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March 10, 2011 

MEMORANDUM 

SUBJECT: Re-evaluation of the Proposed SNUR for P-94-209 in Light of the Olsson 

Frank Weeda letter 

FROM: 

 Toxicologist 

New Chemicals and Assessment Branch 

Risk Assessment Division (7403M) 

THRU: 

 

 New Chemicals and Assessment Branch 

 Risk Assessment Division (7403M) 

TO: 

Program Manager 

Chemical Control Division 

New Chemicals Management Branch (7405M) 

On November 10, 2010, EPA received a letter from the law offices of Olsson Frank 

Weeda speaking on behalf of Kaneka Texas Corporation. The letter was a petition to 

withdraw a proposed SNUR on P-94-209 (CASRN 134701-20-5, submitted 

by Ciba Specialty Chemicals Corporation) or, alternatively, to re-issue a proposed SNUR 

for the chemical. The proposed SNUR for P-94-209 was to require no releases to water. 

Ciba submitted a SNUN requesting permission to release to water in 2006. 

The SNUN was dropped at the November 2, 2006 Focus meeting, based on 2 measured 

biodegradation tests that were submitted by Ciba. 

RAD received a copy of the letter mentioned above on February 9, 2011 from 

(CCD). CCD asked RAD to reconcile issues raised in the letter pertaining to the 

following: 

1. RAD’s review of submitted biodegradation testing and the decision at the 

November 2, 2006 FOCUS meeting to drop the SNUN; 

2. the low ecotoxicity score assigned to this particular chemical in EPA’s 

Chemical Assessment and Management Program (CHAMP) 
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Upon re-evaluation of P-94-209 and the corresponding SNUN, several issues were 

brought to light. First, RAD stands by both (June 14 and July1,2010) reviews of the 

submitted measured biodegradation tests. These reviews stated that the biodegradation 

range was much too broad to be conclusive (23% and 87% depending on the protocol 

used). Second, RAD continues to support the classification of P-94-209 into the TSCA 

chemical category of phenols. This has not changed. However, since P-94-209 and 

 went to FOCUS Decision meetings, the ECOSAR dataset for phenols has been 

significantly updated from 78 chemicals to 203 chemicals. The additional number of data 

points has increased the robustness of the category as well as our confidence in the 

ECOSAR predictions. As a result, when the most recent version of ECOSAR (v. 1.00a) 

was run in 2011, the database predicts no adverse ecotoxicological effects at saturation 

for P-94-209. This is a significant change from the ECOSAR predictions in 1993-2006 

(see Attachment 1). Third, the measured water solubility data support no expected acute 

or chronic adverse ecological effects, based on log Kow of 10.45 for CASRN 134701-20-

5 (greater than a log Kow of 8, no acute or chronic adverse effects are expected to be 

observed). Therefore, based upon the new ECOSAR predictions, which are based on a 

more robust data set, RAD concludes that the ecological risk to P94-209 is low. 

Based on the above information, the discrepancy between the CHAMP characterization 

of the PMN substance and RAD’s previous reviews are no longer relevant. The CHAMP 

assessment of low hazard for the PMN substance was based on the most recent version of 

ECOSAR and RAD supports the designation in CHAMP. In addition, EPA 

acknowledges, as stated in the Olsson, Frank, Weeda letter, the overall conclusions of 

both EPA’s and Australia’s National Industrial Chemicals Notification and Assessment 

Scheme (NICNAS) that CASRN 134701-20-5 is a “low” ecotoxicological hazard. 

In summary, after considering the contents of the letter from Olsson, Frank, Weeda and 

re-evaluating P-94-209 based on the most up-to-date information, RAD has determined 

that P94-209 is a low ecological risk. As a result, RAD would support revoking the 

proposed SNUR requiring no releases to water based on physical/chemical data, 

predictive tools, and best professional judgment. 
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Attachment 1 

PMN P-94-0209: Phenol 2,4-dimethyl-6-(1-methylpentadecyl) 

Physical State: Liquid 

Sorption to soils/sediment: Very strong 

MW: 347 

VP: 7.5 10-7 mm Hg at 25° C (measured) 

Water solubility: 0.016 mg/L (measured) 

POTW removal: 90% 

Ultimate biodegradation t1/2: weeks 

Log BCF: < 10 (measured) 

Log Kow: 10.45 (estimated) 

1993-2006 

ECOTOX predicted (P) and measured (M) toxicity values in mg/L (PPM) are: 

fish 96-h LC50 = * P 

fish 96-h LC50 = * M 

daphnia 48-h EC50 = * P 

daphnia 48-h EC50 = 0.080 Ma 

algae 96-h EC50 = * P 

algae 72-h EC50 = 25 Ma

fish ChV = 0.001 P 

daphnia ChV = 0.001 P 

algae ChV = 0.001 P a

Measured concentrations are significantly greater than the water solubility limit of 0.016 mg/L. 

2011 

ECOTOX : Predicted (P) toxicity values in mg a.i./L (PPM) are: 

fish 96-h LC50 = * P 

fish 96-h LC50 = * M 

daphnid 48-h LC50 = * P 

daphnia 48-h EC50 = 0.080 Ma

 

algae 96-h EC50 = * P 

algae 72-h EC50 = 25 Ma

fish ChV = * P 

daphnid ChV = * P 

algae ChV = * P 

a

Measured concentrations are significantly greater than the water solubility limit of 0.016 mg/L.