## Support Documents for

Significant New Use Rule (SNUR) on

Premanufacture Notice (PMN)

P-10-361

EPA Docket EPA-HQ-OPPT-2011-0577

## Index

A-001 Structure Activity Team (SAT) Report for

PMN P-10-361

A-002 Initial Review Engineering Report for

PMN P-10-361

A-003 Initial Review Exposure Report for

PMN P-10-361

## A-001

Structure Activity Team (SAT) Report

for PMN P-10-361

## A-002

Initial Review Engineering Report

for PMN P-10-361Support - P-10-0361 engineering.2.txt

INITIAL REVIEW ENGINEERING REPORT

PMN: 10-0361

Post-Focus Draft Revision 1 3/24/2011

ENGINEER: Austin \ AH

PV (kg/yr):

Revision Notes / Assessment Overview:

SUBMITTER:

USE:

OTHER USES:

MSDS: Yes Label: No

Gen Eqpt:

Respirator:

Health Effects:

TLV/PEL:

CRSS :

Chemical Name:

S-H20: 0.1094 g/L @

VP: 8.5E-3 torr @

MW: 164.00 %<500 %<1000 Physical State and Misc CRSS Info:

Page 1Support - P-10-0361 engineering.2.txt

Neat: Solid Mfg: Proc/Form: End Use:

Submitted data: off-white solid; MP = 70 °C; BP = 250 °C

at 745 torr; WS = 0.255 g/L (est.); VP = 0.00776 torr

(est.); flash point >65.6 °C. Literature data (STN eprop

database): MP = 70 °C; BP = 250-250.5 °C at 745 torr,

132-134 °C at 15 torr. NOMO5 (Class 5) estimated data

from BP = 250 °C at 745 torr: BP = 250.7 °C, VP = 0.0085

torr. EPI estimated data (input MP = 70 °C): BP = 254.6

°C; VP = 0.00324 torr; WS = 0.1094 g/L; log P = 4.06. ACD

Labs estimated data (STN pprop database): BP = 250.9 °C;

VP = 1.33E-02 torr; WS = 0.33 g/L; log P = 3.741.

Consumer Use: No

SAT (concerns) (05/11/2010):

Migration to groundwater: Moderate

PBT rating: P1B1T2

Health: 2 Dermal, Drinking Water, Inhalation

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

OCCUPATIONAL EXPOSURE RATING: 2-3A

NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER.

POLLUTION PREVENTION CONSIDERATIONS:

P2 Claim:

Page 2Support - P-10-0361 engineering.2.txt

.

EXPOSURE-BASED REVIEW:

INITIAL REVIEW ENGINEERING REPORT

PMN: 10-0361

Manufacturing

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.

Output 2:

to:

from:

Page 3Support - P-10-0361 engineering.2.txt

basis:

Output 2:

to:

from:

basis:

Typical:

Worst Case:

to:

from:

basis:

Typical:

Worst Case:

to:

from:

basis:

Output 2:

to:

from:

basis:

Output 2:

to:

from:

basis:

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes:

Basis:

Inhalation:

Exposure to Upper Bound:

Number of workers (all sites) with inhalation exposure:

Page 4Support - P-10-0361 engineering.2.txt

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? 2 Yes

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Exposure to Typical:

Worst Case: 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? 2 Yes

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Exposure to High End:

Number of workers (all sites) with dermal exposure:

Basis:

Exposure to High End:

Number of workers (all sites) with dermal exposure:

Basis:

INITIAL REVIEW ENGINEERING REPORT

PMN: 10-0361

Use:

Number of Sites/ Location:

Days/yr:

Basis:

Process Description:

Page 5Support - P-10-0361 engineering.2.txt

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.

Output 2:

to:

from:

basis:

Typical:

Worst Case:

to:

from:

basis:

Output 2:

to:

from:

basis:

Typical:

Worst Case:

to:

from:

basis:

Conservative:

to:

from:

basis:

Output 2:

to:

from:

Page 6Support - P-10-0361 engineering.2.txt

basis:

Incineration

Output 2:

to:

from:

basis:

RELEASE TOTAL

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes:

Basis:

Inhalation:

Exposure to Upper Bound:

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? Yes

OR b) Hazard Rating for health of 2 or greater? 2 Yes

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Exposure to Typical:

Worst Case: 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? 2 Yes

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Exposure to High End:

Number of workers (all sites) with dermal exposure:

Page 7Support - P-10-0361 engineering.2.txt

Basis:

Exposure to High End:

Number of workers (all sites) with dermal exposure:

Basis:

Page 8

## A-003

Initial Review Exposure Report

for PMN P-10-361Date 3/25/11 Page of

POST FOCUS EXPOSURE REPORT

Summary Page

Chemical ID: P-10-0361 Reviewer: bevington

Endpoints-Assessed Table

Reasons for not assessing releases

Endpoints/Assessment

Cycles 1 Releases

Assessed

in

NCEM2? No XB

Testing

Required No

Hazard

Concern No

Releases Release

Below

Acute

Threshold 5 Release

Below

Chronic

Threshold 5 Other

Ingestion

Surface water

Ground water (landfill)

Consumer Use: DtD 2

Inhalation

Air: incineration (stack)

Air: fugitive

Consumer Use: CEM 3

Dermal

Consumer Use: CEM

Eco

Surface water: ADR

conc and/or PDM 4

Consumer Use: DtD

1 Assessment cycles are endpoint concentrations and dose calculations within the NCEM2 model.

2 Down-the-Drain

3 Consumer Exposure Model

4 Probabilistic Dilution Model

5 The threshold values for assessing endpoints are 1 mg/day for acute doses and 1 mg/year for chronic doses.

EAB DROP: Release information for this compound does not meet criteria for preparation of an exposure

assessment in the Exposure Assessment Branch = s (EAB) Initial Review Exposure Report (this report).