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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

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MEMORANDUM 

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

SUBJECT: Acceptability of a biodegradation study for Bruggolite to satisfy TSCA section 4 

test rule requirements for methanesulfinic acid, hydroxyl-, monosodium salt (CAS 

No . 149-44-0). 

FROM: Jed Costanza, Environmental Engineer V, 

Exposure Assessment Branch (7406M) 

TO : Mike Mattheisen, Chief 

Chemical Information and Testing Branch (7405M) 

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The following is an evaluation of the biodegradation test submitted for the HPV-1 test 

rule chemical, methanesulfinic acid, hydroxyl-, monosodium salt (CAS No. 149-44-0). The c" 

monosodium salt was between 89.3 and 98.4%. Thus, the concentration of methanesulfinic acid, 

hydroxyl-, monosodium salt was between 17 .9 and 19.7 mg/L on a carbon basis, which was 

within the 10 to 20 mg/L range specified in the OECD 301 B test guideline. While the presence 

of impurities decreased the percentage of methanesulfinic acid, hydroxyl-, monosodium salt used 

during testing, the concentration was within an acceptable range for the OECD 301 B test and 

comprised greater than 89% of the carbon fraction of the Bruggolite product. 

biodegradation results provided as Appendix A of your July 15, 2008 memorandum are for a 

ready biodegradability test completed using the Organization for Economic Co-operation anW, 

Development (OECD) Guideline 301 B for the product Bruggolite, which contained betweeff, 

68 .5 and 73.3% of methanesulfinic acid, hydroxyl-, monosodium salt . The other componentpf 

Bruggolite included sodium hydroxymethanesulfonate, which is the oxidized form of 

methanesulfinic acid, hydroxyl-, monosodium salt; sodium sulfite, a commonly used reducing 

agent; sodium sulfate, the oxidized form of sodium sulfite; and water. Other than sodium 

hydroxymethanesulfonate, the only other carbon containing component of Bruggolite was c 

sodium carbonate. According to the information listed under section 3 .5 of Appendix A, the cst 

concentration of Bruggolite used for the test was 20 mg/L as carbon and we calculated that the 

carbon containing fraction of Bruggolite attributable to methanesulfinic acid, hydroxyl-, 

Methanesulfinic acid, hydroxyl-, monosodium salt (CAS No . 149-44-0) is anticipated to 

be readily biodegradable based on BIOWIN v4.10 model predictions and according to the test 

result listed in the database for Biodegradation and Bioconcentration of Existing Chemical 

Substances maintained by the Japanese National Institute of Technology and Evaluation . 

Intemet Address 

CONTAINS 

(URL) " http ://www .epa1~~ . CBI 

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The impurities of Bruggolite, which included sodium hydroxymethanesulfonate, sodium 

sulfite, sodium sulfate, water, and sodium carbonate, were not anticipated to negatively impact 

the biodegradation test . The test results are acceptable and we conclude that methanesulfinic 

acid, hydroxyl-, monosodium salt (CAS No . 144-44-0) is readily biodegradable.