Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-12-33 

EPA Docket EPA-HQ-OPPT-2012-0182 

EPA SANITIZED Page 1 of 21
Index 

A-001 Structure Activity Team (SAT) Report for 

 PMN P-12-33 

A-002 Initial Review Engineering Report for 

 PMN P-12-33 

A-003 Initial Review Exposure Report for 

 PMN P-12-33 

EPA SANITIZED Page 2 of 21
A-001 

Structure Activity Team (SAT) Report 

for PMN P-12-33 

EPA SANITIZED Page 3 of 21
SAT Report

PMN Number: P-12-0033

SAT Date: 11/8/2011

Print Date: 12/5/2011

Related cases: CBI: Yes

Health related cases: 

Ecotox related cases: 

Concern levels:

Type of Concern: Health Eco Comments

Level of Concern: 1-2 2

 Persistence Bioaccum Toxicity Comments

1 12

Exposure Based Review:

Health: No

Ecotox: No

Routes of exposure: Health: Dermal Drinking Water Inhalation 

Ecotox: All releases to water

Fate: ;

Keywords:

 Keywords: NEURO, REPRO-M, LIVER, KIDNEY, LUNG, DEVEL, 

HYPERSENS, AQUATOX-A,C

Summary of Assessment:

 Fate:

Fate Summary: P-12-0033

FATE: 

Liquid with MP < 25 C (E)

log Kow = 3.74 (E) 

S = 61 mg/L at 25 C (E)

VP = 2.2E-2 torr at 25 C (NOMO5)

BP = 250 C (NOMO5) based on 122-124 C @ 9 mm Hg (M)

H = 3.97E-5 (E)

log Koc = 2.66 (E)

EPA SANITIZED Page 4 of 21
log Fish BCF = 2.13 (E)

log Fish BAF = 2.17 (E) 

POTW removal (%) = 50-90 via biodeg

Time for complete ultimate aerobic biodeg = mo

Sorption to soils/sediments = low - moderate

Volatilization half-life from a standard river = 22 hrs

Volatilization half-life from a standard lake = 15 da

Atmospheric Oxidation Half-life = 61hr via OH radical

PBT Potential: P1B1

*CEB FATE: Migration to ground water = moderate - rapid

 Health:

 Health Summary: Absorption is good all routes based on analogs. Expect 

hydrolysis of the ester by esterases in the body to yield tert-butylbenzoic acid. Concerns for 

neurotoxic effects, male reproductive toxicity, liver, kidney, and lung effects were supported in 

the Standard Review for P-tert-Butylbenzoic acid was reported to cause 

lesions in the kidney tubules, testes, and spinal cord at 0.52 g/m3 and greater in a 4-hr inhalation 

study in rats . The Standard Review for concluded that p-tert-butylbenzoic 

acid has been shown to induce testicular, kidney, and liver damage as low as 5 mg/kg when 

given orally over a 90-day period. With no established NOAEL. There is also concern for 

developmental toxicity and hypersensitivity by analogy to benzoic acid. Low moderate 

concern. 

 Ecotox:

Test 

Organism

Tes

t 

Typ

e

Test End 

Point

Predicted Measured Comments

fish 96-

h 

LC50 2.5

daphnid 48-

h

LC50 4.3

green 

algal

96-

h

EC50 1.4

fish _ chronic 

value

0.13

daphnid _ chronic 

value

1.8

algal _ chronic 

value

0.62

Sewage 

Sludge

3-h EC50 _

Sewage 

Sludge

_ Chronic 

Value

_

EPA SANITIZED Page 5 of 21
Ecotox Values Comments: Predictions are based on SARs for esters; SAR chemical class = 

ester; MW 192; log Kow = 3.74 (EPI); liquid with mp = unknown (P); S = 61 mg/L at 25 C (P); 

pH7; effective concentrations based on 100% active ingredients and nominal concentrations; 

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

Factors Values Comments

Assessment Factor 10

Concentration of Concern 

(ppb)

13

SARs esters

SAR Class ester new chemicals category: esters

Ecotox Category 

Ecotox Factors Comments: 

 SAT Chair: Becky Jones

EPA SANITIZED Page 6 of 21
A-002 

Initial Review Engineering Report 

for PMN P-12-33 

EPA SANITIZED Page 7 of 21
INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0033

Focus Ready Draft 11/21/2011

ENGINEER: Jon \ CLM

PV (kg/yr): 25,000 Import Only

SUBMITTER: Aceto Corporation

USE: Chemical intermediate for a coupler for imaging

products. L-11-344 from the same submitter is for the

same use. Synthetic sequence: P-12-33 -> P-11-578 ->

P-11-0579 + P-11-580 -> P-11-581 -> P-11-582 -> P-11-583

(ER, P-03-628).

OTHER USES: Analog , STN CA 155:94300:

polymerization catalyst; Analog : chemical

intermediate; STN CA 144:207370: chemical intermediate to

prepare herbicides; Analog : plasticizer; Analog

: wet cleaning system.

MSDS: Yes Label: Yes

Gen Eqpt: Eye/Face: tightly fitting safety goggles. //

Skin: wear protective gloves/clothing.

Respirator: In case of insufficient ventilation wear

suitable respiratory equipment.

Health Effects: Eyes: contact with eyes may cause

irritation. Avoid contact with eyes. // Skin: may be

harmful by skin contact. Substance may cause slight skin

irritation. Avoid contact with skin. // Inhalation: may

be harmful by inhalation. May cause irritation of the

mucous membranes. May cause irritation of respiratory

tract. Avoid breathing vapors or mists. // Ingestion: may

be harmful if swallowed. Do not ingest.

TLV/PEL:

none established

CRSS :

Chemical Name: Benzoic acid, 4-(1,1-dimethylethyl)-,

methyl ester

S-H20: 0.061 g/L @

VP: 2.2E-2 torr @

MW: 192.00 %<500 %<1000

Physical State and Misc CRSS Info:

Neat: Liquid Mfg: NK: Imported Proc/Form: NA End Use:

Destroyed. Submitted Data: Transparent, colorless liquid;

BP = 122-124°C at 9 torr (MSDS); density = 0.995 g/cm3.

Literature Data (STN eProp): BP = 110-112°C at 5 torr.

Estimated Data (NOMO5 with 122°C at 9 torr): BP = 249.9°C

at 760 torr; VP = 0.022 torr. Estimated Data (EPI with MP

= 20°C): WS = 0.061 g/L; log P = 3.74; BP = 252.15°C; VP

= 0.0243 torr. Estimated Data (STN/ACD Labs): WS = 0.15

g/L; log P = 3.972; BP = 257.6°C; VP = 0.0144 torr.

Consumer Use: No

SAT (concerns) (11/08/2011):

Related Cases and Related Cases and Misc SAT Info:

Ecotox Related Cases:

Page 1

EPA SANITIZED Page 8 of 21
Analogs: | Human

Health Related Cases: |

Migration to groundwater: Moderate to Rapid

PBT rating: P1B1T1 .

Health: 1-2 Dermal, Drinking Water, Inhalation

Eco: 2 Water (All releases to water with a CC = 13 ppb)

OCCUPATIONAL EXPOSURE RATING: 2A

NOTES & KEY ASSUMPTIONS:

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

PMN was formerly submitted as ; the submitter now

anticipates increased demand and submitted a full PMN.

This PMN is import only and is used as a chemical

intermediate. Therefore, only end use as an intermediate

is assessed. // Note, SAT concerns for dermal, inhalation,

 drinking water, and all releases to water with a CoC =

13 ppb and migration to gw = moderate to rapid. // This

PMN is volatile (VP > 0.001), therefore, air releases are

assessed. // For USE: This IRER assesses releases from

container cleaning to incineration or landfill

(submission); releases from equipment cleaning to

uncertain media; air releases are assessed during

unloading, container cleaning, and equipment cleaning (VP

> 0.001 torr). Both dermal and inhalation exposure are

assessed. // Same-submitter, same-use past case 

and different-submitter, same-use (intermediate) past

case were referenced for consistency. Both past

cases did not have the binding option marked and were

assessed at a PV of 10,000 kg/yr (consistent with this

IRER). Both past cases were import only (consistent with

this IRER). Both past cases were non-volatile. This IRER

assesses a volatile liquid and assesses air releases.

Both past cases assess dermal and inhalation exposure

(consistent with this IRER). Both past cases assume full

consumption of the PMN during use as an intermediate

(consistent with this IRER).

POLLUTION PREVENTION CONSIDERATIONS:

None.

EXPOSURE-BASED REVIEW: No

INITIAL REVIEW ENGINEERING REPORT 

PMN: 12-0033

USE: Chemical Intermediate

Number of Sites/ Location: 1

Eastman Business Park Rochester NY 14652

Days/yr: 63

Basis: Submission specifies 1 site, 400 kg/bt. ChemSTEER

calculates 63 bt/yr.

Process Description: PMN (100%, liquid) is imported --->

Charged to reaction vessel with other raw materials --->

Raw materials are heated to form another chemical

substance ---> PMN destroyed (submission, CRSS).

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources

Page 2

EPA SANITIZED Page 9 of 21
to the same medium.

Water or Incineration or Landfill

Conservative: 4.0E+0 kg/site-day over 63 days/yr from 1

site

or 2.5E+2 kg/yr

to: solvent recovery (submission)

from: Equipment Cleaning Losses of Liquids from a Single,

Large Vessel

basis: EPA/OPPT Single Vessel Residual Model, CEB

standard 1% residual. The submission estimates <0.5 kg/bt

released to a solvent recovery process from equipment

cleaning. Due to uncertainty in the effectiveness of this

process, CEB assesses release to uncertain media using

the CEB standard model. CEB standard estimate is an

order of magnitude higher than the submitter estimate.

Air

Typical: 4.5E-5 kg/site-day over 63 days/yr from 1 site

Worst Case: 9.0E-5 kg/site-day over 63 days/yr from 1 site

to: air (model)

from: Unloading Liquid Raw Material from Drums

basis: EPA/OAQPS AP-42 Loading Model.

Air

Output 2: 1.5E-6 kg/site-day over 63 days/yr from 1 site

to: air (model)

from: Cleaning Liquid Residuals from Drums Used to

Transport the Raw Material

basis: EPA/OPPT Penetration Model.

Air

Output 2: 3.0E-3 kg/site-day over 63 days/yr from 1 site

to: air (model)

from: Equipment Cleaning Losses of Liquids from a Single,

Large Vessel

basis: EPA/OPPT Mass Transfer Coefficient Model.

Incineration or Landfill

High End: 1.2E+1 kg/site-day over 63 days/yr from 1 site

or 7.5E+2 kg/yr

to: incineration or landfill (submission)

from: Cleaning Liquid Residuals from Drums Used to

Transport the Raw Material

basis: EPA/OPPT Drum Residual Model, CEB standard 3%

residual. The submission estimates <0.5 kg/bt PMN is

released to incineration or landfill from container

cleaning. As conservative, CEB assesses release to

incineration or landfill using the CEB standard model.

RELEASE TOTAL

1.0E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 3

Basis: The submission estimates 3 workers/site are

exposed to 100% PMN during unloading and cleaning.

Inhalation:

Exposure to Vapor (Class II)

Typical: 2.2E-2 mg/day over 63 days/yr

Page 3

EPA SANITIZED Page 10 of 21
Worst Case: 1.3E+0 mg/day over 63 days/yr

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

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT

Mass Balance Model.

NOTE: The respirator class is: II. Gas/vapor (all

substances in the gas form).

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 Liquid at 100.00% concentration

High End: 1.8E+3 mg/day over 63 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.

Page 4

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A-003 

Initial Review Exposure Report 

 for PMN P-12-33 

EPA SANITIZED Page 12 of 21
11/18/2011 Page of 

INITIAL REVIEW EXPOSURE REPORT (IRExR) 

 Chemical ID: P-12-0033 Reviewer: Bevington/BC 

 

 

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 = 

13 

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 

USE: Max 

ADR: max 

acute eco 

1.09E-04 --- 1.37E-04 --- 1.90E+00 --- --- --- --- --- --- 

USE: PDM1 --- --- --- --- 1.90E+00 0 --- --- --- --- --- 

USE: Max 

LADD 

--- 7.55E-07 --- 4.40E-07 --- --- 5.94E-04 --- --- --- --- 

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: 

EPA SANITIZED Page 13 of 21
11/18/2011 Page of 

 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P-12-0033 Assessor: Bevington/BC 

ENVIRONMENTAL RELEASES 

 Scenario#:1 Number of Release Sites: 1. 

 Release Activity: USE: Max ADR 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 252.00 0.00 N/A N/A 

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

 

 Non-sludge/Sludge 

Release Days/yr: 63.00 0.00/0.00 N/A N/A 

Per Site Release: 4.00 0.00/0.00 N/A N/A 

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

Remarks: 

EPA SANITIZED Page 14 of 21
11/18/2011 Page of 

INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P-12-0033 

SITE-SPECIFIC HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

SCENARIO NUMBER:1 RELEASE ACTIVITY: USE: Max ADR 

FACILITY NAME: EASTMAN KODAK CO 

FACILITY LOCATION: ROCHESTER NY 14652 

RECEIVING WATER NAME: GENESEE R 

REACH NUMBER: 04130003001 FACILITY ON REACH: Yes DISCHARGE TYPE: Direct 

NPDES PERMIT #: NY0001643 EXPOSED POPULATION: Adult 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PRETREATMENT 

RELEASE 

(kg/site/day) 

POSTTREATMENT 

RELEASE 

(kg/site/day) 

DWT 

(%) BCF 

(L/kg) 

50. 63. 4. 2.00 0.00 136.00 

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER 

FLOW DESCRIPTOR Harmonic Mean 30Q5 7Q10 1Q10 PLANT 

FLOW (MLD) 3565.85 1528.47 1054.21 851.75 NA 

CONCENTRATION (μg/L) 0.56 1.31 1.90 2.35 NA 

DRINKING WATER INGESTION AND FISH INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water 

Results 

Drinking Water 

Units 

Fish Ingestion 

Results 

Fish Ingestion 

Units 

Cancer 

LADDpot 7.55E-07 mg/kg/day 4.40E-07 mg/kg/day 

LADCpot 3.87E-05 mg/L 5.27E-03 mg/kg 

Acute 

ADRpot 1.09E-04 mg/kg/day 1.37E-04 mg/kg/day 

Surface Water Comments: 

EPA SANITIZED Page 15 of 21
11/18/2011 Page of 

 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P-12-0033 Assessor: Bevington/BC 

ENVIRONMENTAL RELEASES 

 Scenario#:2 Number of Release Sites: 1. 

 Release Activity: USE: PDM1 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 252.00 0.00 N/A N/A 

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

 

 Non-sludge/Sludge 

Release Days/yr: 63.00 0.00/0.00 N/A N/A 

Per Site Release: 4.00 0.00/0.00 N/A N/A 

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

Remarks: 

EPA SANITIZED Page 16 of 21
11/18/2011 Page of 

INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P-12-0033 

SITE-SPECIFIC HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

SCENARIO NUMBER:2 RELEASE ACTIVITY: USE: PDM1 

FACILITY NAME: EASTMAN KODAK CO 

FACILITY LOCATION: ROCHESTER NY 14652 

RECEIVING WATER NAME: GENESEE R 

REACH NUMBER: 04130003001 FACILITY ON REACH: Yes DISCHARGE TYPE: Direct 

NPDES PERMIT #: NY0001643 EXPOSED POPULATION: Adult 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PRETREATMENT 

RELEASE 

(kg/site/day) 

POSTTREATMENT 

RELEASE 

(kg/site/day) 

DWT 

(%) BCF 

(L/kg) 

50. 63. 4. 2.00 0.00 136.00 

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER 

FLOW DESCRIPTOR Harmonic Mean 30Q5 7Q10 1Q10 PLANT 

FLOW (MLD) 3565.85 1528.47 1054.21 851.75 NA 

CONCENTRATION (μg/L) 0.56 1.31 1.90 2.35 NA 

DRINKING WATER INGESTION AND FISH INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water 

Results 

Drinking Water 

Units 

Fish Ingestion 

Results 

Fish Ingestion 

Units 

Cancer 

LADDpot 7.55E-07 mg/kg/day 4.40E-07 mg/kg/day 

LADCpot 3.87E-05 mg/L 5.27E-03 mg/kg 

Acute 

ADRpot 1.09E-04 mg/kg/day 1.37E-04 mg/kg/day 

Surface Water Comments: 

EPA SANITIZED Page 17 of 21
11/18/2011 Page of 

INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P-12-0033 

SITE-SPECIFIC HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

SCENARIO NUMBER: 2 RELEASE ACTIVITY: USE: PDM1 

FACILITY NAME: EASTMAN KODAK CO 

FACILITY LOCATION: ROCHESTER NY 14652 

RECEIVING STREAM NAME: GENESEE R 

REACH NUMBER: 04130003001 FACILITY ON REACH: Yes DISCHARGE TYPE: Direct 

NPDES PERMIT NUMBER: NY0001643 GAGING STATION ID: N/A 

GAGING STATION 

PERIOD OF RECORD: N/A 

GAGING STATION 

NUMBER OF 

OBSERVATIONS: N/A 

NUMBER OF STATIONS ON 

REACH: N/A 

MEAN FLOW (MLD): 6914.59 7q10 FLOW (MLD): 1054.21 EFFLUENT FLOW (MLD):126.89

 

RESULTS 

COC (μg/L) 

Percent of Year 

COC Exceeded 

Number of Days 

COC Exceeded 

Release 

days/year 

Pre-treatment 

Loading 

(kg/site/day) 

Waste Water 

Treatment (%) 

13.00 0 0 63.00 4.00 50.00 

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11/18/2011 Page of 

 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P-12-0033 Assessor: Bevington/BC 

ENVIRONMENTAL RELEASES 

 Scenario#:3 Number of Release Sites: 1. 

 Release Activity: USE: Max LADD 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 252.00 1008.00 N/A N/A 

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

 

 Non-sludge/Sludge 

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

Per Site Release: 252.00 1008.00/0.00 N/A N/A 

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

Remarks: 

EPA SANITIZED Page 19 of 21
11/18/2011 Page of 

INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P-12-0033 

SITE-SPECIFIC HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

SCENARIO NUMBER:3 RELEASE ACTIVITY: USE: Max LADD 

FACILITY NAME: EASTMAN KODAK CO 

FACILITY LOCATION: ROCHESTER NY 14652 

RECEIVING WATER NAME: GENESEE R 

REACH NUMBER: 04130003001 FACILITY ON REACH: Yes DISCHARGE TYPE: Direct 

NPDES PERMIT #: NY0001643 EXPOSED POPULATION: Adult 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PRETREATMENT 

RELEASE 

(kg/site/day) 

POSTTREATMENT 

RELEASE 

(kg/site/day) 

DWT 

(%) BCF 

(L/kg) 

50. 1. 252. 126.00 0.00 136.00 

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER 

FLOW DESCRIPTOR Harmonic Mean 30Q5 7Q10 1Q10 PLANT 

FLOW (MLD) 3565.85 1528.47 1054.21 851.75 NA 

CONCENTRATION (μg/L) N/A N/A N/A N/A NA 

DRINKING WATER INGESTION AND FISH INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water 

Results 

Drinking Water 

Units 

Fish Ingestion 

Results 

Fish Ingestion 

Units 

Cancer 

LADDpot 7.55E-07 mg/kg/day 4.40E-07 mg/kg/day 

LADCpot 3.87E-05 mg/L 5.27E-03 mg/kg 

Acute 

ADRpot N/A mg/kg/day N/A mg/kg/day 

Surface Water Comments: 

EPA SANITIZED Page 20 of 21
11/18/2011 Page of 

INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P-12-0033 

DRINKING WATER EXPOSURE ESTIMATES FROM LANDFILL RELEASES 

SCENARIO #: 3 ACTIVITY: USE: 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 

 (%) 

1. 1008.00/1.00 0.00/0.00 Rapid 0.00 0.00 

 1 Landfilled sludge equals the fraction adsorbed to wastewater treatment sludge times the surface 

 water pre-treatment release.

 

 2 Migration Descriptor Log Koc Groundwater Concentration (GWC) 

 (mg/L per kg release)

 Negligible no migration None 

Negligible to slow > 4.5 3.21E-6 

Slow <4.5 to 3.5 2.67E-5 

Moderate <3.5 to 2.5 5.95E-5 

Rapid <2.5 7.55E-5 

 

ASSUMPTIONS 

 Exposure Units Results ED 

(years) 

AT 

(years) 

BW 

(kg) 

IR 

 (L/day) 

Cancer 

LADDpot (mg/kg/day) 5.94E-04 30.00 75.00 71.80 1.40 

LADCpot (mg/L) 3.04E-02 30.00 75.00 NA NA 

REMARKS: 

 

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