Study Plan 

Solubility Determination of 

CASRN 78-11-5 

(Pentaerythritol tetranitrate ) 

In Hard Water 

Dyno Nobel Inc 

2795 East Cottonwood Parkway 

Suite 500 

Salt Lake City, UT 84121 

July 11, 2014 
Solubility of CASRN 78-11-5 (PETN) in Hard Water 

Purpose 

The purpose of this study is to determine the solubility of PETN in the hard water test medium used for 

acute toxicity testing to fish and Daphnia. 

Background 

During acute toxicity testing, the concentration of PETN in the testing medium could not attain the 

reported solubility limit of 2130 μg/L – the actual report provides a reported limit of 2130 μg/L for the 

48 hour sample, and a reported limit of 1950 μg/L for the 72 hour sample. The reported solubility limit 

was determined in accordance with 40 CFR 799.6784 which uses double distilled water as the test 

medium. 

Acute toxicity testing performed in accordance with ASTM E 729-96 provides specifications on the hard 

water to be used during the testing. A PETN concentration at or near the reported solubility limit in

hard water was not achieved during the acute toxicity testing. 

In correspondence from the U.S. Environmental Protection Agency to Dyno Nobel dated April 22, 2014, 

it was recommended that the solubility of PETN in the fish and Daphnia test medium be determined. 

Such testing should be performed under similar conditions (e.g., temperature, test medium, 

concentration of organic solvent, etc.) to those used in the aquatic toxicity tests. 

Hard Water for the Acute Toxicity Testing to Fish and Daphnia 

The hard water to be used in this solubility testing is to be the same as that which was used during the 

previously performed acute aquatic toxicity testing to fish and Daphnia. In accordance with ASTM E 

729-96, and as used by the laboratory that performed the acute aquatic toxicity testing, the 

reconstituted hard water consists of the following (based on a 15 Liter quantity): 

• NaHCO3 - 2280 mg (to attain 192 mg/L) 

• CaSO4 - 2H2O - 1800 mg (to attain 120 mg/L) 

• MgSO4 - 1800 mg (to attain 120 mg/L) 

• KCl - 120 mg (to attain 8 mg/L) 

• Selenium added to obtain nominal concentration of 2 μg/L 

• Target Chemistry is pH 7.6 - 8.0; Hardness 160 - 180; Alkalinity 110 - 120 

PETN Supplied to Aquatic Toxicity Laboratory 

PETN is a highly sensitive explosive compound. Laboratories that perform aquatic toxicity testing cannot 

manage and handle PETN unless it has been diluted to render the material non-explosive. To facilitate

the aquatic toxicity testing, acetone was used as a solvent to dissolve PETN to a nominal concentration 

of 5000 mg PETN/L acetone. The source of the PETN was the Dyno Nobel facility in Graham, KY. It was 

provided to the U.S. Army Center for Health Promotion and Preventative Medicine (CHPPM) for use 
during the HPV1 test studies. At the request of Dyno Nobel, the CHPPM provided the test material to 

the aquatic toxicity laboratory at the concentration of 5000 mg PETN/L acetone. The PETN to be used at 

the Dyno Nobel Lehi, UT facility will be sourced from the Graham, KY facility, and will be accompanied by 

an analytical specification sheet providing information on the material’s purity. The Lehi, UT facility will 

dissolve the PETN into acetone to establish a nominal concentration of 5000 mg PETN/L acetone. 

Methodology 

The reported solubility limit for PETN was derived by testing performed by CHPPM, and was 

subsequently submitted as part of the HPV1 testing rule. The same methodology for solubility testing 

(40 CFR 799.6784) will be utilized for the hard water solubility testing of PETN, except for the 

modifications needed to implement the recommendations provided in the April 22, 2014 

correspondence from the U.S. EPA. 

In email correspondence dated June 3, 2014, the U.S. EPA confirmed that it would be acceptable for 

Dyno Nobel’s laboratory to conduct the solubility testing for PETN as described in the earlier 

correspondence dated April 22, 2014. 

Modifications include: 

• Reconstituted hard water will be used as the test medium 

• PETN at a nominal concentration of 5000 mg PETN/L acetone at the test material 

• Temperatures of 20°C (Daphnia magna) and 25°C (Pimephales promelas) 

Test Report 

The report is to include the following information: 

a) The individual analytical determinations and the average where more than one value was 

determined for each flask. 

b) The average of the value for the different flasks which were in agreement. 

c) The test temperature. 

d) The analytical method employed