A 397.60 0.42 

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

 

 Non-sludge/Sludge 

Release Days/yr: N/A 0.00/0.00 1.00 1.00 

Per Site Release: N/A N/A/0.00 397.60 0.42 

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

Remarks: 

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INITIAL EXPOSURE REVIEW REPORT 

Chemical ID: P090552 

INHALATION EXPOSURE ESTIMATES (POST-TREATMENT) 

SCENARIO #: 2 RELEASE ACTIVITY:MFG/USE: max LADD 

RELEASE DESCRIPTION: 

METHOD OF CALCULATION: Screen3 

EXPOSED POPULATION: Adult 

Number of Sites: 1. 

Per Site Fugitive Release: 0.42 kg/site/day 

Fugitive Release Days per Year: 1.00 days 

% Removal via Fugitive Release: 0.00 % 

Total Fugitive Release: 0.42 kg/yr 

Max Annual Average Air Concentration 

(Fugitive): 

1.25E-02 μg/m3

Max 24 Hour Average Air 

Concentration(Fugitive): 

56.90 μg/m3

Per Site Stack Release: 397.60 kg/site/day 

Stack Release Days per Year: 1.00 days 

% Removal via Stack Release: 99.90 % 

Total Stack Release: 397.60 kg/yr 

Max Annual Average Air Concentration (Stack): 1.47E-03 μg/m3

Max 24 Hour Average Air Concentration (Stack): 

ASSUMPTIONS 

Exposure Units 

Results 

(Stack) 

Results 

(Fugitive) ED 

(years) 

AT 

(years) 

BW 

(kg) 

Inh. Rate 

(m3/hr) 

Cancer 

LADDpot (mg/kg/day) 1.08E-07 9. 19E-07 30.00 75.00 71.80 0.55 

LADCpot (mg/m3) 5.88E-07 5.00E-06 30.00 75.00 NA NA 

Acute 

ADRpot (mg/kg/day) 

Inhalation Comments: 

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 Stack Parameter Data Fugitive Parameter Data 

Stack Height 10.00 m Release Height: 3.00 m 

Inside Stack 

Diameter: 

0.10 m Length of Release 

Opening: 

10.00 m 

Stack Gas Exit 

Velocity: 

0.10 m/sec Width of Release 

Opening: 

10.00 m 

Stack Gas 

Temperature: 

293.00 K 

 

 Meteorological and Terrain Information: 

Surrounding Land Use: Rural 

Terrain Height: 0.00 m 

Distance to Residence of Interest: 100.00 m 

Meteorological Class: Full 

Stability Class: NA 

Wind Speed: NA 

 

 Downwash Information: 

Facility Length: NA m 

Facility Width: NA m 

Facility Height: NA m 

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8/26/09 Page of 

LEGEND FOR NEW CHEMICALS EXPOSURE REPORT 

This new chemicals exposure report was prepared by the Exposure Assessment Branch (EAB) of the Economics, 

Exposure and Technology Division, Office of Pollution Prevention and Toxics, USEPA. 

The goals of these reports are to calculate conservative (protective) estimates of exposure endpoints for consumers, 

the general population, and the environment. 

For each exposure scenario to industrial releases, the following three endpoints are calculated: 

(1) maximum possible acute concentrations and doses 

(2) maximum possible chronic concentrations and doses 

(3) for water releases ≥ 20 days, the probability of exceedence of the aquatic concentration of concern 

These endpoints are identified by abbreviations on the Release Activity line, e.g., (1) max ADR, (2) max 

LADD, (3) max PDM. Depending on the release inputs, these endpoints may be calculated and presented on 

the same page or different pages. That is, a release activity ID of mfg; max ADR, max PDM, max LADD

indicates that all the exposure endpoints were calculated from common manufacturing release values; 

conversely, a release activity ID of mfg &proc; max ADR indicates that only the maximum acute exposure 

values were calculated for manufacturing and processing releases that occurred at the same site. 

For each consumer product use exposure scenario, whether exposure is to the user directly or to the general 

population/environment, the maximum exposure values are calculated and presented together. 

In addition to the exposure values above, EPA policy directs that exposure and release values be compared to 

criteria threshold values for Exposure-based and PBT Exposure-based cases. 

Exposure-based (YX) cases (those with ≥ 100,000 kg/yr production volume) 

Criteria are exceeded under the following conditions: 

 Presence in consumer product with likely exposure 

≥ 3E-3 mg/kg/d exposure via air, fish ingestion or drinking water 

≥ 10,000 kg/yr release to environment (post-treatment) 

≥ 1,000 kg/yr release to water (post-treatment) 

Persistent, Bioaccumulative, Toxic (PBT) chemicals of P2B2 rating or higher and production volume ≥ 20,000 kg/yr 

Criteria are exceeded as for YX cases, with the following differences: 

≥ 2,000 kg/yr release to environment (post-treatment) 

≥ 200 kg/yr release to water (post-treatment) 

Bolding rules in the Report: Values for endpoints above that are also health or eco concerns are bolded. 

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