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P-09-0198-99 2/20/2009

Assessor: Kwon

Production Volume:

USE:

OTHER USES:

Chemical Name:

Fate Assessment :

Due to the novel naturePage 2 of 4

P-09-0198-99 2/20/2009

These p-chem properties are novel to

Testing methods typical ly used for these parameters (e.g., ready biodegradation test, porous pot, etc.) may or may not apply.

EAB recommends that th e submitter evaluate the current OPPT guidelines for fate testing and then submit fate testing pr otocols based on their specific knowledge o the EAB’s fate experts for their revi ew prior to the actual testing.

General Population and Environmental Exposure

A qualitative evaluation of the releases estimated by CEB indicates that

uman inhalation, ingestion and dermal exposure may result from the water, landfill, incineration and fugitive releases.

t is recommended that the submitter work with EPA engineers, fate experts and exposure assessors for this PMN chemical.

Specific data needs from the submitter are summarized below:

Identify all releases and their media of release.

Questions for incineration releases: Provide information to CEB e ngineer on: What type of control technology is used for the incineration releases? What is its removal efficiency for the PMN substance? Are there any monitoring data available that demonstrate this efficiency? Provide data. Information to be provided to the EAB assessor: Are there any monitoring data

available downwind of the incine ration releases? Provide data.

Questions for air (fugitive releases) provide information to CEB e ngineer on: What type of control technology is used for the fugitive releases? What is its removal efficiency for the PMNPage 3 of 4

P-09-0198-99 2/20/2009

substance? Are there any monitoring data available that demonstrate this efficiency? Provide data. Information to be provided to the EAB a ssessor: Are there any monitoring data available downwind of the fugitive releases? Provide data.

Questions for water releases : If the facility the PMN substance is being release from is a direct discharger, is the waste water di scharged directly into the stre am or into a on-site treatment plant? If it is discharged into an on-site treatment plant, what is the treatment method, how much of the PMN substance is removed during treatment , where is the stream located, and are there any monitoring data to determine the amount released? Provide data.

If the waste water is being released into a Publicly Owned Treatment Works (POTW), how does the PMN substance behave during the various treatment steps typical of POTWs (e.g., flocculation, activated sludge, filtration, etc.)? How much of the PMN chemical is removed during treatment? What is the mechanism of removal (e.g., adsorption into the sludge, biodegradation, volatilation, etc.)? What test methodologies were used to determine the answer to the above questions? Also, where is the POTW located ? Provide data.

Questions for landfill releases: What type of landfill will the PMN substance be placed in? What is the potential for migration of the PMN s ubstance to the ground water? What testing data are available to support the migration potenti al of the PMN substance? Provide data.Page 4 of 4

P-09-0198-99 2/20/2009

Environmental Releases from the Engineering Report

Source Media of

Release kg/day/site days/yr kg/yr (all sites)

Water or Air

or Incineration

or Landfill

Incineration

Incineration

Total Releases kg/yr – all sites