Support Documents for 

Significant New Use Rules (SNURs) on 

Premanufacture Notices (PMNs) 

P-09-152 and P-09-153 

EPA Docket EPA-HQ-OPPT-2010-1075 

 

EPA SANITIZED Page 1 of 59
Index

A-001 Structure Activity Team (SAT) Reports for 

PMNs P-09-152 and P-09-153 

A-002 Initial Review Engineering Reports for 

PMNs P-09-152 and P-09-153 

A-003 Initial Review Exposure Reports for 

PMNs P-09-152 and P-09-153 

EPA SANITIZED Page 2 of 59
A-001 

Structure Activity Team (SAT) Reports 

 for PMNs P-09-152 and P-09-153 

 

EPA SANITIZED Page 3 of 59
SAT Report

PMN Number: P-09-0152

SAT Date: 1/16/2009

Related cases:

Health related cases: 

Ecotox related cases: 

Concern levels:

Type of Concern: Health Eco Comments

Level of Concern: 1-2 2

 Persistence Bioaccum Toxicity Comments

 2 1 2

Exposure Based Review:

Health:

Ecotox: No

Routes of exposure: Health: Inhalation, drinking water

Ecotox: All releases to water

Fate: ;

P2Rec Comments:

Comment: SAT had no comment

Keywords:

 Keywords: DEVEL; MUTA; BLOOD; ONCO; SENS (UNCERT); MALE 

REPRO (UNCERT); AQUATOX

Summary of Assessment:

 Fate:

Fate Summary: P-09-0152-53

FATE: 

Solid

S = 75 g/L at 25 C (M)

VP < 1.0E-6 torr at 25 EC (E)

BP > 400 EC (E)

H < 1.00E-8 (E)

POTW removal (%) = 0

Time for complete ultimate aerobic biodeg = mo

EPA SANITIZED Page 4 of 59
Time for primary anaerobic biodeg # da

Sorption to soils/sediments = low - moderate

PBT Potential: P2B1

*CEB FATE: Migration to ground water = negl

 Health:

 Health Summary: Not absorbed from the skin or the GI tract intact, 

absorbed from the lung (pchem); expect dissociation from the 2:1 complex to the 1:1 complex 

with <5% bioavailability of based on data for expect reduction in both moieties 

and group reduction for the moieties containing that group; and absorption of the 

reduction products from the GI tract (analog). Concern for blood toxicity (methemoglobinemia) 

and uncertain concern for male reproductive toxicity based on submitted test data for 

 Concern for developmental toxicity, mutagenicity, and 

methemoglobinemia for the reduction product; mutagenicity, 

oncogenicity, and developmental toxicity for the naphthylamine reduction product based on

; developmental toxicity, mutagenicity, oncogenicity, and blood toxicity for the 

 reduction product. Uncertain concern for developmental toxicity and mutagenicity 

for to the extent that it is bioavailable.

 Test Data: For (-) Salmonella with 

and without activation; (-) E. coli with and without activation; (-) for chromosome aberrations in 

CHL cells with and without activation; rat oral LD0 = 2000 mg/kg; rat dermal LD0 = 2000 

mg/kg; slight eye irritation in rabbits, cleared by 48 hours; no skin irritation in rabbits; no skin 

sensitization in guinea pigs using the Magnusson-Kligman assay; rat 28-day oral NOEL = 200 

mg/kg, blood toxicity and discolored organs, including the testes, at 1000 mg/kg

 Ecotox:

Test 

Organism

Test 

Type

Test End 

Point

Predicted Measured Comments

fish 96-h LC50 7.0

daphnid 48-h LC50 7.0

green algal 96-h EC50 3.0 shading

fish _ chronic value 1.1

daphnid chronic value 1.1

algal _ chronic value 0.30 shading

Sewage Sludge 3-h EC50 _

Sewage Sludge _ Chronic Value _

Ecotox Values Comments: Predictions are based on SAR-nearest analog method for 

 and indirect effect of algal 

shading from the ; SAR chemical class = MW 1026/924; pH7; 

effective concentrations based on 100% active ingredients and mean measured concentrations; 

hardness <180.0 mg/L as CaCO3; and TOC <2.0 mg/L;

Factors Values Comments

EPA SANITIZED Page 5 of 59
Assessment Factor 10

Concentration of Concern 

(ppb)

30

SARs

SAR Class

Ecotox Factors Comments: 

 SAT Chair: L Keifer 564-8916

EPA SANITIZED Page 6 of 59
SAT Report

PMN Number: P-09-0153

SAT Date: 1/16/2009

Related cases:

Health related cases: 

Ecotox related cases: 

Concern levels:

Type of Concern: Health Eco Comments

Level of Concern: 1-2 2

 Persistence Bioaccum Toxicity Comments

 2 1 2

Exposure Based Review:

Health:

Ecotox: No

Routes of exposure: Health: Inhalation, drinking water

Ecotox: All releases to water

Fate: ;

P2Rec Comments:

Comment: SAT had no comment

Keywords:

 Keywords: DEVEL; MUTA; BLOOD; ONCO; SENS (UNCERT); MALE 

REPRO (UNCERT); AQUATOX

Summary of Assessment:

 Fate:

Fate Summary: P-09-0152-53

FATE: 

Solid

S = 75 g/L at 25 C (M)

VP < 1.0E-6 torr at 25 EC (E)

BP > 400 EC (E)

H < 1.00E-8 (E)

POTW removal (%) = 0

Time for complete ultimate aerobic biodeg = mo

EPA SANITIZED Page 7 of 59
Time for primary anaerobic biodeg # da

Sorption to soils/sediments = low - moderate

PBT Potential: P2B1

*CEB FATE: Migration to ground water = negl

 Health:

 Health Summary: Not absorbed from the skin or the GI tract intact, 

absorbed from the lung (pchem); expect dissociation from the 2:1 complex to the 1:1 complex 

with <5% bioavailability of based on data for expect reduction in both moieties 

and group reduction for the moieties containing that group; and absorption of the 

reduction products from the GI tract (analog). Concern for blood toxicity (methemoglobinemia) 

and uncertain concern for male reproductive toxicity based on submitted test data for 

 Concern for developmental toxicity, mutagenicity, and 

methemoglobinemia for the reduction product; mutagenicity, 

oncogenicity, and developmental toxicity for the reduction product based on 

; developmental toxicity, mutagenicity, oncogenicity, and blood toxicity for the 

 reduction product. Uncertain concern for developmental toxicity and mutagenicity 

for to the extent that it is bioavailable.

 Test Data: For (-) Salmonella with 

and without activation; (-) E. coli with and without activation; (-) for chromosome aberrations in 

CHL cells with and without activation; rat oral LD0 = 2000 mg/kg; rat dermal LD0 = 2000 

mg/kg; slight eye irritation in rabbits, cleared by 48 hours; no skin irritation in rabbits; no skin 

sensitization in guinea pigs using the Magnusson-Kligman assay; rat 28-day oral NOEL = 200 

mg/kg, blood toxicity and discolored organs, including the testes, at 1000 mg/kg

 Ecotox:

Test 

Organism

Test 

Type

Test End 

Point

Predicted Measured Comments

fish 96-h LC50 7.0

daphnid 48-h LC50 7.0

green algal 96-h EC50 3.0 shading

fish _ chronic value 1.1

daphnid chronic value 1.1

algal _ chronic value 0.30 shading

Sewage Sludge 3-h EC50 _

Sewage Sludge _ Chronic Value _

Ecotox Values Comments: Predictions are based on SAR-nearest analog method for 

 and indirect effect of algal 

shading from the ; SAR chemical class = MW 1026/924; pH7; 

effective concentrations based on 100% active ingredients and mean measured concentrations; 

hardness <180.0 mg/L as CaCO3; and TOC <2.0 mg/L;

Factors Values Comments

EPA SANITIZED Page 8 of 59
Assessment Factor 10

Concentration of Concern 

(ppb)

30

SARs

SAR Class

Ecotox Factors Comments: 

 SAT Chair: L Keifer 564-8916

EPA SANITIZED Page 9 of 59
A-002 

Initial Review Engineering Reports 

for PMNs P-09-152 and P-09-153 

 

EPA SANITIZED Page 10 of 59
INITIAL REVIEW ENGINEERING REPORT

P-09-0152 C

P-09-0152, P-09-0153

Focus Ready Draft 1/26/2009

ENGINEER: Prothero \ CPW

PV (kg/yr): 

Revision Notes/Assessment Overview:

SUBMITTER:

USE:

OTHER USES:

MSDS: LABEL: 

Gen Eqpt:

Respirator:

Health Effects:

TLV/PEL: 

CRSS: 

Chemical Name:

Chemical Category: 

S-H2O: g/L @ 

VP: torr @ 

MW: %<500 %<1000

Physical State and Misc CRSS Info:

Neat: Mfg: 

Proc/Form: End Use

Consumer Use:

SAT (concerns):

Migration to groundwater:

PBT rating: 

Health:

Eco:

OCCUPATIONAL EXPOSURE RATING:

NOTES & KEY ASSUMPTIONS:

EPA SANITIZED Page 11 of 59
Generated by the 06/07/2005 version of ChemSTEER. 

POLLUTION PREVENTION CONSIDERATIONS:

P2 Claim: 

P2 REC:

EXPOSURE-BASED REVIEW: 

EPA SANITIZED Page 12 of 59
P-09-0152 C

P-09-0152, P-09-0153

 

 

EPA SANITIZED Page 13 of 59
P-09-0152 C

P-09-0152, P-09-0153

EPA SANITIZED Page 14 of 59
 

EPA SANITIZED Page 15 of 59
INITIAL REVIEW ENGINEERING REPORT

P-09-0152 C

P-09-0152, P-09-0153

Focus Ready Draft 1/26/2009

ENGINEER: Prothero \ CPW

PV (kg/yr): 

Revision Notes/Assessment Overview:

SUBMITTER:

USE:

OTHER USES:

MSDS: LABEL: 

Gen Eqpt:

Respirator:

Health Effects:

TLV/PEL: 

CRSS: 

Chemical Name:

Chemical Category: 

S-H2O: g/L @ 

VP: torr @ 

MW: %<500 %<1000

Physical State and Misc CRSS Info:

Neat: Mfg: 

Proc/Form: End Use

Consumer Use:

SAT (concerns):

Migration to groundwater:

PBT rating: 

Health:

Eco:

OCCUPATIONAL EXPOSURE RATING:

NOTES & KEY ASSUMPTIONS:

EPA SANITIZED Page 16 of 59
Generated by the 06/07/2005 version of ChemSTEER. 

POLLUTION PREVENTION CONSIDERATIONS:

P2 Claim: 

P2 REC:

EXPOSURE-BASED REVIEW: 

EPA SANITIZED Page 17 of 59
P-09-0152 C

P-09-0152, P-09-0153

 

 

EPA SANITIZED Page 18 of 59
P-09-0152 C

P-09-0152, P-09-0153

EPA SANITIZED Page 19 of 59
 

EPA SANITIZED Page 20 of 59
A-003 

Initial Review Exposure Reports

for PMNs P-09-152 and P-09-153

EPA SANITIZED Page 21 of 59
1/23/09 Page of 

INITIAL REVIEW EXPOSURE REPORT (IRExR) 

 Chemical ID: P090152c 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 

7Q10 

CC=30 

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 

PROC: max ADR, 

LADD, PDM 1.57E-03 6.75E-06 --- --- 32.22 8 --- --- --- --- --- 

USE: max ADR, 

LADD, PDM 4.14E-02 4.62E-04 --- --- 905.66 184 --- --- --- --- --- 

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. 

Fate test recommendations: None 

EPA SANITIZED Page 22 of 59
1/23/09 Page of 

 

 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P090152c Assessor: Kwon 

ENVIRONMENTAL RELEASES 

 Scenario#:1 Number of Release Sites: 1. 

 

 

Remarks: 

EPA SANITIZED Page 23 of 59
1/23/09 Page of 

INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P090152c 

SIC-CODE BASED HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

SCENARIO #: 1 Number of Sites: 1 RELEASE ACTIVITY:PROC: 

max ADR, LADD, PDM 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PRETREATMENT 

RELEASE 

(kg/site/day) 

POSTTREATMENT 

RELEASE 

(kg/site/day) 

DWT 

(%) BCF 

(L/kg) 

0.00 50. 0.25 0.25 0.00 0.00 

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER 

PLANT 

TYPE 

% ILE 

FACILITY 

STREAM FLOW (MLD) STREAM CONC. (μg/l) 

Harmonic 

Mean 30Q5 7Q10 1Q10 

Harmonic 

Mean 30Q5 7Q10 1Q10 

ALL 50 288.00 123.84 78.18 66.05 0.87 2.02 3.20 3.79 

ALL 10 39.60 13.29 7.76 7.57 6.31 18.81 32.22 33.03 

DRINKING WATER AND FISH INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water Results Drinking 

Water Units Fish Ingestion Results 

Fish 

Ingestion 

Units 

50% 10% 50% 10% 

Cancer 

LADDpot 9.27E-07 6.75E-06 mg/kg/day 0.00 0.00 mg/kg/day 

LADCpot 4.76E-05 3.46E-04 mg/L 0.00 0.00 mg/kg 

Acute 

ADRpot 1.69E-04 1.57E-03 mg/kg/day 0.00 0.00 mg/kg/day 

SIC Code Comments: 

EPA SANITIZED Page 24 of 59
1/23/09 Page of 

INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P090152c 

SIC CODE EXPOSURES TO SURFACE WATER RELEASES 

SCENARIO #: 1 RELEASE ACTIVITY: PROC: max ADR, LADD, PDM 

SIC CODE RESULTS 

COC (μg/L) 

Percent of 

Year COC 

Exceeded 

Number of 

Days COC 

Exceeded 

Release 

days/year 

Loading 

(kg/site/day) 

Waste Water 

Treatment (%) 

High/Avg 

Analysis 

30.00 2 8 50.00 0.25 0.00 High 

EPA SANITIZED Page 25 of 59
1/23/09 Page of 

 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P090152c Assessor: 

ENVIRONMENTAL RELEASES 

 

 

 

 

EPA SANITIZED Page 26 of 59
1/23/09 Page of 

INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P090152c 

SIC-CODE BASED HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

SCENARIO #: 2 Number of Sites: 25 RELEASE ACTIVITY:USE: max 

ADR, LADD, PDM 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PRETREATMENT 

RELEASE 

(kg/site/day) 

POSTTREATMENT 

RELEASE 

(kg/site/day) 

DWT 

(%) BCF 

(L/kg) 

0.00 250. 0.96 0.96 0.00 0.00 

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER 

PLANT 

TYPE 

% ILE 

FACILITY 

STREAM FLOW (MLD) STREAM CONC. (μg/l) 

Harmonic 

Mean 30Q5 7Q10 1Q10 

Harmonic 

Mean 30Q5 7Q10 1Q10 

ALL 50 125.56 44.02 26.80 22.53 7.65 21.81 35.82 42.61 

ALL 10 11.11 1.94 1.06 0.96 86.41 494.85 905.66 1000.00 

DRINKING WATER AND FISH INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water Results Drinking 

Water Units Fish Ingestion Results 

Fish 

Ingestion 

Units 

50% 10% 50% 10% 

Cancer 

LADDpot 4.08E-05 4.62E-04 mg/kg/day 0.00 0.00 mg/kg/day 

LADCpot 2.09E-03 2.37E-02 mg/L 0.00 0.00 mg/kg 

Acute 

ADRpot 1.82E-03 4.14E-02 mg/kg/day 0.00 0.00 mg/kg/day 

SIC Code Comments: 

EPA SANITIZED Page 27 of 59
1/23/09 Page of 

INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P090152c 

SIC CODE EXPOSURES TO SURFACE WATER RELEASES 

Remarks: COC exceeded for > 20 days. 

EPA SANITIZED Page 28 of 59
1/23/09 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. 

EPA SANITIZED Page 29 of 59
1/23/09 Page of 

INITIAL REVIEW EXPOSURE REPORT (IRExR) 

 

 

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 

7Q10 

CC=30 

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 

PROC: max ADR, 

LADD, PDM 1.57E-03 6.75E-06 --- --- 32.22 8 --- --- --- --- --- 

USE: max ADR, 

LADD, PDM 4.14E-02 4.62E-04 --- --- 905.66 184 --- --- --- --- --- 

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. 

Fate test recommendations: None 

EPA SANITIZED Page 30 of 59
1/23/09 Page of 

 

 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P090152c Assessor: Kwon 

 

 

 

 

 

 

 

EPA SANITIZED Page 31 of 59
1/23/09 Page of 

INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P090152c 

SIC-CODE BASED HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

SCENARIO #: 1 Number of Sites: 1 RELEASE ACTIVITY:PROC: 

max ADR, LADD, PDM 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PRETREATMENT 

RELEASE 

(kg/site/day) 

POSTTREATMENT 

RELEASE 

(kg/site/day) 

DWT 

(%) BCF 

(L/kg) 

0.00 50. 0.25 0.25 0.00 0.00 

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER 

PLANT 

TYPE 

% ILE 

FACILITY 

STREAM FLOW (MLD) STREAM CONC. (μg/l) 

Harmonic 

Mean 30Q5 7Q10 1Q10 

Harmonic 

Mean 30Q5 7Q10 1Q10 

ALL 50 288.00 123.84 78.18 66.05 0.87 2.02 3.20 3.79 

ALL 10 39.60 13.29 7.76 7.57 6.31 18.81 32.22 33.03 

DRINKING WATER AND FISH INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water Results Drinking 

Water Units Fish Ingestion Results 

Fish 

Ingestion 

Units 

50% 10% 50% 10% 

Cancer 

LADDpot 9.27E-07 6.75E-06 mg/kg/day 0.00 0.00 mg/kg/day 

LADCpot 4.76E-05 3.46E-04 mg/L 0.00 0.00 mg/kg 

Acute 

ADRpot 1.69E-04 1.57E-03 mg/kg/day 0.00 0.00 mg/kg/day 

SIC Code Comments: 

EPA SANITIZED Page 32 of 59
1/23/09 Page of 

INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P090152c 

SIC CODE EXPOSURES TO SURFACE WATER RELEASES 

g/site/day) 

Waste Water 

Treatment (%) 

High/Avg 

Analysis 

30.00 2 8 50.00 0.25 0.00 High 

EPA SANITIZED Page 33 of 59
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 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P090152c Assessor: 

 

 

 

 

 

 

 

EPA SANITIZED Page 34 of 59
1/23/09 Page of 

INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P090152c 

SIC-CODE BASED HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PRETREATMENT 

RELEASE 

(kg/site/day) 

POSTTREATMENT 

RELEASE 

(kg/site/day) 

DWT 

(%) BCF 

(L/kg) 

0.00 250. 0.96 0.96 0.00 0.00 

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER 

PLANT 

TYPE 

% ILE 

FACILITY 

STREAM FLOW (MLD) STREAM CONC. (μg/l) 

Harmonic 

Mean 30Q5 7Q10 1Q10 

Harmonic 

Mean 30Q5 7Q10 1Q10 

ALL 50 125.56 44.02 26.80 22.53 7.65 21.81 35.82 42.61 

ALL 10 11.11 1.94 1.06 0.96 86.41 494.85 905.66 1000.00 

DRINKING WATER AND FISH INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water Results Drinking 

Water Units Fish Ingestion Results 

Fish 

Ingestion 

Units 

50% 10% 50% 10% 

Cancer 

LADDpot 4.08E-05 4.62E-04 mg/kg/day 0.00 0.00 mg/kg/day 

LADCpot 2.09E-03 2.37E-02 mg/L 0.00 0.00 mg/kg 

Acute 

ADRpot 1.82E-03 4.14E-02 mg/kg/day 0.00 0.00 mg/kg/day 

SIC Code Comments: 

EPA SANITIZED Page 35 of 59
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INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P090152c 

SIC CODE EXPOSURES TO SURFACE WATER RELEASES 

SIC CODE RESULTS 

COC (μg/L) 

Percent of 

Year COC 

Exceeded 

Number of 

Days COC 

Exceeded 

Release 

days/year 

Loading 

(kg/site/day) 

Waste Water 

Treatment (%) 

High/Avg 

Analysis 

30.00 50 184 250.00 0.96 0.00 High 

Remarks: COC exceeded for > 20 days. 

EPA SANITIZED Page 36 of 59
1/23/09 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. 

EPA SANITIZED Page 37 of 59
03/23/2009 

POST-FOCUS EXPOSURE REPORT 

 

 

 

 

 

 

 

EPA SANITIZED Page 38 of 59
03/23/2009 

POST-FOCUS EXPOSURE REPORT 

Chemical ID: P090152c Assessor: 

 

 

 

 

 

 

 

 

EPA SANITIZED Page 39 of 59
03/23/2009 

POST-FOCUS EXPOSURE REPORT 

 Chemical ID: P090152c 

SIC-CODE BASED HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

 

 

 

 

 

 

EPA SANITIZED Page 40 of 59
03/23/2009 

POST-FOCUS EXPOSURE REPORT 

Chemical ID: P090152C Assessor: 

 

 

 

 

 

 

 

EPA SANITIZED Page 41 of 59
03/23/2009 

POST-FOCUS EXPOSURE REPORT 

 Chemical ID: P090152C 

SIC-CODE BASED HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

SCENARIO #: 2 Number of Sites: 25 RELEASE ACTIVITY:Use: max 

PDM 

: Adult 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PRETREATMENT 

RELEASE 

(kg/site/day) 

POSTTREATMENT 

RELEASE 

(kg/site/day) 

DWT 

(%) BCF 

(L/kg) 

0.00 250. 0.0026 2.60E-03 0.00 0.00 

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER 

PLANT 

TYPE 

% ILE 

FACILITY 

STREAM FLOW (MLD) STREAM CONC. (μg/l) 

Harmonic 

Mean 30Q5 7Q10 1Q10 

Harmonic 

Mean 30Q5 7Q10 1Q10 

ALL 50 125.56 44.02 26.80 22.53 2.07E-02 5.91E-02 9.70E-02 0.12 

ALL 10 11.11 1.94 1.06 0.96 0.23 1.34 2.45 2.71 

DRINKING WATER AND FISH INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water Results Drinking 

Water Units Fish Ingestion Results 

Fish 

Ingestion 

Units 

50% 10% 50% 10% 

Cancer 

LADDpot 1.11E-07 1.25E-06 mg/kg/day 0.00 0.00 mg/kg/day 

LADCpot 5.67E-06 6.41E-05 mg/L 0.00 0.00 mg/kg 

Acute 

ADRpot 4.94E-06 1.12E-04 mg/kg/day 0.00 0.00 mg/kg/day 

SIC Code Comments: 

EPA SANITIZED Page 42 of 59
03/23/2009 

POST-FOCUS EXPOSURE REPORT 

 Chemical ID: P090152C 

SIC CODE EXPOSURES TO SURFACE WATER RELEASES 

SCENARIO #: 2 RELEASE ACTIVITY: Use: max PDM 

SIC CODE RESULTS 

COC (μg/L) 

Percent of 

Year COC 

Exceeded 

Number of 

Days COC 

Exceeded 

Release 

days/year 

Loading 

(kg/site/day) 

Waste Water 

Treatment (%) 

High/Avg 

Analysis 

30.00 0 1 250.00 2.60E-03 0.00 High 

EPA SANITIZED Page 43 of 59
03/23/2009 

POST-FOCUS EXPOSURE REPORT 

Chemical ID: P090152C Assessor: 

ENVIRONMENTAL RELEASES 

 

 

 

 

EPA SANITIZED Page 44 of 59
03/23/2009 

POST-FOCUS EXPOSURE REPORT 

 Chemical ID: P090152C 

SIC-CODE BASED HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

SCENARIO #: 3 Number of Sites: 25 RELEASE ACTIVITY: Use: max 

ADR 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PRETREATMENT 

RELEASE 

(kg/site/day) 

POSTTREATMENT 

RELEASE 

(kg/site/day) 

DWT 

(%) BCF 

(L/kg) 

0.00 1. 0.22 0.22 0.00 0.00 

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER 

PLANT 

TYPE 

% ILE 

FACILITY 

STREAM FLOW (MLD) STREAM CONC. (μg/l) 

Harmonic 

Mean 30Q5 7Q10 1Q10 

Harmonic 

Mean 30Q5 7Q10 1Q10 

ALL 50 125.56 44.02 26.80 22.53 1.75 5.00 8.21 9.76 

ALL 10 11.11 1.94 1.06 0.96 19.80 113.40 207.55 229.17 

DRINKING WATER AND FISH INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water Results Drinking 

Water Units Fish Ingestion Results 

Fish 

Ingestion 

Units 

50% 10% 50% 10% 

Cancer 

LADDpot 3.74E-08 4.23E-07 mg/kg/day 0.00 0.00 mg/kg/day 

LADCpot 1.92E-06 2.17E-05 mg/L 0.00 0.00 mg/kg 

Acute 

ADRpot 4.18E-04 9.48E-03 mg/kg/day 0.00 0.00 mg/kg/day 

SIC Code Comments: 

EPA SANITIZED Page 45 of 59
03/23/2009 

POST-FOCUS EXPOSURE REPORT 

Chemical ID: P090152C Assessor: 

 

 

 

 

 

 

 

EPA SANITIZED Page 46 of 59
03/23/2009 

POST-FOCUS EXPOSURE REPORT 

 Chemical ID: P090152C 

SIC-CODE BASED HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

SCENARIO #: 4 Number of Sites: 25 RELEASE ACTIVITY: Use: max 

LADD 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PRETREATMENT 

RELEASE 

(kg/site/day) 

POSTTREATMENT 

RELEASE 

(kg/site/day) 

DWT 

(%) BCF 

(L/kg) 

0.00 1. 0.87 0.87 0.00 0.00 

DRINKING WATER AND FISH INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water Results Drinking 

Water Units Fish Ingestion Results 

Fish 

Ingestion 

Units 

50% 10% 50% 10% 

Cancer 

LADDpot 1.48E-07 1.67E-06 mg/kg/day 0.00 0.00 mg/kg/day 

LADCpot 7.59E-06 8.58E-05 mg/L 0.00 0.00 mg/kg 

SIC Code Comments: 

EPA SANITIZED Page 47 of 59
03/23/2009 

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 exceedance 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. 

EPA SANITIZED Page 48 of 59
03/23/2009 

POST-FOCUS EXPOSURE REPORT 

Updated according to new engineering report, Post-Focus Draft Revision 2, 3/23/2009, to add water releases 

from processing. 

 

 

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 

7Q10 

CC=30

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

PROC: max 

ADR, max 

LADD, max 

acute eco 

1.45E05 8.69E-09 --- --- 0.30 --- --- --- --- --- --- 

USE: max 

PDM --- --- --- --- 2.45 1 --- --- --- --- --- 

USE: max 

ADR; max 

acute eco 

9.48E03 --- --- --- 207.55 --- --- --- --- --- --- 

USE: max 

LADD 

--- 1.67E-0 6 --- --- --- --- --- --- --- --- --- 

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. 

Fate test recommendations: None 

EPA SANITIZED Page 49 of 59
03/23/2009 

POST-FOCUS EXPOSURE REPORT 

 

 

 

 

 

 

/

Remarks: 

EPA SANITIZED Page 50 of 59
03/23/2009 

POST-FOCUS EXPOSURE REPORT 

 Chemical ID: P090152c 

SIC-CODE BASED HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PRETREATMENT 

RELEASE 

(kg/site/day) 

POSTTREATMENT 

RELEASE 

(kg/site/day) 

DWT 

(%) BCF 

(L/kg) 

0.00 7. 0.0023 2.30E-03 0.00 0.00 

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER 

PLANT 

TYPE 

% ILE 

FACILITY 

STREAM FLOW (MLD) STREAM CONC. (μg/l) 

Harmonic 

Mean 30Q5 7Q10 1Q10 

Harmonic 

Mean 30Q5 7Q10 1Q10 

ALL 50 288.00 123.84 78.18 66.05 7.99E-03 1.86E-02 2.94E-02 3.48E-02

ALL 10 39.60 13.29 7.76 7.57 5.81E-02 0.17 0.30 0.30 

DRINKING WATER AND FISH INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water Results Drinking 

Water Units Fish Ingestion Results 

Fish 

Ingestion 

Units 

50% 10% 50% 10% 

Cancer 

LADDpot 1.19E-09 8.69E-09 mg/kg/day 0.00 0.00 mg/kg/day 

LADCpot 6.13E-08 4.46E-07 mg/L 0.00 0.00 mg/kg 

Acute 

ADRpot 1.55E-06 1.45E-05 mg/kg/day 0.00 0.00 mg/kg/day 

SIC Code Comments: 

EPA SANITIZED Page 51 of 59
03/23/2009 

POST-FOCUS EXPOSURE REPORT 

Chemical ID: P090152C Assessor: 

ENVIRONMENTAL RELEASES 

 

 

 

 

 

EPA SANITIZED Page 52 of 59
03/23/2009 

POST-FOCUS EXPOSURE REPORT 

 Chemical ID: P090152C 

SIC-CODE BASED HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PRETREATMENT 

RELEASE 

(kg/site/day) 

POSTTREATMENT 

RELEASE 

(kg/site/day) 

DWT 

(%) BCF 

(L/kg) 

0.00 250. 0.0026 2.60E-03 0.00 0.00 

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER 

PLANT 

TYPE 

% ILE 

FACILITY 

STREAM FLOW (MLD) STREAM CONC. (μg/l) 

Harmonic 

Mean 30Q5 7Q10 1Q10 

Harmonic 

Mean 30Q5 7Q10 1Q10 

ALL 50 125.56 44.02 26.80 22.53 2.07E-02 5.91E-02 9.70E-02 0.12 

ALL 10 11.11 1.94 1.06 0.96 0.23 1.34 2.45 2.71 

DRINKING WATER AND FISH INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water Results Drinking 

Water Units Fish Ingestion Results 

Fish 

Ingestion 

Units 

50% 10% 50% 10% 

Cancer 

LADDpot 1.11E-07 1.25E-06 mg/kg/day 0.00 0.00 mg/kg/day 

LADCpot 5.67E-06 6.41E-05 mg/L 0.00 0.00 mg/kg 

Acute 

ADRpot 4.94E-06 1.12E-04 mg/kg/day 0.00 0.00 mg/kg/day 

SIC Code Comments: 

EPA SANITIZED Page 53 of 59
03/23/2009 

POST-FOCUS EXPOSURE REPORT 

 Chemical ID: P090152C 

SIC CODE EXPOSURES TO SURFACE WATER RELEASES 

SIC CODE RESULTS 

COC (μg/L) 

Percent of 

Year COC 

Exceeded 

Number of 

Days COC 

Exceeded 

Release 

days/year 

Loading 

(kg/site/day) 

Waste Water 

Treatment (%) 

High/Avg 

Analysis 

30.00 0 1 250.00 2.60E-03 0.00 High 

EPA SANITIZED Page 54 of 59
03/23/2009 

POST-FOCUS EXPOSURE REPORT 

Chemical ID: P090152C Assessor: 

 

 

 

Remarks: 

EPA SANITIZED Page 55 of 59
03/23/2009 

POST-FOCUS EXPOSURE REPORT 

 Chemical ID: P090152C 

SIC-CODE BASED HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PRETREATMENT 

RELEASE 

(kg/site/day) 

POSTTREATMENT 

RELEASE 

(kg/site/day) 

DWT 

(%) BCF 

(L/kg) 

0.00 1. 0.22 0.22 0.00 0.00 

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER 

PLANT 

TYPE 

% ILE 

FACILITY 

STREAM FLOW (MLD) STREAM CONC. (μg/l) 

Harmonic 

Mean 30Q5 7Q10 1Q10 

Harmonic 

Mean 30Q5 7Q10 1Q10 

ALL 50 125.56 44.02 26.80 22.53 1.75 5.00 8.21 9.76 

ALL 10 11.11 1.94 1.06 0.96 19.80 113.40 207.55 229.17 

DRINKING WATER AND FISH INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water Results Drinking 

Water Units Fish Ingestion Results 

Fish 

Ingestion 

Units 

50% 10% 50% 10% 

Cancer 

LADDpot 3.74E-08 4.23E-07 mg/kg/day 0.00 0.00 mg/kg/day 

LADCpot 1.92E-06 2.17E-05 mg/L 0.00 0.00 mg/kg 

Acute 

ADRpot 4.18E-04 9.48E-03 mg/kg/day 0.00 0.00 mg/kg/day 

SIC Code Comments: 

EPA SANITIZED Page 56 of 59
03/23/2009 

POST-FOCUS EXPOSURE REPORT 

Chemical ID: P090152C Assessor: 

 

 

 

 

 

 

 

EPA SANITIZED Page 57 of 59
03/23/2009 

POST-FOCUS EXPOSURE REPORT 

 Chemical ID: P090152C 

SIC-CODE BASED HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

 

 

 

 

Comments: 

EPA SANITIZED Page 58 of 59
03/23/2009 

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 exceedance 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. 

EPA SANITIZED Page 59 of 59