### SAT Report PMN Number: P-09-0107 SAT Date: 12/19/2008

Print Date: 9/6/2012

Related cases : : Yes Health related cases: Ecotox related cases:

Concern levels : Type of Concern: Health Eco Comments Level of Concern: 2 3

Persistence Bioaccum Toxicity Comments 1 11

Exposure Based Review : Health: N o Ecotox: Yes

Routes of exposure : Health: Dermal, inhalation Ecotox: All releases to water Fate: ;

P 2 Rec Comments : Comment: SAT has no comment

Keywords : Keywords: LUNG, IRR/CORR-E,S,MM, AQUATOX
Summary of Assessment :

Fate : Fate Summary: P-09-0107 FATE: Estimations for low weight MW 325.54

Liquid with MP < 25 EC (E) log Kow = 5.97 (E) S = Disp. (ICB) VP < 1.0E-6 torr at 25 EC (E)BP > 400 EC (E) H < 1.00E-8 (E) log Koc = 4.18 (E) log Fish BCF = 2.90 (E) POTW removal (%) = 88 via sorption; OPPTS835.3210 (SCAS test): 88.07%/7 d. RB. Time for complete ultimate aerobic biodeg = wk-mo Sorption to soils/sediments = strong PBT Potential: P1B1 *CEB FATE: Migration to ground water = negl

Health : Health Summary: Absorption is poor from the skin, moderate from the GI tract, and good from the lung (analog). Concern for surfactant effects on the lung; irritation to eye, skin (chronic), mucous membranes and lung based on surfactant properties of the compounds. Concern for corrosion to eyes based on statement in the MSDS; and lung toxicity from cationic binding to lung membranes. Test Data: some eye irritation in rabbits, cleared by day 7; some skin irritation in rabbits; rat oral LD0 = 2000 mg/kg

Ecotox :
Test Organism Test Type Test End Point Predicted Measured Comments

fish 96-h LC50 0.26 0.105 11.3 mg/L with 10% HA mitigation daphnid 48-h LC50 0.061 0.498 53 mg/L with 10% HA mitigation green algal 96-h EC50 0.097 0.200 21 mg/L with 10% HA mitigation fish

_ chronic value 0.006 daphnid

_ chronic value 0.019

algal

_ chronic value 0.013

Sewage Sludge 3-h EC50

_ Sewage Sludge

_ Chronic Value _

Ecotox Values Comments: Predictions are based on SARs for ; SAR chemical class = ; MW 394 (major product/worst case); log Kow = 6.02; p H7; effective concentrations based on 100% active ingredients and mean measured concentrations; hardness <150.0 mg/L as CaCO3; and TOC <2.0 mg/L;

P09-0107EVALUATION OF ECOTOXICITY STUDIES For Tuesday, December 19, 2008 SAT Evaluator: S. Cragg N ominal ECOSA R Function Parameter Conc Predicted Test Type Evaluated Measured (mg a.i./L)(a) Conc (mg/L) Acute Fish Lethality 96-hr LC50 0.105 0.26 Fathead Minnow LOEC 0.063 (Pimephales promelas) N OEC 0.031 static ChV 0.044 96-hr LC50 ajusted by mitigation factor 11.3

Acute Fish Lethality 96-hr LC50 11.3 Fathead Minnow LOEC N/D (Pimephales promelas) N OEC 6.25 static ChV N/D 10% Humic Acid mitigated mitigation factor 107

Acute Fish Lethality 96-hr LC50 19.0 Fathead Minnow LOEC N/D (Pimephales promelas) N OEC 12.5 static ChV N/D 20% Humic Acid Mitigated mitigation factor 180

Acute Daphnia Mobility 48-hr EC50 0.498 0.054 (Daphnia magna) LOEC N/D static NOEC N/D ChV N/D 48-hr EC50 ajusted by mitigation factor 53

Freshwater Algae Growth Inhibition S capricornutum Growth Rate† 96-hr ErC50 0.200 0.083 LOEC N/D N OEC N/D ChV N/D 48-hr EC50 ajusted by mitigation factor 21

ECOSAR fish chronic 0.006 ECOSAR daphnia ChV 0.016 ECOSAR algal ChV 0.012

(a) Reported test concentrations represent only nominal (loading) values. N o chemical analysis of the aqueous media was performed. The PMN is characterized as being "dispersible" by EPA/EETD with no actual limit of water solubility reported. However, the MSDS accompanying the PMN indicates that solubility of this in water is > 10%.The testing laboratory indicated that 10 minutes stirring in deionized water with a magnetic stirrer (nominal conc = 250,120 mg/L without humic acid) resulted in compete dissolution of the test substance within 10 minutes. For these reasons and because the estimated vapor pressure of the PMN is <0.00001 torr, Henry's Law Constant is <1.0E-08 indicates that the nominal concentratons are probably an accurate reflection of actual concentrations. The attached MSDS reports the tested substance had the PMN at a concentration and that the laboratory adjusted for this concentration as "active ingredient." † Concentration that reduced growth rate by 50%.

Conclusion: Results from the four tests are considered valid. The most sensitive species is fish with a 96-hr LC50 of 0.105 mg/L. When mitigated with humic acid (10 mg/L), the 96-hr LC50 is 11.3 mg/L. Thus, to calculate the concentration of concern (CoC), 11.3 mg/L is divided by a factor of 10 to simulate a chronic value, then divided again by an assessment (uncertainty) factor of 10 yielding a CoC of 0.113 mg/L, rounded to 110 μ g/L ( p pb). Alternatively, the ChV of 4.70 (adjusted by the mitigation factor of 107) could have been divided by an assessment (uncertainty) factor of 10 to directly yield a CoC of 470 p pb. The more conservative ( p rotective) method using the adjusted acute value is used for consistence since the of the PMN did not have a LOEC with which to derive a ChV to more directly derive a CoC. The PMN is of moderate concern for ecotoxicity.

Fish Fish (mitigated 10% HA) Daphnia Algae Test cmpnd purity (%) : Temp Range (°C): 21.9 - 22.4 21.0 - 22.5 19.2 - 21.1 24.0 - 25.0 O2 conc (mg/L): 6.9 - 7.9 6.2 - 8.0 7.8 - 8.4 N ot foun d H2O Hrdnss (mg/L CaCO3): 88 110 100 N ot foun d p H: 7.7 - 7.9 7.3 - 9.0 7.5 - 8.7 7.0 - 8.8 Conductivity (μmhos/cm): 297 302 304 N /D N ominal or Measured? N ominal Nominal Nominal Nominal Flow-thru/Static/Semi-static: Static Static Static Static Certificate of Analysis?: N ot reported Not reported Not reported Not reported Illumination (foot candles): N ot reported Not reported Not reported 96 - 100

Estimated Measured Physical State Liquid -- VP (mmHg @ 25°C) <1.0E-06 -- Absorptivity (Log Koc) 4.18 -- Log Kow 5.97 -- Water Solubility (mg/L) "Dispersible" -- Henry's Law Constant 1.0E-08 -- Sorption to Soils "strong" -- log fish BCF 2.9 --

Factors Values Comments Assessment Factor 10Concentration of Concern ( p pb) 110

SARs SAR Class Ecotox Category

Ecotox Factors Comments:

SAT Chair: L Keifer 546-8916