# Support Documents for

Significant New Use Rule (SNUR) on

Premanufacture Notice (PMN)

P-10-44

EPA Docket EPA

- HQ

- OPPT -2011-0577

# Index

A-001 Structure Activity Team (SAT) Report for

PMN P-10-44

A-002 Initial Review Engineering Report for

PMN P-10-44

A-003 Init ial Review Exposure Report for

PMN P-10-44

# A-001

Structure Activity Team (SAT) Report

for PMN P-10-44

# A-002

Initial Review Engineering Report

for PMN P-10-44Support - P-10-0044 Engine xt

INITIAL REVIEW ENGINEERING REPORT

PMN: 10-0044 Post-Focus Draft Revision 1 1/21/2010

ENGINEER: Jackson/Hall \ AG / JAS PV (kg/yr): 15,000 Import Only

Revision Notes / Assessment Overview: Revision 1/21/10: An amendment was sent on 01/05/2010 indicating: (1) the NPDES number for the WWTP in Wayne, NJ is 0028002 (Mountain View WWTP); (2) the PMN is imported as liquid only; and (3) dedicated transport containers will be returned to Canada and not cleaned

in the US.

SUBMITTER: Green Era Solutions

USE: Fragrance ingredient.

OTHER USES:

MSDS: Yes Label: No

Gen Eqpt: impermeable gloves to prevent prolonged skin contact / use safety eye wear designed to protect eyes against liquid splash and mists. / use protective clothing to prevent skin contact; use head caps, boots, and chemical aprons when necessary. / provide general or mechanical ventilation or local exhaust to keep vapor concentrations low. Respirator: a jointly approved NIOSH/MSHA air supplied respirator is advised in absence of proper environmental control. OSHA regulations also permit other NIOSH/MSHA respirators under specified conditions. Health Effects: Inhalation: may caues headache or nausea / Eye: may caue moderate eye irritation / Skin: prolonged or repeated and confined exposure may cause skin irritation. repeated contact may cause drying or flaking of skin. a single prolonged exposure is not likely to result in the material being absorbed through the skin in a harmful amount. the dermal LD50 has not been determined. / Ingestion: swallowing can cause gastrointestinal irritation, nausea, and diarrhea. / This product is not considered to be a carcinogen but no studies have been done at this time. / Some people may have an allergic reaction to cypress oil.

TLV/PEL:

none established.

CRSS : Chemical Name: Oils, Callitropsis nootkatensis Definition: Extractives and their physically modified derivatives. Callitropsis nootkatensis. S-H20: 2.5 g/L @

VP: 3.3E-2 torr @

MW: 202.00 %<500 %<1000 Physical State and Misc CRSS Info: Neat: Liquid Mfg: NK: Import Proc/Form: Solution: 0.1-0.5% PMN

Page 1Support - P-10-0044 Engineering.1.txt

material End Use: Solid (Est.) or Solution (Est.). The composition of the PMN substance is provided as 30-80%

nootkatene (5090-61-9, not on TSCA), 5-30% valencene (4630-07-3,

on TSCA), 1-15% carvacrol (499-75-2, on TSCA) and 1-20% nootkatone (4674-50-4, on TSCA). It has been reported that chaminic acid, chamic acid, nootkatin, methyl carvacrol and

chanootin have also been isolated from Alaska cedar heartwood. The MF and MW are provided for the major constituent nootkatene, the top structure on page 1 of this report. Submitted Data: WS = 0.25% (approx.); Density = 0.97 g/cc (approx.); Flash Point > 37. 8°C. The odor is described as citrus, sweet, woody. Estimated

Data: BP = 255.79°C (EPI); VP = 0.0328 torr (EPI); WS = 0.1201 mg/L (EPI); logP = 6.09 (EPI). The EPI estimations were performed on the major constituent nootkatene.

Consumer Use: Yes

SAT (concerns) (11/20/2009): Migration to groundwater: Slow PBT rating: P2B3T1 Health: 1-2 Dermal, Drinking Water, Inhalation Eco: 3 Water (All releases to water with a CC = 1 ppb)

OCCUPATIONAL EXPOSURE RATING: 2-3B

NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER. Revision 1/21/10: An amendment was sent on 01/05/2010 indicating: (1) the NPDES number for the WWTP in Wayne, NJ is 0028002 (Mountain View WWTP); (2) the PMN is imported as liquid only; and (3) dedicated transport containers will be returned to Canada and not cleaned in the US. The IRER was updated accordingly. // The PMN is imported; therefore no releases or exposures from manufacturing were assessed. The PMN is a volatile liquid; therefore, fugitive releases are calculated for each activity. Contact was called, see contact report. ///

The current PMN is being imported to Mane USA.

This IRER assumes 100% consumer use as it is not addressed in

the submission

. ///

/// The Aug 2007 "Blending of Fragrance Oils into Commercial and Consumer Products" GS was referenced for USE. The production volume of consumer products in this case (15,000 kg/yr / 0.01 = 1,500,000 kg/yr or 3.3 million lb/yr) is less than the PV for continuous processes given in the G.S. (4 to 25 million lb/yr); therfore, CEB assumes that the "formulation into consumer products" operation is batch-wise, not continuous

POLLUTION PREVENTION CONSIDERATIONS:

None.

Page 2Support - P-10-0044 Engineering.1.txt

EXPOSURE-BASED REVIEW: No

INITIAL REVIEW ENGINEERING REPORT

PMN: 10-0044

Proc1: Formulation of Fragrance Oil

Number of Sites/ Location: 1

Mane, USA Wayne NJ 07470 Days/yr: 250 Basis: Submission states: PV of 15,000 kg/yr, 1 site, and 250 days/year of operation. ChemSTEER calculates 60 kg/site-day. Submission states PMN is at concentration in fragrance oil of

<5% (assessed at 5%).

Process Description: Unload buckets of PMN material imported (100 % PMN, liquid) --> Blend with other essential oils to make a fragrance (<5% PMN, liquid) --> Drums (per submission and past cases)

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. The amendment sent on 1/5/2010 indicated that the transport containers are dedicated and are not cleaned in the US before being returned to Canada; therefore, container cleaning

was not assessed below.

Water Conservative: 6.0E-1 kg/site-day over 250 days/yr from 1 site to: POTW, per past cases (NPDES 0028002, per amendment

01/05/2010) from: Equipment Cleaning Losses of Liquids from a Single Vessel basis: EPA/OPPT Single Vessel Residual Model, CEB standard 1% residual. Per past cases, equipment is cleaned using water and soap. Waste wash water discharged to local POTW.

Air Output 2: 2.3E-3 kg/site-day over 250 days/yr from 1 site

to: Air from: Equipment Cleaning Losses of Liquids from a Single Vessel

basis: EPA/OPPT Mass Transfer Coefficient Model.

Air Typical: 1.0E-5 kg/site-day over 250 days/yr from 1 site Worst Case: 2.1E-5 kg/site-day over 250 days/yr from 1 site

to: Air from: Loading Liquid Product into Drums basis: EPA/OAQPS AP-42 Loading Model.

Air Typical: 5.2E-6 kg/site-day over 250 days/yr from 1 site Worst Case: 1.0E-5 kg/site-day over 250 days/yr from 1 site

to: Air from: Unloading Liquid Raw Material from Buckets basis: EPA/OAQPS AP-42 Loading Model.

RELEASE TOTAL 1.5E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Page 3Support - P-10-0044 Engineering.1.txt Tot. # of workers exposed via assessed routes: 6 Basis: Submission estimates 2 workers exposed. CEB assesses 3
workers/site as minimum default.

Inhalation:

Exposure to Vapor (Class II) Typical: 5.0E-3 mg/day over 250 days/yr Worst Case: 3.0E-1 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 3 Basis: Loading Liquid Product into 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? No

OR b) Hazard Rating for health of 2 or greater? 1-2 No Inhalation Monitoring Data Desired? No

Exposure to Vapor (Class II) Typical: 2.5E-3 mg/day over 250 days/yr Worst Case: 1.5E-1 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 3 Basis: Unloading Liquid Raw Material from Buckets; EPA/OPPT Mass Balance Model. Technical contact stated PMN may be imported as neat powder or neat liquid. 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? No

OR b) Hazard Rating for health of 2 or greater? 1-2 No Inhalation Monitoring Data Desired? No

Dermal:

Exposure to Liquid at 5.00% concentration High End: 8.8E+1 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 3 Basis: Loading Liquid Product into Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

Exposure to Liquid at 100.00% concentration High End: 1.8E+3 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 3 Basis: Unloading Liquid Raw Material from Buckets; EPA/OPPT 2-Hand Dermal Contact with Liquids Model. Technical contact stated PMN may be imported as neat powder or neat liquid.

INITIAL REVIEW ENGINEERING REPORT

PMN: 10-0044

Proc2: Formulation of Consumer Products

Number of Sites/ Location: 1

Mane, USA Wayne NJ 07470

Page 4Support - P-10-0044 Engineering.1.txt Days/yr: 250 Basis: Submission and technical contact state processing fragrance oil into final consumer product occurs at same site as PROC 1. CEB assesses 1 site and 250 days/year. ChemSTEER calculates 60 kg/site-day. Consumer product is <1% PMN

(assessed at 1%).

Process Description: Fragrance oil unloaded from drums (<5% PMN, liquid) --> mixed with other chemicals --> finished household consumer products (<1% PMN) (per submission and past cases)

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.

Water or Air or Landfill Output 2: 4.0E-1 kg/site-day over 250 days/yr from 1 site or 1.0E+2 kg/yr to: water, landfill or air (Fragrance GS) (if water, NPDES 0028002, per amendment 01/05/2010) from: Loading Solid Product into Transport Containers basis: User-Defined Loss Rate Model. Fragrance GS indicates 4. 5% loss from spray-drying solid products, with 85% eff. air pollution control (cyclones), release to water, landfill, or air. Release = Qchem_site_day x 0.045 x (1 - 0.85).

Water or Incineration or Landfill High End: 1.8E+0 kg/site-day over 250 days/yr from 1 site or 4.5E+2 kg/yr to: uncertain (if water, NPDES 0028002, per amendment

01/05/2010) from: Cleaning Liquid Residuals from Drums Used to Transport the

Raw Material

basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. Submission does not estimate media of release of cleaning
residuals. Therefore, assessed to water, incineration or

landfill as a conservative estimate.

Water or Incineration or Landfill Conservative: 1.2E+0 kg/site-day over 250 days/yr from 1 site or 3.0E+2 kg/yr to: uncertain (if water, NPDES 0028002, per amendment

01/05/2010) from: Equipment Cleaning Losses of Liquids from Multiple Vessels basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB

standard 2% residual. Submission does not estimate media of release for equipment cleaning. CEB assumes releases to water,

incineration or land.

Air Typical: 2.1E-4 kg/site-day over 250 days/yr from 1 site Worst Case: 4.2E-4 kg/site-day over 250 days/yr from 1 site

to: Air from: Unloading Liquid Raw Material from Drums basis: EPA/OAQPS AP-42 Loading Model.

Air Output 2: 6.9E-6 kg/site-day over 250 days/yr from 1 site

to: Air from: Cleaning Liquid Residuals from Drums Used to Transport the

Raw Material

Page 5Support - P-10-0044 Engineering.1.txt

basis: EPA/OPPT Penetration Model.

Air Typical: 5.2E-4 kg/site-day over 250 days/yr from 1 site Worst Case: 1.0E-3 kg/site-day over 250 days/yr from 1 site

to: Air from: Loading Liquid Product into Small Containers basis: EPA/OAQPS AP-42 Loading Model.

Air Typical: 8.3E-6 kg/site-day over 250 days/yr from 1 site Worst Case: 6.7E-5 kg/site-day over 250 days/yr from 1 site

to: Air from: Sampling Liquid Product

basis: EPA/OPPT Penetration Model.

Air : 7.0E-3 kg/site-day over 250 days/yr from 1 site

to: Air from: Vapor Release from Open Liquid Surfaces basis: EPA/OPPT Penetration Model. For 6000 kg batch (final product), Fragrance GS Eqn. 4-3 calculates diameter of 197 cm. Per Fragrance GS, assessed vapor correction factor as Yprod = 0.

05.

Air Output 2: 1.8E-2 kg/site-day over 250 days/yr from 1 site

to: Air from: Equipment Cleaning Losses of Liquids from Multiple Vessels

basis: EPA/OPPT Mass Transfer Coefficient Model.

RELEASE TOTAL 8.6E+2 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 29 Basis: Technical contact stated that consumer products may be solid or liquid (for example scented candle or lotion). Therefore, solid exposures (inhalation and dermal were assessed). Submission states PMN in final product <1%. The Generic Scenario for Fragrances states the typical % in formation can range from 0.5% to 15% of fragrance oil (PMN concentration in the oil can vary). Used 1% PMN in the consumer products as a

conservative estimate. Submission estimates 2 workers at one site. GS estimates up to 29 workers per site.

Inhalation:

Exposure to Vapor (Class II) Typical: 10.0E-2 mg/day over 250 days/yr Worst Case: 6.0E+0 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 29 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 Page 6Support - P-10-0044 Engineering.1.txt b) Hazard Rating for health of 2 or greater? 1-2 No Inhalation Monitoring Data Desired? Yes (both criteria met)

Exposure to Vapor (Class II) Typical: 2.5E-1 mg/day over 250 days/yr Worst Case: 1.5E+1 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 29 Basis: Loading Liquid Product into Small Containers; 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)

Exposure to Particulate (Class I) Typical: 4.8E-3 mg/day over 200 days/yr Worst Case: 1.6E-2 mg/day over 200 days/yr Number of workers (all sites) with inhalation exposure: 29 Basis: Loading Solid Product into Transport Containers; EPA Small Volume Handling Model, less than 54 kg of PMN handled per site-day. NOTE: The respirator class is: I. Particulate (including solid or liquid droplets).

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? 1-2 No Inhalation Monitoring Data Desired? No

Exposure to Vapor (Class II) Typical: 4.0E-3 mg/day over 250 days/yr Worst Case: 9.6E-1 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 29 Basis: Sampling Liquid Product; 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? No

OR b) Hazard Rating for health of 2 or greater? 1-2 No Inhalation Monitoring Data Desired? No

Exposure to Vapor (Class II) Output 2: 0.0E+0 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 29 Basis: Vapor Release from Open Liquid Surfaces; User-defined

Inhalation Model. NOTE: The respirator class is: II. Gas/vapor (all substances in the gas form).

INHALATION MONITORING DATA REVIEW Page 7Support - P-10-0044 Engineering.1.txt 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? 1-2 No Inhalation Monitoring Data Desired? No

Dermal:

Exposure to Liquid at 5.00% concentration High End: 8.8E+1 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 29 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

Exposure to Solid at 1.00% concentration High End: 3.1E+1 mg/day over 200 days/yr Number of workers (all sites) with dermal exposure: 29 Basis: Loading Solid Product into Transport Containers; EPA/OPPT

Direct 2-Hand Dermal Contact with Solids Model.



CALL BY: Anthony Gaglione Organization: ERG

CALL TO: Maryam Azad

Organization: Green Era Solutions

Date: 11/23/2009

Time: 4:10 PM

Phone: 310-473-1651

PMN: 10-0044

Q1: Submission indicates PMN is imported to Mane USA site for processing. Does Mane USA process fragrant into fragrance oil AND formulate fragrance oil into final consumer product?| A1:
Yes, believe so. Will confirm.| | Q2: What is the concentration and physical form of PMN as imported, in fragrance oil, and in consumer product?| A2: PMN may be imported as neat substance in liquid form or powder form. Fragrance oil composition is unknown, but likely less than 5% PMN. Consumer products can be anything, such as lotions or candles. PMN is likely less than 1% in final consumer product, but is uncertain at this point.| | Q3: | A3: | | Q4: | A4:

Page 8

# A-003

Initial Review Exposure Report

for PMN P-10-4402/03/2010 Page 1 of 10

POST FOCUS EXPOSURE REPORT

This revised report is based on th e revised engineering report of 1/21 /2010, which provided the site-specific

information for the Pro cessing water releases.

Chemical ID: P-10-0044 Reviewer: Sherer/Flessner

Results Table: Dose, Concentration, and Days Exceeded Results Summary

Exposure Scenario 1 Water Landfill Stack Air Fugitive Air

Release activity(ies) 2 ;

exposure calculation(s) 3 Drinking Water Fish Ingestion 7Q10 4

CC=1 PDM

Days

Exceeded LADD ADR LADD ADR LADD ADR LADD ADR LADD

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

PROC1,2: max ADR,

LADD, PDM/acute

eco. 2.67E-05 3.72E-07 6.03E-04 7.69E-06 0.51 0 1.77E-0 4 3.71E-06 2.04E-07 1.08E-02 2.36E-04

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:

Results Table: Consumer Exposure Results Summary

Scenario Water (DtD) Dermal Inhalation

Drinking Water Fish Ingestion 7Q10 PDM Days

Exceeded ADR LADD ADR LADD ADR LADD ADR LADD

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

CEM 1 : --- --- --- --- --- ---

CEM 1 , general

purpose cleaner --- --- --- --- --- --- 2.72e-02 1.70e-02 3.38e-01 1 16e-01

1 Consumer Exposure Module within NCEM2 model.

Results Table: Exposure Based (XB)/Persistent (P2B2) Criteria

Parameter Exp Based Persistent Exceedance Value

Drinking (Surface) Wate r Dose (mg/kg/day) No No

Fish Ingestion Dose (mg/kg/day) No No

Inhalation Dose (mg/kg/day) No Yes 1.08E-02

Groundwater Dose (mg/kg/day) No No

Surface Water Release After Treatment (kg/yr) No No

Total Release After Treatment (kg/yr) No No

Consumer Use? No Yes 3.38e-01

Fate test recommendations: (default is NA)02/03/2010 Page 2 of 10

POST FOCUS EXPOSURE REPORT

Chemical ID: P100044 Assessor: Sherer

ENVIRONMENTAL RELEASES

Scenario#:1 Number of Release Sites: 1.

Release Activity: Proc 1,2: max ADR, max LADD, PDM/acute eco.

Release Description: WATER LANDFILL

Non-sludge/Sludge STACK FUGITIVE

Total Releases: 1000.00 850.00 750.00 107.50

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

Non-sludge/Sludge

Release Days/yr: 250.00 1.00/0.00 250.00 250.00

Per Site Release: 4.00 850.00/0.00 3.00 0.43

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

Remarks:02/03/2010 Page 3 of 10

POST FOCUS EXPOSURE REPORT

Chemical ID: P100044

SITE-SPECIFIC HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES

SCENARIO NUMBER:1 RELEASE ACTIVITY: Pr oc 1,2: max ADR, max LADD, PDM/acute

eco.

FACILITY NAME: MOUNTAIN VIEW STP

FACILITY LOCATION: WAYNE NJ 07470

RECEIVING WATER NAME: PASSAIC R

REACH NUMBER: 02030103012 FACILITY ON REACH: No DISCHARGE TYPE: Direct

NPDES PERMIT #: NJ0028002 EXPOSED POPULATION: Adult

WWT

REMOVAL

(%) RELEASE

DAYS PRETREATMENT

RELEASE

(kg/site/day) POSTTREATMENT

RELEASE

(kg/site/day) DWT

(%) BCF

(L/kg)

99. 250. 4. 4.00E-02 0.00 4820.00

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER

FLOW DESCRIPTOR Harmonic Mean 30Q5 7Q10 1Q10 PLANT

FLOW (MLD) 574.00 125.12 79.02 65.01 NA

CONCENTRATION ( μ g/L) 6.97E-02 0.32 0.51 0.62 NA

DRINKING WATER INGESTION AND FISH INGESTION EXPOSURE ESTIMATES

Exposure Units Drinking Water

Results Drinking Water

Units Fish Ingestion

Results Fish Ingestion

Units

Cancer

LADD pot 3.72E-07 mg/kg/day 7.69E-06 mg/kg/day

LADC pot 1.91E-05 mg/L 9.20E-02 mg/kg

Acute

ADR pot 2.67E-05 mg/kg/day 6.03E-04 mg/kg/day

Surface Water Comments:02/03/2010 Page 4 of 10

POST FOCUS EXPOSURE REPORT

Chemical ID: P100044

SITE-SPECIFIC HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES

SCENARIO NUMBER: 1 RELEASE ACTIVITY: Pr oc 1,2: max ADR, max LADD, PDM/acute

eco.

FACILITY NAME: MOUNTAIN VIEW STP

FACILITY LOCATION: WAYNE NJ 07470

RECEIVING STREAM NAME: PASSAIC R

REACH NUMBER: 02030103012 FACILITY ON REACH: No DISCHARGE TYPE: Direct

NPDES PERMIT NUMBER: NJ0028002 GAGING STATION ID: 01389500

GAGING STATION

PERIOD OF RECORD: 01/01/66 -

01/02/91 GAGING STATION

NUMBER OF

OBSERVATIONS: 9134.00 NUMBER OF STATIONS ON

REACH: 1

50 %ile FLOW (MLD): N/A 10 %ile FLOW (MLD): N/A EFFLUENT FLOW (MLD):22.97

RESULTS

COC ( μ g/L) Percent of Year

COC Exceeded Number of Days

COC Exceeded Release

days/year Pre-treatment

Loading

(kg/site/day) Waste Water

Treatment (%)

1.00 0 0 250.00 4.00 99.0002/03/2010 Page 5 of 10

POST FOCUS EXPOSURE REPORT

Chemical ID: P100044

DRINKING WATER EXPOSURE ESTIMATES FROM LANDFILL RELEASES

SCENARIO #: 1 ACTIVITY: Proc 1,2: max ADR, max LADD, PDM/acute eco.

RELEASE DESCRIPTION:

EXPOSED POPULATION: Adult

NUMBER

OF

SITES NON-SLUDGE

LANDFILL

RELEASE AND

DAYS OF

RELEASE

(kg/site/day)/(days) LANDFILLED

SLUDGE 1

AND DAYS OF

RELEASE

(kg/site/day)/(days) MIGRATION

DESCRIPTOR 2 ADSORPTION

TO

WASTEWATER

SLUDGE

(%) DRINKING

WATER

TREATMENT

(%)

1. 850.00/1.00 0.00/0.00 Slow 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

Exposure Units Results ASSUMPTIONS

ED

(years) AT

(years) BW

(kg) IR

(L/day)

Cancer

LADD pot (mg/kg/day) 1.77E-04 30.00 75.00 71.80 1.40

LADC pot (mg/L) 9.08E-03 30.00 75.00 NA NA

REMARKS:02/03/2010 Page 6 of 10

POST FOCUS EXPOSURE REPORT

Chemical ID: P100044

INHALATION EXPOSURE ESTIMATES (POST-TREATMENT)

SCENARIO #: 1 RELEASE ACTIVITY:Pro c 1,2: max ADR, max LADD, PDM/acute

eco.

RELEASE DESCRIPTION:

METHOD OF CALCULATION: Screen3

EXPOSED POPULATION: Adult

Number of Sites: 1.

Per Site Fugitive Release: 0.43 kg/site/day

Fugitive Release Days per Year: 250.00 days

% Removal via Fugitive Release: 0.00 %

Total Fugitive Release: 107.50 kg/yr

Max Annual Average Air Concentration

(Fugitive): 3.21 μg/m 3

Max 24 Hour Average Air

Concentration(Fugitive): 58.60 μg/m 3

Per Site Stack Release: 3.00 kg/site/day

Stack Release Days per Year: 250.00 days

% Removal via Stack Release: 99.90 %

Total Stack Release: 750.00 kg/yr

Max Annual Average Air Concentr ation (Stack): 2.77E-03 μg/m 3

Max 24 Hour Average Air Concentration (Stack): 2.02E-02 μg/m 3

Exposure Units Results

(Stack) Results

(Fugitive) ASSUMPTIONS

ED

(years) AT

(years) BW

(kg) Inh. Rate

(m 3 /hr)

Cancer

LADD pot (mg/kg/day) 2.04E-07 2. 36E-04 30.00 75.00 71.80 0.55

LADC pot (mg/m 3 ) 1.11E-06 1.28E-03 30.00 75.00 NA NA

Acute

ADR pot

(mg/kg/day) 3.71E-06 1. 08E-02 NA 1 day 71.80 0.5502/03/2010 Page 7 of 10

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 m02/03/2010 Page 8 of 10

Inhalation Exposure Estimates

ID Number: P100044

Scenario: General Purpose Cleaner Population: Adult

Exposure Duration (years) chronic: 57 Exposure Duration (days) acute: 1

Exposure Units Result AT (days)

Chronic Cancer

LADD pot (mg/kg-day) 1.16e-01 2.74e+04

LADC pot (mg/m 3 ) 5.96e-01 2.74e+04

Acute

ADR pot

(mg/kg-day) 3.38e-01 1

Cp pot (mg/m 3 ) 6.19e+00 NA

LADD - Lifetime Average Daily Dose (mg/kg-day) LADC - Lifetime Average Daily Concentration (mg/m 3 )

ADR - Acute Dose Rate (mg/kg-day) Cp - Peak Concentration (mg/m 3 )

Note: 75 years = 2.738e+04 days pot - potential dose

Note: The general Agency guidance for assessing short-term, infre quent events (for most chemicals, an exposure of less than 24

hours that occurs no more frequently than monthly) is to treat such events as independent, acu te exposures rather than

as chronic exposure. (Methods for E xposure-Response Analysis for Acute Inha lation Exposure to Chemicals (External

Review Draft). EPA/600/R-98/051. April 1998)02/03/2010 Page 9 of 10

CEM Dermal Exposure Estimates

ID Number: P100044

Scenario: General Purpose Cleaner Population: Adult

Exposure Duration (chronic) (years): 57 Exposure Duration (acute) (days): 1

Exposure Units Result AT (days)

Chronic Cancer

LADD pot (mg/kg-day) 1.70e-02 2.74e+04

Acute

ADR pot

(mg/kg-day) 2.72e-02 1

LADD - Lifetime Average Daily Dose (mg/kg-day)

ADR - Acute Dose Rate (mg/kg-day)02/03/2010 Page 10 of 10



## 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.