### Re: Fw : Robust Summary EPA Robust Summary EPA Robust Summary EPA - HQ - OPPT - 2009-0112 2009-0112 2009-0112

for CASRN for CASRN for CASRN

25321-41-9 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 30 o C 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 ~107.7 o C. 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 02/07/2013 01:01:11 PM Daniel, Does your discussion mean that EPA sh...
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 BiologistUSEPA / OPPT / CCD / CITB 1201 Constitution Ave, NW Washington, DC 20460 Mail Code: 7405M Phone: 202-564-8173 Chuantung Lin 02/07/2013 11:18:09 AM Hi John, I checked the test results that submitted.

.. 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 30 o C at 25 . 3 mm Hg (i. e. at a reduced pressure) . ICB used NOMO5 program (in house program) to convert such data to the temperature of 107.5 o 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 107.7 o 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 . 4 mm Hg @ 50 o C

C ; BP(obtained) is 123 o C @ 760 mmHg 2) VP = 30 . 1 mmHg @ 40 o C

; BP is 115.5 o C @ 760 mmHg 3) VP = 25 . 3 mmHg @ 30 o C (

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 is 107 . 5 o C @ 760 mmHg 4) VP = 22 . 2 mmHg @

20 o C ; 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

~ 23 mmHg @ 25 o C

) From these data, we could see the extrapolated BP values were in a close agreement. The average BP The average BP The average BP is 111 o C @ 760 mmHg

. 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 100 o C boiling 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 = 165 o C @ 0 . 1 mmHg (convertedby NOMO5 to 395 . 4 . o C @ 760 mmHg ) 2) para - Toluenesulfonic acid Toluenesulfonic acid Toluenesulfonic acid [CASRN 6192-52-5] - BP = 140 o C @ 20 mmHg (converted by NOMO5 to 241. 6 . o C @ 760 mmHg ). With these data for comparison purpose, the initial decomposition temperature of 30 o C at 25 . 3 mm Hg ( i . e . , 107 . 5 o C at 760 mm 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 02/06/2013 10:14:52 AM Daniel I am forwarding this email to you, it also c

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