Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-09-61 

EPA Docket EPA-HQ-OPPT-2010-1075 

 

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Index

A-001 Structure Activity Team (SAT) Report for 

PMN P-09-61 

A-002 Initial Review Engineering Report for 

PMN P-09-61 

A-003 Initial Review Exposure Report for 

PMN P-09-61 

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A-001 

Structure Activity Team (SAT) Report 

 for PMN P-09-61 

 

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SAT Report

PMN Number: P-09-0061

SAT Date: 11/21/2008

Related cases:

Health related cases: 

Ecotox related cases: 

Concern levels:

Type of Concern: Health Eco Comments

Level of Concern: 1 3 Health: ; Eco: chronic toxicity only

 Persistence Bioaccum Toxicity Comments

 2 1 1

Exposure Based Review:

Health: No

Ecotox: Yes

Routes of exposure: Health: No exposures needed

Ecotox: All releases to water

Fate: ;

P2Rec Comments:

Comment: SAT had no comment

Keywords:

 Keywords: 

Summary of Assessment:

 Fate:

Fate Summary: P-09-0061

FATE: 

Solid with MP = 194-196 EC (M)

log Kow = -1.62 (M); 

S = 9.3 g/L at 25 EC (M)

VP < 1.0E-6 torr at 25 EC (E)

BP = Dec. 199 EC (M)

H < 1.00E-8 (E)

log Koc = 1.41 (E)

log Fish BCF = 0.50 (E) 

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POTW removal (%) = 0 

Time for complete ultimate aerobic biodeg = mo

Sorption to soils/sediments = low

PBT Potential: P2B1

*CEB FATE: Migration to ground water = rapid

 Health:

 Health Summary: Not absorbed through the skin as the neat material, poor

through the skin if in solution; moderate absorption from the GI tract and good absorption from 

the lung (pchem). No significant health concerns.

 Test Data: (-) Salmonella with and without activation; (-) in all 

strains with activation; (-) E. coli with and without activation; (-) for chromosome aberrations in 

human peripheral blood lymphocytes; rat oral LD0 = 5000 mg/kg; (-) for skin sensitization in a 

mouse local lymph node assay

 Ecotox:

Test 

Organism

Test 

Type

Test End 

Point

Predicted Measured Comments

fish 96-h LC50 500 >120 Limit test; highest conc 

tested; No LOEC

daphnid 48-h LC50 160 >120 Limit test; highest conc 

tested; No LOEC

green algal 96-h EC50 750 >120 Limit test; highest conc 

tested; No LOEC

fish _ chronic value 34/0.064 30-dy/60-day

daphnid _ chronic value 30

algal _ chronic value 360

Sewage Sludge 3-h EC50 _

Sewage Sludge _ Chronic Value _

Ecotox Values Comments: Predictions are based on SARs for ; SAR chemical class 

 MW 215; log Kow = 1.74 (EPI), -1.62 (M); pH7; effective concentrations 

based on 100% active ingredients and nominal concentrations; hardness <180.0 mg/L as 

CaCO3; and TOC <2.0 mg/L;

 P09-0061

EVALUATION OF ECOTOXICITY STUDIES

For Friday, November 21, 2008 FOCUS

 Evaluator: S. Cragg

 Nominal ECOSAR

 Concentration Predicted

 Test Type Function EvaluateParameter Measu(mg a.i./L)(a) Value (mg/L)

 Acute Freshwater Fish Lethality 96-hr LC50 >120 500

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 Zebra Fish LOEC >120

 (Danio rerio) NOEC >120

 static

 Acute Freshwater Copepod Mobility 48-hr EC50 >120 160

 (Daphnia magna) LOEC >120

 static NOEC >120

 "Limit Test"

 Acute Freshwater Algae Growth Inhibition

(Pseudokirchneriella subcapita Growth Rate† 72-hr ErC50 >120 750

 LOEC >120

 NOEC >120

 Yield 0-72-hr EyC50 >120

 LOEC >120

 NOEC >120

 ECOSAR fish chronic 34/0.064

 ECOSAR daphnia ChV 30

 ECOSAR algal ChV 360

(a) Value represents nominal values verified via analytical measurement (HPLC with UV 

detector). Agreement > 95%.

† Concentration that reduced growth rate by 50%.

†† Concentration that reduced yeild (cell density) by 50%.

Conclusion: Results from the three limit tests are considered valid. No effects were detected 

(mortality, behavior, morphology, or growth) for fish, daphnia, or algae at the limit concentration 

of 120 mg/L. The concern concentration may be derived by dividing 120 mg/L by a factor of 10 

to approximate a chronic value and then again by a second assessment (uncertainty) factor of 10 

to yeild a concentration of concern (CoC) of 1.2 mg/L or 1,200 μg/L, rounded to 1,000 μg/L 

(ppb). The PMN is of low concern for ecotoxicity.

 Fish Daphnia Algae

Test compound purity (%): 99.1 99.1 99.1

Temperature Range (°C): 21.0 - 22.5 18.1 - 18.4 24

O2 concentration (mg/L): 6.90 - 7.99 7.68 - 7.95

Water Hardness: 166 200

pH: 6.85 - 7.22 7.15 - 7.21 7.3 - 7.6

Conductivity 535 478

Nominal or Measured? Nominal* Nominal* Nominal*

Flow-through/Static/Semi-stati Static Static Static

Certificate of Analysis? Yes

* with analytical confirmation

EPA SANITIZED Page 6 of 25
 Estimated Measured

Physical State -- Solid

Volatility (mmHg) 1.0E-06 --

Absorptivity (Log Koc) N/D --

Log Kow -- -1.62

Water Solubility (mg/L) -- 9,300

Henry's Law Constant 1.0E-08 --

Sorption to Soils low --

Factors Values Comments

Assessment Factor 10

Concentration of Concern 

(ppb)

6

SARs

SAR Class

Ecotox Factors Comments: 

 SAT Chair: L Keifer 564-8916

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A-002 

Initial Review Engineering Report 

 for PMN P-09-61 

 

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INITIAL REVIEW ENGINEERING REPORT

P-09-0061

Focus Ready Draft 12/8/2008

ENGINEER: Jon \ JAS

PV (kg/yr): 

Revision Notes/Assessment Overview:

SUBMITTER: DuPont Agricultural Caribe Industries, Ltd. (submitter)

USE: Chemical intermediate for an herbicide.

OTHER USES:

MSDS: LABEL: 

Gen Eqpt:

Respirator:

Health Effects:

TLV/PEL: 

CRSS:

Chemical Name: 

S-H2O:

VP: 

MW: 

 

 

Consumer Use: No

SAT (concerns):

Migration to groundwater: Rapid

PBT rating: P2 B1 T1

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Health: 1

Eco: 3, Water (All releases to water with a CC = 6 ppb), 

OCCUPATIONAL EXPOSURE RATING: NR

NOTES & KEY ASSUMPTIONS:

Generated by the 06/07/2005 version of ChemSTEER. 

POLLUTION PREVENTION CONSIDERATIONS:

P2 Claim: 

P2 REC:

EXPOSURE-BASED REVIEW: 

 

 

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P-09-0061

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OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis: 

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A-003 

Initial Review Exposure Report 

 for PMN P-09-61 

 

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INITIAL REVIEW EXPOSURE REPORT (IRExR) 

 Chemical ID: P090061 Reviewer: Sherer 

 

Results Table: Dose, Concentration, and Days Exceeded Results Summary 

Exposure Scenario1 Water Landfill Stack Air Fugitive Air 

Drinking Water Fish Ingestion 

ADR LADD ADR LADD 

7Q10 

CC=6 

PDM 

Days 

Exceeded

LADD ADR LADD ADR LADD 

Release activity(ies)2; 

exposure 

calculation(s)3

mg/kg/day mg/kg/day mg/kg/day mg/kg/day μg/l # Days mg/kg/day mg/kg/day mg/kg/day mg/kg/day mg/kg/day 

--- --- --- --- 2.41 --- --- --- --- --- --- 

--- --- --- --- 1.38 --- --- --- --- --- --- 

--- --- --- --- 2.38 3 --- --- --- --- --- 

--- --- --- --- 1.36 --- --- --- --- --- --- 

1

 Exposure scenario titles consist of release activity followed by exposure calculation abbreviation. 2 Release activities are from engineering report's Manufacturing (Mfg), Processing (Proc) and Use release activity 

labels. 

Multiple release activities are combined in one exposure scenario if their releases occur at same location. 3

 Exposure calculations are Acute Dose Rate (ADR), Lifetime Average Daily Dose (LADD), and Probabilistic 

Dilution Model (PDM). There may be one, two, or all three exposure calculations per exposure scenario. 

CC is the aquatic concentration of concern. 

Remarks: 

Exposure Based Criteria 

Parameter 

Drinking (Surface) Water Dose (mg/kg/day) 

Fish Ingestion Dose (mg/kg/day) 

Inhalation Dose (mg/kg/day) 

Groundwater Dose (mg/kg/day) 

Surface Water Release After Treatment (kg/yr) 

Total Release After Treatment (kg/yr) 

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INITIAL REVIEW EXPOSURE REPORT (IRExR) 

Summary Table: Endpoints assessed 

Endpoints-Assessed Table 

Reasons for not assessing releases 

Endpoints/Assessment 

Cycles1

Releases 

Assessed 

in 

NCEM2? 

No XB 

Testing 

Required 

No 

Hazard 

Concern 

No 

Releases 

Release 

Below 

Acute 

Threshold5

Release 

Below 

Chronic 

Threshold5

Other 

Ingestion 

 Surface water N NA X 

 Ground water (landfill) N NA X 

 Consumer Use: DtD2 N NA X 

Inhalation 

 Air: incineration (stack) N NA X 

 Air: fugitive N NA X 

 Consumer Use: CEM3 N NA X 

Dermal 

 Consumer Use: CEM N NA 

Eco 

 Surface water: ADR 

conc and/or PDM4

Y NA 

 Consumer Use: DtD N NA 

1

Assessment cycles are endpoint concentrations and dose calculations within the NCEM2 model. 

2

Down-the-Drain Module 

3

Consumer Exposure Module 

4

Probabilistic Dilution Model 

5

The threshold values for assessing endpoints are 1 mg/day for acute doses and 1 mg/year for chronic doses. 

Remarks: 

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 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P090061 Assessor: Sherer 

ENVIRONMENTAL RELEASES 

 Scenario#:1 Number of Release Sites: 

 Release Activity: 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 

 (kg/yr) (kg/yr) (kg/yr) (kg/yr) 

 

 Non-sludge/Sludge 

Release Days/yr: 

Per Site Release: 

 (kg/site/day) (kg/site/day) (kg/site/day) (kg/site/day) 

Remarks: 

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INITIAL EXPOSURE REVIEW REPORT 

 Chemical ID: P090061 

SITE-SPECIFIC HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

SCENARIO NUMBER:1 RELEASE ACTIVITY: 

FACILITY NAME: 

FACILITY LOCATION: 

RECEIVING WATER NAME: 

REACH NUMBER: FACILITY ON REACH: DISCHARGE TYPE: 

NPDES PERMIT #: EXPOSED POPULATION: Adult 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PRETREATMENT 

RELEASE 

(kg/site/day) 

POSTTREATMENT 

RELEASE 

(kg/site/day) 

DWT 

(%) BCF 

(L/kg) 

 

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER 

FLOW DESCRIPTOR Harmonic Mean 30Q5 7Q10 1Q10 PLANT 

FLOW (MLD) 

CONCENTRATION (μg/L) 0.67 1.77 2.41 3.03 NA 

DRINKING WATER INGESTION AND FISH INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water 

Results 

Drinking Water 

Units 

Fish Ingestion 

Results 

Fish Ingestion 

Units 

Cancer 

LADDpot 1.44E-08 mg/kg/day 1.95E-10 mg/kg/day 

LADCpot 7.37E-07 mg/L 2.33E-06 mg/kg 

Acute 

ADRpot 1.48E-04 mg/kg/day 3.82E-06 mg/kg/day 

Surface Water Comments: 

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 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P090061 Assessor: 

ENVIRONMENTAL RELEASES 

 Scenario#:2 Number of Release Sites: 

 Release Activity: 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 

 (kg/yr) (kg/yr) (kg/yr) (kg/yr) 

 

 Non-sludge/Sludge 

Release Days/yr: 

Per Site Release: 

 (kg/site/day) (kg/site/day) (kg/site/day) (kg/site/day) 

Remarks: 

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INITIAL REVIEW EXPOSURE REPORT 

CHEMICAL ID: P090061 

SITE-SPECIFIC HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES: 

LAKES, BAYS, ESTUARIES, AND OCEANS 

SCENARIO #: 2 RELEASE ACTIVITY: 

FACILITY NAME: 

FACILITY LOCATION: 

RECEIVING WATER NAME: 

REACH NUMBER: FACILITY ON REACH: DISCHARGE TYPE: 

NPDES PERMIT #: EXPOSED POPULATION: Adult 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PLANT FLOW 

(MLD) 

PRETREAT 

RELEASE 

(kg/site/day) 

POST-TREAT 

RELEASE 

(kg/site/day) 

BCF 

(L/kg) 

 

AQUATIC EXPOSURE ESTIMATES 

MIXING ZONE DILUTION FACTOR WATER CONCENTRATION (ug/L)

ACUTE SCENARIO 1.38 

CHRONIC SCENARIO 1.38 

FISH INGESTION EXPOSURE ESTIMATES 

ASSUMPTIONS 

Exposure Units Results ED 

(years) 

AT 

(years) 

BW 

(kg) 

IR 

 (g/day) 

Cancer 

LADDpot (mg/kg/day) 3.99E-10 30.00 75.00 71.80 6.00 

LADCpot (mg/kg) 4.77E-06 30.00 75.00 NA NA 

Acute 

ADRpot (mg/kg/day) 7.83E-06 NA 1 day 71.80 129.00 

Lakes Comments: 

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 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P090061 Assessor: 

ENVIRONMENTAL RELEASES 

 Scenario#:3 Number of Release Sites: 

 Release Activity: 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 

 (kg/yr) (kg/yr) (kg/yr) (kg/yr) 

 

 Non-sludge/Sludge 

Release Days/yr: 

Per Site Release: 

 (kg/site/day) (kg/site/day) (kg/site/day) (kg/site/day) 

Remarks: 

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INITIAL EXPOSURE REVIEW REPORT 

 Chemical ID: P090061 

SITE-SPECIFIC HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

SCENARIO NUMBER:3 RELEASE ACTIVITY: 

FACILITY NAME: 

FACILITY LOCATION

RECEIVING WATER NAME: 

REACH NUMBER FACILITY ON REACH: DISCHARGE TYPE: 

NPDES PERMIT #: EXPOSED POPULATION: Adult 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PRETREATMENT 

RELEASE 

(kg/site/day) 

POSTTREATMENT 

RELEASE 

(kg/site/day) 

DWT 

(%) BCF 

(L/kg) 

 

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER 

FLOW DESCRIPTOR Harmonic Mean 30Q5 7Q10 1Q10 PLANT 

FLOW (MLD) 

CONCENTRATION (μg/L) 0.66 1.75 2.38 2.98 NA 

DRINKING WATER INGESTION AND FISH INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water 

Results 

Drinking Water 

Units 

Fish Ingestion 

Results 

Fish Ingestion 

Units 

Cancer 

LADDpot 1.98E-06 mg/kg/day 2.68E-08 mg/kg/day 

LADCpot 1.02E-04 mg/L 3.21E-04 mg/kg 

Acute 

ADRpot 1.46E-04 mg/kg/day 3.76E-06 mg/kg/day 

Surface Water Comments: 

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INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P090061 

SITE-SPECIFIC HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

SCENARIO NUMBER: 3 RELEASE ACTIVITY: 

FACILITY NAME: 

FACILITY LOCATION: 

RECEIVING STREAM NAME: 

REACH NUMBER: FACILITY ON REACH: DISCHARGE TYPE: 

NPDES PERMIT NUMBER: GAGING STATION ID: 

GAGING STATION 

PERIOD OF RECORD: N/A 

GAGING STATION 

NUMBER OF 

OBSERVATIONS: 

NUMBER OF STATIONS ON 

REACH: 

MEAN FLOW (MLD): 7q10 FLOW (MLD): EFFLUENT FLOW (MLD)

 

RESULTS 

COC (μg/L) 

Percent of Year 

COC Exceeded 

Number of Days 

COC Exceeded 

Release 

days/year 

Pre-treatment 

Loading 

(kg/site/day) 

Waste Water 

Treatment (%) 

6.00 1 3 140.00 

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 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P090061 Assessor: 

ENVIRONMENTAL RELEASES 

 Scenario#:4 Number of Release Sites: 

 Release Activity: 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 

 (kg/yr) (kg/yr) (kg/yr) (kg/yr) 

 

 Non-sludge/Sludge 

Release Days/yr: 

Per Site Release: 

 (kg/site/day) (kg/site/day) (kg/site/day) (kg/site/day) 

Remarks: 

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INITIAL REVIEW EXPOSURE REPORT 

CHEMICAL ID: P090061 

SITE-SPECIFIC HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES: 

LAKES, BAYS, ESTUARIES, AND OCEANS 

SCENARIO #: 4 RELEASE ACTIVITY: 

FACILITY NAME: 

FACILITY LOCATION: 

RECEIVING WATER NAME: 

REACH NUMBER: FACILITY ON REACH: DISCHARGE TYPE: 

NPDES PERMIT #: EXPOSED POPULATION: Adult 

WWT 

REMOVAL 

(%) 

RELEASE 

DAYS 

PLANT FLOW 

(MLD) 

PRETREAT 

RELEASE 

(kg/site/day) 

POST-TREAT 

RELEASE 

(kg/site/day) 

BCF 

(L/kg) 

 

AQUATIC EXPOSURE ESTIMATES 

MIXING ZONE DILUTION FACTOR WATER CONCENTRATION (ug/L)

ACUTE SCENARIO 1.36 

CHRONIC SCENARIO 1.36 

FISH INGESTION EXPOSURE ESTIMATES 

ASSUMPTIONS 

Exposure Units Results ED 

(years) 

AT 

(years) 

BW 

(kg) 

IR 

 (g/day) 

Cancer 

LADDpot (mg/kg/day) 5.50E-08 30.00 75.00 71.80 6.00 

LADCpot (mg/kg) 6.58E-04 30.00 75.00 NA NA 

Acute 

ADRpot (mg/kg/day) 7.70E-06 NA 1 day 71.80 129.00 

Lakes Comments: 

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LEGEND FOR NEW CHEMICALS EXPOSURE REPORT 

This new chemicals exposure report was prepared by the Exposure Assessment Branch (EAB) of the Economics, 

Exposure and Technology Division, Office of Pollution Prevention and Toxics, USEPA. 

The goals of these reports are to calculate conservative (protective) estimates of exposure endpoints for consumers, 

the general population, and the environment. 

For each exposure scenario to industrial releases, the following three endpoints are calculated: 

(1) maximum possible acute concentrations and doses 

(2) maximum possible chronic concentrations and doses 

(3) for water releases ≥ 20 days, the probability of exceedence of the aquatic concentration of concern 

These endpoints are identified by abbreviations on the Release Activity line, e.g., (1) max ADR, (2) max 

LADD, (3) max PDM. Depending on the release inputs, these endpoints may be calculated and presented on 

the same page or different pages. That is, a release activity ID of mfg; max ADR, max PDM, max LADD

indicates that all the exposure endpoints were calculated from common manufacturing release values; 

conversely, a release activity ID of mfg &proc; max ADR indicates that only the maximum acute exposure 

values were calculated for manufacturing and processing releases that occurred at the same site. 

For each consumer product use exposure scenario, whether exposure is to the user directly or to the general 

population/environment, the maximum exposure values are calculated and presented together. 

In addition to the exposure values above, EPA policy directs that exposure and release values be compared to 

criteria threshold values for Exposure-based and PBT Exposure-based cases. 

Exposure-based (YX) cases (those with ≥ 100,000 kg/yr production volume) 

Criteria are exceeded under the following conditions: 

 Presence in consumer product with likely exposure 

≥ 3E-3 mg/kg/d exposure via air, fish ingestion or drinking water 

≥ 10,000 kg/yr release to environment (post-treatment) 

≥ 1,000 kg/yr release to water (post-treatment) 

Persistent, Bioaccumulative, Toxic (PBT) chemicals of P2B2 rating or higher and production volume ≥ 20,000 kg/yr 

Criteria are exceeded as for YX cases, with the following differences: 

≥ 2,000 kg/yr release to environment (post-treatment) 

≥ 200 kg/yr release to water (post-treatment) 

Bolding rules in the Report: Values for endpoints above that are also health or eco concerns are bolded. 

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