1 Schaeffer, John

To: John Schaeffer Subject: Response to Harcos Chemicals regarding review for C ASRN 31138-65-5

From: Lin, Chuantung

Sent: Thursday, February 26, 2015 12:59 PM

To: Schaeffer, John

Cc: Njo, Heather; Williamson, Tracy; Christian, Myrta Subject: Re: Response to Harcos Chemicals regarding review for CASRN 31138-65-5

Hi John,

Sorry for the delay. This case must have slipped aw ay from my to do list during recent snow weather

conditions.

The followings are ICB's responses to the tested re sults sent from the sponsor of HPV 2 test chemical, Sodium glucoheptonate (CASRN 31138-65-5):

ICB has reviewed the test results and the related t est methods used to determine the Pour Point (in lieu of Melting Point/ Freezing Point ), Boiling Point, Water Solubility , and the estimated Log P value of Sodium glucoheptonate (CASRN 31138-65-5) required under th e TSCA Section 4 Test Rule for HPV Group 2 chemicals. In a pre-testing communication between EPA and the Sponsor of this test chemical, EPA has agreed with the Sponsor of this test chemical to us e whatever "dried" sample they could get in their t esting (due to 100% of dried sample could not be easily ob tained). The test samples used to obtain these P/Ch em data endpoints were ~50% aqueous solution as indica ted in its moisture content test (which was determi ned to be 49.5% w/w (495 g/kg) in test result submitted by the Sponsor). Therefore, the test sample was a "liquid" form, instead of solid, and the Pour Point test is used for Freezing Point/Melting Point endpoint.

ICB reviewer agrees with these test results and the y could also be accepted to fulfill the HPVC 2 Test Rule's requirements for the P/Chem data endpoints (A1, A2, A4, and A5). However, ICB reviewer suggests to indicate that the test result of 117 ± 1 °C at 102.9 kPa (p artially boils from this temperature) for the Boili ng Point provided by the sponsor should be treated as the "d ecomposing temperature", instead. The "Pour Point" value could be used in lieu of the Melting Point./F reezing Point. it is expected the melting point an d boiling point of neat/dried salt compound to be very high ( even decomposing before melting or boiling). An estimated Log P value is accepted per previous agre ement between EPA and the Sponsor of this test chem ical.

Please let me know if you have any other questions on this matter.

Thanks!

Daniel

Daniel (Chuantung) Lin, Ph.D.2 Chemist, Industrial Chemistry Branch

Office of Pollution Prevention and Toxics

US EPA 1200 Pennsylvania Ave., NW (7406M) [Deliveries to: 1201 Constitution Ave., NW, EPA Eas t (WJC) 5133E] Washington, DC 20460

202-564-8584 (direct) 202-564-8740 (branch) 202-564-8679 (fax)

----- Forwarded by Chuantung Lin/DC/USEPA/US on 02/ 12/2015 01:24 PM -----

From: Chuantung Lin/DC/USEPA/US To: Paul Campanella/DC/USEPA/US@EPA, Cc: David Brooks/DC/USEPA/US@EPA, John Schaeffer/DC/USE PA/US@EPA, Tracy Williamson/DC/USEPA/US@EPA, Myrta Christian/DC/USEPA/US@EPA Date: 08/15/2012 04:18 PM Subject: Re: Fw: Response to Harcos Chemicals regarding revi ew for CASRN 31138-65-5

Hi Paul,

After I discussed with Tracy on this HPV2 test chem ical, ICB agrees that the company could just go ahe ad to test the required P/C endpoints with whatever "dried" sample they could get. For the nature of salt compounds such as sodium glucoheptonate (CASRN 31138-65-5), it is expected t he melting point and boiling point be very high (ev en decomposing before melting or boiling). They could just report the decomposition temperature with the dried sampl e they could obtain. As for the water solubility of this salt c ompound, we expect that it should excess 50% level (due to the commercial product they could get was in 50% or greater aqueou s solution). They could just go ahead doing the te sting on those P/C endpoints as required by the Test Rule. Log P valu e could be estimated as indicated in the testing re quirements for this chemical.

For other toxic endpoints, RAD should be able to ad dress this question (to use the dried sample that t hey could get) from their perspectives.

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)