### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, DC 20460

Mr. Keith Pitts Vice President, Regulatory Affairs Marrone Bio Innovations 212 Second Street, Suite B-107 Davis, CA 95618 OFFICE OFCHEMICAL SAFETY AND POLLUTION PREVENTION



### FEB 10 L 014

Subject: Response to YourLetter ofFebruary 20, 2013 to Steven Bradbury Regarding Sodium Hypochlorite and Other Biocide Zebra Mussel Uses

DearMr. Pitts:

Thankyou for your response to Joan Harrigan-Farrelly's October 17, 2012 correspondence and the detailed analysis provided. Weevaluated the issues raised in your letter regarding 1) sodium hypochlorite risk concerns, 2) other biocides risk concerns, and 3) procedural issues related to sodium hypochloriteregistration review, and have addressed them in this correspondence.

As background to yourconcerns over risk assessment adequacy, we note that the agency's aquatic environmental risk assessment process for antimicrobial pesticides has progressed over time. Forinstance, at
one time, recirculating cooling tower uses were considered indoor uses that did not require environmental assessments, while once through cooling tower uses were considered outdoor aquatic uses that did. With the promulgation of40 CFRPart 158 W, the agency now includes both ofthese uses under the industrial processes and watersystems use pattern and requires aquatic non-target organism toxicity data and performs non-target aquatic risk assessments for both. Similarly, what the agency has required in terms ofaquatic non-target organism data has also changed overtime

. The aquatic animal data now typically required for industrial processes and water systems use patterns, including mulluscicide uses, are shown in Table 1in Attachment 

### 1.
Further, as mandated in 1996 by the Food Quality Protection Act, the registration review program is the primary mechanism for the agency to assure that, as the ability to assess risk evolves and as policies and practices change, all registered pesticides continue to meet the FIFRA statutory standard ofno unreasonable adverse effects. Changes in science, public policy, and pesticide use practices will occur over time. Through the registration review program, the agency periodically reevaluates pesticides to make sure that as change occurs, products in the marketplace can still be used safely. We will certainly be evaluating the adequacy ofpastrisk assessments and data supporting antimicrobial pesticide substances used in industrial processes and water systems, including those with mulluscicide uses, underthis program.

1. 

### Sodium Hypochlorite

With respect to the agency's review ofsodium hypochlorite specifically, current risk assessment standards
were considered along with current use patterns and allowed discharge rates. (You are correct that mussels
were not specifically addressed

. However, the mulluscicidal use is considered part ofthe coolingtower use pattern. 1 ) As explained in more detail below, the agency determined that no additional toxicology or ecological effects data are required and no additional risk assessment is needed to support current sodium hypochlorite uses. In coming to this conclusion, the agency took into consideration, among otherthings, the existence of scientifically sound water quality criteria for protection ofaquatic life specific to chlorine and the existence ofscientifically sound risk-based water quality criteria and drinking water criteriafor protection ofhuman health specific to chlorine and chlorination by-products.
EcologicalEffectsDataRequirements

In September of2012, we determined that no further ecological effects data are needed to support the registration review ofexisting calcium and sodium hypochlorite uses, including the use for treatment of mollusks. All use patterns were considered in light ofcurrentpractice during development ofthe Product Chemistry, EnvironmentalFate, andEcologicalEffects ScopingDocument in Support of RegistrationReview of Sodium & Calcium Hypochlorite Salt? (Fate and Ecological Scoping Document)

. Ofall the use patterns registered for the hypochlorites, the use in cooling towers is one which would, under currentpractice, require the greatest amount ofecological effects data to continue to supportregistration

. As discussed in the Fate and Ecological Scoping Document, however, all such data requirements were metboth for aquatic and terrestrial animals. Indeed, not only are the data requirements met for aquatic animals, butexcept for aquatic invertebrate sediment testing, the data set is quite robust, as there are more databoth in number oftests and diversity ofspecies tested than required for a typical active ingredient registration. In part, this is because chlorine has been used as a water disinfectant for over a hundred years and in that time data have been published in the open literature and generatedby the government on its effects to aquatic and terrestrial organisms. Public literature and agency generated studies can be used to satisfy data requirements, as discussed in 40 CFRPart 152.94. In the case ofsedimenttesting, the physical-chemical characteristics of sodium hypochlorite result in such data notbeing needed to assess risk. (40 CFRPart 158

.2240)

Forexample, Table 2 lists the aquatic animal data requirements andthe number and type ofstudies used to develop the national ambient water quality criteria (NA WQC) for chlorine. These data were cited in the Fate and Ecological Scoping Document and theNa & Ca Hypochlorite RegistrationReview: Final Work Plan (FWP)3

. These data were available prior to 1988 and were used to develop the NA WQC for chlorine in 1984

1 On a similar note, we investigated the concerns expressed in your November 18, 2013 email regarding the EarthTec label, EPA Registration No

. 64962-1, and determined that the amendment to add zebra and quagga mussel pests did not involve a new site or userate for elemental copper, butrather a newpest. See http://www.epa.gov/oppsrrd1/REDs/cotmer red amend.pdf

. 2 March 22, 2012, docket numberEPA-HQ-OPP-2012-0004-0003 at http://www.regulations.gov 3 September 2012, docket number EPA-HQ-OPP-2012-0004-0006 at http://www.regulations.gov Page

### 2 of7and 1986. As of2013, these criteriaremain unchanged. And while the criteria are decades old, this does not
mean thatthey should be considered invalid or scientifically unsound. The Federal WaterPollution Control Act (FWPCA), Section 304(a)(1) provides, in pertinent part, thatEPA "shall develop and publish

...criteria for water quality accurately reflecting the latest scientific knowledge." The FWPCA also provides thatthese criteria are to be revised from time to time to reflect the latest scientific knowledge. TheEPAreviews existing NA WQC periodically and revises the criteria, ifappropriate, based on new scientific data. Since 1986, these periodic reviews have so far not resulted in any additional scientific data that materially change the NA WQC for chlorine

. Finally, EPA did not require additional ecological effects data on halomethane4 disinfection by-products formed from use ofhypochlorites because there is extensive information on this issue from a combination of ambient water quality criteria for halomethanes5

, the public literature, government generated studies, and models6

.
Human Health Toxicology DataRequirements

Inthe context ofregistration review, no additional toxicity orexposure data are anticipated as needed to support existing calcium and sodium hypochlorite uses, including the use for treatment ofmollusks. All use patterns were considered in light ofcurrent practice during development ofthe Sodium Hypochlorite and Calcium Hypochlorite: Human Health RiskAssessmentScoping Document in Support of Registration Review1 (Human Health Scoping Document). As discussed and referenced in the Reregistration Eligibility DocumentSodium and Calcium Hypochlorite Salti (RED) and Human Health Scoping Document, toxicity data were available notjustfor chlorine, but also for halomethanes including the trihalomethaneschlorination by-products. Accordingly, the agency believes the data base for chlorine and chlorination disinfection by-products is sufficient for purposes ofconducting registration review. As pointed out previously, chlorinehas been used as a water disinfectant for over a hundred years, and in that time data have been published in the public literature and developed by the government on its effects and effects ofits chlorination by-products to mammals, in addition to data thathas been submitted by registrants. The public literature and government generated data are ofsufficient quality and quantity that the Office ofWater has developed national ambient water quality criteria (A WQC) for halomethanes for the protection ofwaters designated for drinking water use and consumption offish and shellfish and set maximum contaminant levels (MCLs) for drinking water. Current AWQC and MCLvalues for chlorine and hypochlorite chlorination byproducts are listed in Table 39• While this table was notexplicitly provided in the Human Health Scoping

4 Chloromethane (methyl chloride) CAS# 74-87-3; dichloromethane (methylene chloride), CAS#75-09-2; trichloromethane (chloroform) CAS# 67-66-3; bromodichloromethane CAS#75-27-4; or dibromochloromethane CAS# 124-48-l. 5http://water

.epa
.gov/scitech/swguidance/standards/criterialupload/200I 10 12 criteria ambientwgc halomethanes80.

## ~

ECOSAR http://www

.epa
.gov/opptlnewchems/tools/21ecosar
.htm 7 January 20, 2012; docket number EPA-HQ-OPP-2012-0004-0004 at http://www.regulations.gov 8February 1992; http://www

.epa.gov/oppsrrdl/REDs/old reds/case0029.pdf 9 http://water.epa.gov/drink/contaminants/basicinformation/disinfectionbyproducts

.cfm 

### Page 3 of7Document, these values were referenced as the basis for not needing to require any additional toxicity data. These values are periodically reviewed and updatedby EPA.



### RiskAssessmentof Hypochlorite Mollusk Use Pattern



### In the case ofhypochlorite registrations, the Agency took into consideration that scientifically sound water quality criteria for protection ofaquatic life exist for chlorine and that scientifically sound risk-based water quality criteria and drinking waterregulations for protection ofhuman health also exist for chlorine and chlorination by-products.



### In general, FIFRA labels do not provide site specific facility discharge limits for cooling towers. FIFRA labels provide maximum use rates at a facility, and in some cases also provide guidance on the need for pretreatment. However, the label does not mean that all facilities can use the product at the given rate and expect not to exceed water quality standards. For instance, given two facilities with the same discharge instream flow rates, end ofpipe antimicrobial concentration, and same water body designated use(s) 10

, one facility may be able to use the antimicrobial product at the label rate and the other may not be able to use the antimicrobial product or may need to use it at a lower rate because one has a mixing zone, 11
•12
•13 butthe other
one does not. TheAgency ensures that site specific conditions are taken into consideration before use at a given facility by including the label language requiring notice to National PollutantDischargeElimination System (NPDES) Permitting Authority before water treated with an antimicrobial pesticide can be discharged. Such language is on the DixichlorMax label and other labels for sodium hypochlorite use for mussels.
Formally adopted numeric criteria and standards are the legal basis for including water-quality based effluent limitations in NPDES permits to ensure a specific discharge meets instream water quality standards. The FWPCA requires discharges to meet instream water quality standards. (See section 301(b)(l)(C), 33 U.S.C. 131l(b)(l)(C)). Where state ornational ambient water quality criteria exist, permit writers use this information along with information about the specific discharge source and instream water quality standards to establish water-quality based permit limits for the specific use site. States may include policies generally affecting the application and implementation ofinstream water quality standards, such as mixing zones, low flows and variances. Where formally adopted numeric criteria for an antimicrobial do not exist, permit writers can use other sources ofinformation to develop limits, such as public literature, government generated data, models, and risk assessments conducted by the Office ofPesticide Programs, to inform the site-specific facility water-quality based discharge permit limits.

10 Examples ofdesignated use categories: protection ofaquatic life; protection ofhuman health related to consumption offish and shellfish; recreation (primary contact, secondary contact); domestic water supply; livestock irrigation; navigation. 11 According to EPA's Technical SupportDocument for Water Quality-based Toxics Control (TSD) (USEPA, 1991), "a mixing zone is an area where an effluent discharge undergoes initial dilution and is extended to cover the secondary mixing in the ambient waterbody. A mixing zone is an allocated impact zone where water quality criteria can be exceeded as long as acutely toxic conditions areprevented." (Water quality criteria must be met at the edge ofa mixing zone.)" 12 http://water.epa.gov/scitech/swguidance/standards/mixingzones/about.cfm 13 http://water.epa.gov/scitech/swguidance/standards/mixingzones/docs.cfm Page 4 of7AquaticLife

An ecological risk assessmentfor the hypochlorites specific to the mollusk use was unnecessary because of the given state ofknowledge regarding chlorination, its chemistry, the existence offormally adopted water quality criteria for chlorine, toxicity information on chlorination by-products ofconcern, and existing label language. As discussed previously, while the aquatic life criteria have remained unchanged sincetheir adoption, they have undergone review by the Office ofWater, they are considered scientifically sound, and they are legally enforceable (state water quality criteria can be more stringent). Information provided by an additional risk assessment would not result in any additional label change ormodification ofthe enforceable water quality criteria

. While Dixichlor Max, for example, has a higher use rate for mollusks than other hypochlorite labels, this does not allow contravention or override ofwater-quality based discharge permit limits that would be imposed under NPDES (compliance with which is already required on the label).

Pretreatment ofchlorinated waters such as dechlorination prior to discharge is a well known option to allow a facility to use chlorination and meet water quality standards. In theZebraMussel Chemical Control Guide (USGS, 200014), this is evident in the discussion aboutthe practice when chlorination is used:

The actualpermit limitationfor facilities discharging to surface waters is basedon a calculation specific for eachplantand receiving stream. Because of water quality considerations, someplants practicing chlorination fordisinfection are requiredto dechlorinate. In such cases the limits may varyfrom non detectable concentrations to 0.05 mg/L. Where waterquality consideration have not been determined to be afactor, the established limits of1.5 to 2.0mg/L chlorine residua/for critical water (defined as those waters which come into close human contact, such as lakes and rivers used for drinking water, shell.fishing, and for contact watersports) and 1.0 to 2.0 mg/Lfornon critical waterare appropriate.

An aquatic ecological risk assessment is typically conducted where the antimicrobial is one that does not have a formally adopted AWQC. Underthese circumstances, the need for an aquatic ecological risk assessment and its setting ofendpoints, understanding offate, exposure analysis and modeling becomes more critical to understanding and characterizingrisk and aiding the Agency in appropriate label language

. It also provides a source for permit writers to develop appropriate site specific discharge limits, require pretreatment, ordeny use such that instream water quality standards are met.

Human Health Risks

A drinking waterrisk assessment for the mollusk use was not necessary as the AWQC are already risk-based values 15 :

EPA's section 304(a) human health guidelines attempt toprovide criteria which minimize orspecify thepotential risk of adverse human effectsdue to substances in ambient water (45 FR 79347).

14 Sprecher, S.L. and K.D. Getsinger. US Army Corps ofEngineers, Engineer Research and Development Center. Environmental Laboratory ERDC/ELTR-00-l. 15 http://water.epa.gov/lawsregs/rulesregs/ntr/index.cfm 

### Page 5 of7EPA's section 304(a) criteriaforhuman health are based on two types of biological endpoints: (1) carcinogenicity and (2) systemic toxicity (i.e., all otheradverse effects other than cancer). 

### Thus, there are twoproceduresfor assessing these health effects: onefor carcinogens andonefor noncarcinogens.

Methods used to conduct these risk assessments are from time to time updated. The most recent is EPA's (2000)MethodologyforDerivingAmbient Water Quality Criteriafor the Protection of Human Health Technical SupportDocument, Volume 1: RiskAssessment16• The current AWQC were updated using these methods. The formally adopted human health AWQC are legally enforceable criteria (state water quality criteria can be more stringent). Information provided by an additional drinking water risk assessment would notresult in any additional label change ormodification ofthe enforceable water quality criteria. While, for example, DixichlorMaxhas a higher use rate for mollusks than otherhypochlorite labels, this does not allow contravention or override ofwater-quality based discharge permitlimits which would be imposed under NPDES, compliance with which is already required on the label.



### 2. Biocides otherthanHypochlorites

Mulluscicides and theirregistration review status are listed in Table

### 4 in Attachment 

### 1. Many ofthese biocides have been determined as requiring specific biocide/ antimicrobial aquatic risk assessments. Through the registration review program, the agency will be evaluating the adequacy ofdata/risk assessments supporting these biocides. These substances and their registration review status are listed below in Table 4, and we encourage Marrone Bio Innovations to engage in the public process available underregistration review for these substances.
Unlike the hypochlorite registrations, the agency was not able to take advantage ofa formally adopted ambient water quality criteria (A WQC) for many ofthe biocides, otherthan the hypochlorites, for our antimicrobial/biocide evaluations. Under the CW A, where formally adopted numeric criteria for an antimicrobial do not exist, NPDES permit writers can use other sources ofinformation to develop limits, such as public literature, government generated data, models, and risk assessments conductedby the OPP, to inform the site-specific facility water-quality based discharge permit limits.

To be clear, we agree with you that the addition ofnew use rates to antimicrobial pesticide products used in industrial processes and water systems triggers the need for an updated risk assessment or, at a minimum, a determination as to why such an update is not needed, and I have recently emphasized these points to my leadership team in the Antimicrobial Division.



### 3. ProceduralIssues Relatedto Sodium Hypochlorite Registration Review
Finally, you indicate in your letter that"

...interested parties were prevented from submitting comments on the scoping document, for which the commentperiod had already closed by the time the public hadbeen notified in April thatthe case had been moved upto 2012." We note that under the registration review program chemical specific public comments are sought on preliminary work plans, proposed risk

16http://water.epa.gov/scitech/swguidance/standards/criterialhealthlmethodology/upload/2005 05 06 criteria humanhe alth method supportdoc.pdf Page 

### 6 of7assessments, and proposed decisions. TheProduct Chemistry, Environmental Fate, andEcological Effects Scoping Document in Support of Registration Review of Sodium & Calcium Hypochlorite Salts that you claim you were prevented from commenting on was a supporting documentto thepreliminary work plan. This type ofsupporting document does not go through a separate commentperiod outside ofthepreliminary work plan comment period. Opportunity was made by the agency to comment on the preliminary work plan and the commentperiod closed on May 29, 2012 (77 FR 18810).
Although the comment period has closed, we have placed your 2/20/2013 and 9/25/2012letters, this letter, and Joan Harrigan-Farrelly's response in the Sodium and Calcium Hypochlorite Registration Review public docket.

cc: RobertMcNally Sincerely,

# J.~~j~~ Antimicrobials Division (751OP) Office ofPesticide Programs U.S. Environmental Protection Agency

Page

### 7 of7

## Attachment 1 to SusanLewis's 2014 Letterto KeithPitts ofMarroneBio Innovations
Table 1. 

### Typical Aquatic Animal Data Requirements for Use in IndustrialProcesses andWater System Uses Aquatic Animal Data Requirements**TypeofTes~** 

### NumberofTests Acute freshwater fish toxicity 2 species (one warm water and one cold water) Acute freshwater invertebrate 1 species Acute estuarine/marine mollusk 1 species (either a shell deposition or an embryo/larval test) toxicity Acute estuarine/ marine fish 1 species toxicity Acute estuarine/ marine shrimp 1 species toxicity Fish early life stage 1 species (the more sensitive ofthe freshwater or estuarine/marine species) Aquatic invertebrate life-cycle 1 species (more sensitive ofthe freshwater orestuarine/marine species)

A 40CFR Part 158.2240


### Table 2. Aquatic Animal Data Requirements for Use ofHypochlorites in Cooling Towers and Studies A "I 

### bl S

. f 

### Th D 

### ta R

va1 a e to atlsty ese a equuements Aquatic AnimalData Requirementsfor HypochloritesA.8 

### Available Studies Cited in 

### Type ofTeste NumberofTests ScopingDocument Acute freshwater fish toxicity 2 species (one warm water and one 20 species (>80 tests), includes cold water) both cold and warm water species, and preferred test species Acute freshwater invertebrate 1 species 12 species (>20 tests), includes preferred test species (3 ofthese species were freshwater mollusks) Acute estuarine/marine mollusk 1 species (either a shell deposition or 1 species toxicity an embryo/larval test) Acute estuarine/ marine fish 1 species 11 species (12 tests), includes toxicity Ipreferred test species Acute estuarine/ marine shrimp 1 species 7 species (11 tests), includes toxicity Ipreferred test species Fish early life stage 1 species (the more sensitive ofthe Freshwater a higher tier life cycle freshwater or estuarine/marine test with 1 species (2 tests); species) Saltwater: 1 species (1 test) Aquatic invertebrate life-cycle 1 species (more sensitive ofthe Freshwater: 2 species freshwater or estuarine/marine species)

A40CFR Part 158.2240

8 Aquatic planttesting data requirements include4 algal species and I vascular species (40CFR 158

.2250), studies are available for each species, the type ofdata available provides supplemental information

. No additional testing was required to characterize risk.



### Page 1 of5c Sodium and calciumhypochloritephysical-chemical properties do not trigger concerns that toxicity to benthic invertebrates is underrepresented by

watercolumn testing; therefore sediment testing is notrequired

.


### Table 3. Human Health National Ambient Water Quality Criteria and Office ofDrinking Water MCL**~** 

### Chi d Chi ti B P d ts 

### s or onnean onna on iY- 

### ro uc National Ambient Water Quality Criteria for Drinking Water Compound Human Health from: Re2ulations Water and Aquatic Organism MCLAIMRDL Or2anism In2estion Consumption Only Chlorine (as Ch) none none 4,000 J.lg/L 

### Halomethane disinfection by-products Chloromethane (or methyl chloride) 0.19 J.lg/L8 15.7 J.lg/LB 

### none Dichloromethane (or methylene 4.6 J.lg/LB,C 590 J.lg/LB,C 

### 5J1g!L chloride) Trichloromethane (or chloroform) 5.7 J.lg/LB,D 470 J.lg/LB 

### SeeiTHMs Chlorodibromomethane 0.40 J.lg/LB,C 13 J.lg/LB,C 

### SeeiTHMs Dichlorobromomethane 0.55 J.lg/LB,C 17J.lg/LB,C 

### SeeiTHMs Tribromomethane (orbromoform) 4.3 J.lg/LB,C 140 J.lg/LB,C 

### SeeiTHMs Total Trihalomethanes (ITHMs) See individual THMs See individual THMs 80 J.lg/L 

### Haloacetic acids0 

### none none 60 J.lg/L

AMaximum contaminant level in drinking water (byproducts); Maximumresidual disinfectant level (chlorine)

. 8 Valuepresented is for a 10-6 incremental increase ofcancerrisk over a lifetime

. Alternaterisk levels may be obtainedby moving thedecimal point (e

.g., for a risk level of 10'5

, movethedecimal point in the recommended criterion one placeto the right)

. cThis criterion reflects the EPA's q1 *orRID, as contained in the Integrated Risk Information System (IRIS) as ofMay 17,2002

.The fish tissue
bioconcentration factor (BCF) from the 1980AmbientWater Quality Criteria documentused to derive the original criterion was retained in each case
. 0 monochloroacetic acid; dichloroacetic acid; trichloroacetic acid; bromoacetic acid; dibromoacetic acid



### Page 2 

### of5

### Table 4. Status ofRegistration Review Actions for Active Ingredients with Aquatic Molluscicide Uses

'

. Registration -1 '. Review Summary Active PC Ingredient Code Case# Document/ RegistrationReview FinalWorkPlans (FWPs) Preliminary Work Plans (PWPs) Alkyl trimethylenediamines 3014 Q1 2015 Q3 2015 (ATMDs;J7

N-(coco alkyl) 067301trimethylenediamine Inorganic Halides 14 4051 Completed 03/18/2009 Completed 09/23/2009

Sodium Bromide 013907 (EPA-HQ-OPP-2009- (Note: Used in 0168) presence of activators such as hypochlorites, chlorine gas, potassium monopersulfate,
orozone to form hypobromous acid) Na andCa 0029 Completed 03/28/2012 Completed 09-28-2012 Hypochlorites19 (EPA-HQ-OPP-2012-

Sodium 014703 0004) Hypochlorite Peroxy Compounds 4072 Docket opened Completed 03/3112010

Hydrogen 000595 0912009 (EPA-HQperoxide OPP-2009-0546) Ethaneperoxoic 063201 acid Dihalodialkylhydantoin.l1 3055 Docket opened Q1 2014 (Note: these react to release 06/19/2013 (EPA-HQhypochlorous acid, and OPP-2013-0220) degradates: DMH and EMHJ

2,4-Imidazo- 006315 lidinedione, 1-bromo-3-chloro5,5-dimethyl 1,3-dichloro-5,5- 028501dimethylhydantoin 1,3-Dichloro-5- 128826 ethyl-5- methylhydantoin Chlorine dioxide 4023 Q3 2015 Q1 2016

Sodium chlorite 020502 (Note: used with hypochlorite at application site to form chlorine dioxide) Chlorine dioxide 020503

17 Case also includes PC Codes 067302; 067309; 067310; 067313 18 RED Case also included PCCodes 013902 and 013905 and RR Case includes these plus 075605 19 Case also includes PC Code 014701 (Calciumhypochlorite) 2

## °

Case also includes PC Code 063604 21 RED Case also includedPCCode006137 and the RR Case also includes this PC Code and 028500, 128989, and 006322 

### Page 3 of5

# . Registration Active PC Review Summary Ingredient Code Case# Document/ Registration Review Final WorkPlans (FWPs) Preliminary Work Plans (J:»WPs) Coppercompounds 0636 Docket opened Completed 03/28/2011

Copper sulfate 024401 09/22/2010 (EPA-HQpentahydrate OPP-2010-0212) Endothallandsalts 2245



### --

Endothall, 038905mono(N,Ndimethyl alkyl amine) salt Glutaraldehyde 043901 2315 Q4 2014 IQ2 201s Dodecylguanidine 044303 0161



### -- hydrochloride 2-Phenylp_henol andSalts<' 2575 Docket opened Q2 2014

o-Phenylphenol 064103 9/25/2013 (EPA-HQOPP-2013-0524) Poly(oxy-1,2- 069183 3034 Q42015 Q2 2016 ethanediyl- (dimethylimino)- 1,2- ethanediyl(dimethyl imino)-1,2- ethanediyl dichloride) (a.k.a. Busan 77) Polyquaternary ammonium 0350 Q4 2015 Q2 2016 compoundi3

Alkyl* dimethyl 069105 benzyl ammonium chloride (ADBAC) *(40% C12; 50% C14; 10% C16) ADBAC(5% 069104 C12; 60% C14; 30% C16; 5% C18) Dialkyl* methyl 069119 BAC *(5% C12; 60%C14; 30% C16; 5% C18) Alkyl* dimethyl 069154 ethylbenzyl AC *(68% C12; 32% C14) Alkyl* dimethyl 069175 BAC *(67% C12, 25% C14, 7% C16, 1% C18) Aliphatic alkyl quaternaries (DDACy24 3003 Q4 2015 Q2 2106

22 Case also includes PC Code 064104 and 064108 23 Case also includes 069106; 069107; 069111; 069112; 069122; 069125; 069129; 069134; 069137; 069140; 069141; 069154; 069157; 069171; 069171;069175;069184;069189;069194; 128928; 169108;and169159 24 RED Case included PC Code 069146; 069165; 069166; 069173 and the RR Case includes theseplus 018101; 129012 

### Page 

### 4 

### of5Registration Active PC Review Summary Ingredient Code Case# Document/ Registration ReviewFinal WorkPlans (FWPs) Preliminary Work Plans (PWPs) 1- 069149 Decanaminium,N-decyl-N,Ndimethyl-, chloride Decyl isononyl 069207



### -- Completed 03/31/2010 Completed 08/05/2010 dimethyl (EPA-HQ-OPP-2010- ammonium 0005) chloride (DIDAC) Inorganic Chlorates' 4049 TBD TBD

Sodium chlorate 073301 (Used to generate chlorine dioxide at use site) Niclosamide 077401 2455 Completed 3/2012013 Completed 08/02/2013 (EPA-HQ-OPP-2013-0137) (EPA-HQ-OPP-2013- 0137) Methiocarb 100501 0577 Completed 6/25/2010 Completed 12/08/2010 (EPA-HQ-OPP-2010-0278) (EPA-HQ-OPP-2010- 0278) Methylisothiazolinone (a

.k.a. 3092 Q2 2015 TBD DMO)

5-Chloro-2- 107103 methyl-3(2H)- isothiazolone 2-methyl-3(2H)- 107104 isothiazolone 2-Propen-1- 128727

-- Q1 2015 Q3 2105 aminium, N,Ndimethyl-N-2- propenyl, chloride, homopolymer Bronopol 216400 2770 Completed 06129/2011 Completed 12/30/2011 (Note: (EPA-HQ-OPP-2011- Formaldehyde is a 0421) degradate)

25 Case also includes PC Code 073302; 073303; and 530200 

### Page 5 

### of5