Re:Fw:Robust Summary EPA Robust Summary EPA Robust Summary EPA -HQ-OPPT-2009-0112 2009-0112 2009-0112for CASRN for CASRN for CASRN25321-41-9 25321-41-9 

Chuantung Lin Chuantung Lin to: John Schaeffer 02/07/2013 02:58 PM

Cc: Tracy Williamson, Myrta Christian

History: This message has been replied to.

No I try to explain to you that the "initial decomposition temperature" of 30oC at 25.3 mm Hg (i. e. at a 

reduced pressure) provided by the sponsor might not be the real decomposition temperature of the test 

substance. It night be for the water content contained in the test sample. I had indicated that the 

decomposition temperature at normal atmospheric pressure by extrapolating from the submitted value as 

provided in the report should be around ~107.7oC. They don't need to repeat such measurement, but the 

value was too low for this type of substance. However, if the sponsor could perform the test on a dry and 

pure sample, it would be appropriated to see the real BP or decomposition temperature of the substance. 

Daniel

______________________________________________________

Dr. Daniel Chuantung Lin 

Industrial Chemistry Branch

Office of Chemicals Safety and Pollution Prevention

US EPA

1200 Pennsylvania Ave., NW (7406M)

Washington, DC 20460

[Deliveries to: 1201 Constitution Ave., NW, 

EPA East, Room#:5133E, Washington, DC 20460]

202-564-8584 (direct)

202-564-8740 (branch)

202-564-8679 (fax)

John Schaeffer Daniel, Does your discussion mean that EPA sh... 02/07/2013 01:01:11 PM

From: John Schaeffer/DC/USEPA/US

To: Chuantung Lin/DC/USEPA/US@EPA

Cc: Tracy Williamson/DC/USEPA/US@EPA, Myrta Christian/DC/USEPA/US@EPA, Paul 

Lewis/DC/USEPA/US@EPA

Date: 02/07/2013 01:01 PM

Subject: Re: Fw: Robust Summary EPA-HQ-OPPT-2009-0112 for CASRN 25321-41-9

Daniel, 

Does your discussion mean that EPA should require that the test sponsor determine a measured 

decomposition temperature at normal atmospheric pressure?

Thanks

John

John Schaeffer

Senior Biologist
USEPA/OPPT/CCD/CITB

1201 Constitution Ave, NW

Washington, DC 20460

Mail Code: 7405M

Phone: 202-564-8173

Chuantung Lin Hi John, I checked the test results that submitted... 02/07/2013 11:18:09 AM

From: Chuantung Lin/DC/USEPA/US

To: John Schaeffer/DC/USEPA/US@EPA

Cc: Tracy Williamson/DC/USEPA/US@EPA, Myrta Christian/DC/USEPA/US@EPA

Date: 02/07/2013 11:18 AM

Subject: Re: Fw: Robust Summary EPA-HQ-OPPT-2009-0112 for CASRN 25321-41-9

Hi John,

I checked the test results that submitted from Impact Analytical on the Boiling Point (BP) endpoint, I have 

the following comments:

1) The sponsor indicated before that this chemical substance will be decomposed as it reaches the 

boiling stage. Therefore, no BP data could be obtained. ICB suggested that under such condition, the 

sponsor should obtain or report the decomposition temperature for this endpoint, instead. The "initial 

decomposition temperature" of this test substance reported by the sponsor via Impact Analytical was 30oC 

at25.3mm Hg (i. e. at a reduced pressure) . ICB used NOMO5 program (in house program) to convert 

such data to the temperature of 107.5o

C at 760 mm Hg which the substance should reach the boiling 

stage This temperature should be the normal BP of the test substance at 1 atm (760 mm Hg) condition. 

This means that this chemical should be decomposed at this temperature when the temperature reaches 

107.7o

C.

However, the test results for the Vapor Pressure (VP) of this chemicals indicated there have four VP 

values at different temperatures (see pages 6 & 10 in the attached document sent by the sponsor). ICB 

also used NOMO5 program to obtain boiling point values from these reduced VP at various temperatures . 

The following were the results:

1) VP = 36.4mm Hg@50oC; BP(obtained) is 123 C

 oC @ 760 mmHg

2) VP = 30.1mmHg@40 

oC;BP is 115.5 o

C @ 760 mmHg

3) VP=25.3mmHg@30 

oC(this is what sponsor indicated the this is what sponsor indicated the this is what sponsor indicated the "initial decomposition temperature for initial decomposition temperature for initial decomposition temperature for 

the test substance ) the test substance );BP is107.5 

oC@760mmHg

4) VP = 22.2mmHg@20 

oC; BP is 98.3 o

C @ 760 mmHg. (Note: This might be the water contents This might be the water contents This might be the water contents 

contained in the test sample . contained in the test sample . The VP for water is The VP for water is The VP for water is ~23mmHg@25oC)

From these data, we could see the extrapolated BP values were in a close agreement. The average BP The average BP The average BP 

is111oC@760mmHg. The sponsor also indicated on the report (see Page 2) that"The temperature of The temperature of The temperature of 

the sample continued to rise throughout the measurement even though a steady reflux was observed the sample continued to rise throughout the measurement even though a steady reflux was observed 

under vacuum . under vacuum.This is an indication of sample decomposition This is an indication of sample decomposition This is an indication of sample decomposition ." However, ICB consider this might be due 

to the water contained in the test sample that it would result a steady reflux (i.e., water reach 100o

Cboiling 

stage) and the temperature of the test sample continued to rise throughout the measurement. ICB thought 

that the decomposition temperature (or the real BP) for the test substance should be much higher than this 

reported value. 

The following BP data were for two close analogs (with only "one methyl one methyl one methyl "group on the benzene ring vs 

the test substance which contains"two methyl two methyl two methyl " groups)

1) meta-Toluenesulfonic acid Toluenesulfonic acid Toluenesulfonic acid ,monohydrate monohydrate monohydrate [CASRN 617-97-0] - BP = 165oC@0.1mmHg (converted 
by NOMO5 to 395.4.oC@760mmHg)

2) para-Toluenesulfonic acid Toluenesulfonic acid Toluenesulfonic acid [CASRN 6192-52-5] - BP=140oC@20mmHg(converted by NOMO5 to 

241.6.oC@760mmHg).

With these data for comparison purpose, the initial decomposition temperature of 30oC at25.3mm Hg 

(i.e.,107.5oC at760mm Hg)for the test substance reported by the sponsor was a little bit lower 

compared to the BP data from two close analogs, though.

The bottom line is: if the sponsor could not obtain a pure, dry sample to perform the BP testing, EPA 

could only accept the measured data they submitted for this BP endpoint or for the decomposition 

temperature.

Hope this is helpful to your question. Please let me know if you have any further question on these 

comments.

Daniel

______________________________________________

Dr. Daniel Chuantung Lin 

Industrial Chemistry Branch

Office of Chemicals Safety and Pollution Prevention

US EPA

1200 Pennsylvania Ave., NW (7406M)

Washington, DC 20460

[Deliveries to: 1201 Constitution Ave., NW, 

EPA East, Room#:5133E, Washington, DC 20460]

202-564-8584 (direct)

202-564-8740 (branch)

202-564-8679 (fax)

John Schaeffer Daniel I am forwarding this email to you, it also c... 02/06/2013 10:14:52 AM