# Support Documents for Significant New Use Rule (SNUR) on Premanufacture Notice (PMN) P-09-552

EPA Docket EPA-HQ-OPPT-2010-1075

# 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

# A-001 Structure Activity Team (SAT) Report for PMN P-09-552

## 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: N o 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

### 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 ( p che m ); 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); p H7; 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 ( p pb) 1
SARs benzyl halides SAR Class benzyl halide
Ecotox Factors Comments: SAT Chair: L Keifer 564-8916

# A-002 Initial Review Engineering Report for PMN P-09-552

### 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 : N o 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: N IOSH 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: N A 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: N o SAT (concerns): (8/21/2009): Migration to groundwater: PBT rating: P 2 B 2 T 2 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 beenperformed. 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: N one.
P2 REC:
EXPOSURE-BASED REVIEW: N o (0 criteria met)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/y r 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/y r 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/y r Worst Case: 3.2E-5 kg/site-day over 100 day/yr from 1 sites or kg/y r to: Air from: Loading Liquid Product into Drums basis: EPA/OAQPS AP-42 Loading Model.



## RELEASE TOTAL 1.0E+2 kg/y r - 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. N ote exposure may be mitigated since the PMN causes skin and eye burns, per MSDS.

Dermal: Exposure to LiquidHigh End: 1.8E+3 mg/day over 100 days/y r 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/y r Worst Case: 7.8E-3 mg/day over 100 days/y r 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? N o (b) Hazard Rating for health of 2 or greater? N o Inhalation Monitoring Data Desired? N oP-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/y r Worst Case: 3.2E-5 kg/site-day over 100 day/yr from 1 sites or kg/y r 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/y r 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/y r 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/y r - 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. N ote these may be the same workers who are exposed during MFG.

Dermal: Exposure to LiquidHigh End: 1.8E+3 mg/day over 100 days/y r 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/y r Worst Case: 7.8E-3 mg/day over 100 days/y r 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? N o (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-09-5528/26/09 Page of

INITIAL REVIEW EXPOSU RE REPORT (IRExR)
Chemical ID: P090552 Reviewer: Kwon 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=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 μ g/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 activ ity followed by exposure calculation abbreviation. 2 Release activities are from engineering report's Manufactur ing (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 Do se (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)8/26/09 Page of

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:8/26/09 Page of

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/m 3

Max 24 Hour Average Air Concentration(Fugitive): 0.57 μg/m 3

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 Concen tration (Stack): 1.28E-03 μg/m 3 Max 24 Hour Average Air Concentration (Stack): 4.85E-02 μg/m 3

ASSUMPTIONS Exposure Units Results (Stack) Results (Fugitive) ED (years) AT (years) BW (kg) Inh. Rate (m 3 /hr) Cancer LADD pot (mg/kg/day) 9.41E-08 9.19E-07 30.00 75.00 71.80 0.55 LADC pot (mg/m 3 ) 5.12E-07 5.00E-06 30.00 75.00 NA NA Acute ADR pot

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

Inhalation Comments:8/26/09 Page of

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 m8/26/09 Page of

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:8/26/09 Page of

INITIAL EXPOSURE REVIEW REPORT Chemical ID: P090552
INHALATION EXPOSURE ESTIMATES (POST-TREATMENT)
SCENARIO #: 2 RELEASE AC TIVITY: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/m 3

Max 24 Hour Average Air Concentration(Fugitive): 56.90 μg/m 3

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 Concen tration (Stack): 1.47E-03 μg/m 3 Max 24 Hour Average Air Concentration (Stack):

ASSUMPTIONS Exposure Units Results (Stack) Results (Fugitive) ED (years) AT (years) BW (kg) Inh. Rate (m 3 /hr) Cancer LADD pot (mg/kg/day) 1.08E-07 9. 19E-07 30.00 75.00 71.80 0.55 LADC pot (mg/m 3 ) 5.88E-07 5.00E-06 30.00 75.00 NA NA Acute ADR pot

(mg/kg/day)

Inhalation Comments:8/26/09 Page of

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 m8/26/09 Page of



## LEGEND FOR NEW CHEMICAL S EXPOSURE REPORT
This new chemicals exposure report wa s 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 calcula te 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 abbreviati ons on the Release Activity line, e.g., (1) max ADR , (2) max LADD , (3) max PDM . Depending on the release inputs, these e ndpoints 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 cal culated 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 proce ssing 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 dir ects 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) chemical s of P2B2 rating or hi gher 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 th at are also health or eco concerns are bolded.