Support Documents for 

Significant New Use Rules (SNUR) on 

Premanufacture Notice (PMN) 

P-11-224 

EPA Docket EPA-HQ-OPPT-2011-0942 

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Index 

A-001 Structure Activity Team (SAT) Report for 

 PMN P-11-224 

A-002 Initial Review Engineering Report for 

 PMN P-11-224 

A-003 Initial Review Exposure Report for 

 PMN P-11-224 

A-004 TSCA Section 5(e) Consent Order and 

Determinations Supporting Consent Order for 

PMN P-11-224 

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A-001 

Structure Activity Team (SAT) Report 

for PMN P-11-224 

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SAT Report

PMN Number: P-11-0224

SAT Date: 3/11/2011

Print Date: 8/31/2011

Related cases:

Health related cases: 

Ecotox related cases: 

Concern levels:

Type of Concern: Health Eco Comments

Level of Concern: 1-2 3

 Persistence Bioaccum Toxicity Comments

3 11

Exposure Based Review:

Health: Yes

Ecotox: Yes

Routes of exposure: Health: Dermal Inhalation 

Ecotox: All releases to water

Fate: ; 4 not 2

Keywords:

 Keywords: NEURO; SENS-CARDIAC (UNCERT); AQUATOX; GLOBAL 

WARMING

Summary of Assessment:

 Fate:

Fate Summary: P-11-0224

FATE: 

H = 4.95E-1 (E)

log Koc = 2.90 (E)

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log Fish BCF = 0.99 (E)

log Fish BAF = 1.03 (E) 

POTW removal (%) ≥ 99 via stripping

Time for complete ultimate aerobic biodeg = mo

Sorption to soils/sediments = low

Volatilization half-life from a standard river = 2 hrs

Volatilization half-life from a standard lake = 6 da

Atmospheric Oxidation Half-life = 32000 hr via OH radical

PBT Potential: P3B1

*CEB FATE: Migration to ground water = moderate - rapid

 Health:

 Health Summary: Absorbed all routes (analog). Concern for neurotoxicity 

based on submitted test data and uncertain concern for cardiac sensitization based on 

 Test Data: rat acute oral LD50 >300 and <2000 mg/kg, 4/5 animals 

died at 2000 mg/kg, no deaths at 300 mg/kg, signs of neurotoxicity; rat acute inhalation LC50 

>0.5 g/m3; rat 28-day oral NOEL = 30 mg/kg (M), 100 mg/kg (F), signs of neurotoxicity at 300 

mg/kg in males and females (reduced to 150 mg/kg after 15 days), reduced body weight in males 

at 300 (150) and 100 mg/kg 

 Ecotox:

Test 

Organism

Test 

Type

Test End 

Point

Predicted Measured Comments

fish 96-h LC50 50 0.89

daphnid 48-h LC50 31 >93

green algal 96-h EC50 18 >22

fish _ chronic value 4.7

daphnid _ chronic value 3.2

algal _ chronic value 7.2

Sewage Sludge 3-h EC50 _

Sewage Sludge _ Chronic Value _

Ecotox Values Comments: Predictions are based on SARs for ; 

SAR chemical class = MW 232; 

 pH7; effective concentrations based on 100% active 

ingredients and mean measured concentrations; hardness <180.0 mg/L as CaCO3; and TOC 

<2.0 mg/L;

Ecotoxicity Test Data Results for P-11-0224:

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Three acute ecotoxicity studies were conducted on this PMN (P-11-0224) in 

with fish, daphnia, and algae. 

hat is in 

contrast to the estimated water solubility value and the measured log Kow. The testing 

laboratory measured the PMN during the ecotoxicity studies using a GC-FID (limit of 

quantification = 0.1 mg/L). The testing laboratory performed toxicity tests for the fish, daphnid, 

and algal tests according to OECD guidelines 203, 202 and 201, respectively. All studies 

complied with OECD guidelines for: 1) O2, pH, temperature, water hardness values and other 

water quality parameters; 2) species, age, number of organisms per replicate, and biomass 

loading rates; and, 3) replicate and overall variability.

Medaka (Oryzias latipes) (4 fish/replicate; 2 replicates/concentration of the test material) were 

exposed to nominal concentrations of 0.76, 1.2, 2.0, 3.1, and 5.0 mg/l (and a control) of the PMN 

under semi-static conditions (closed system) for 96 hours. The mean-measured concentrations 

were 0.37, 0.65, 1.0, 1.6 and 2.5 mg/L (and a control). Sub-lethal effects (gasping for air at the 

water surface, lethargy, muscle spasm, and reduced activity) were observed in test 

concentrations of 1.0, 1.6 and 2.5 mg/L. Over the course of the study, water temperature ranged 

from 24.0-24.6°C; pH ranged from 7.4 – 8.0; O2 levels ranged from 7.0-8.7 mg/L and water 

hardness was 44 mg CaCO3/L (in the dilution water). The measured 96-hour LC50 for fish is 

0.89 mg/L. The measured 96-hour NOEC for mortality is 0.65 mg/L. 

In a 48-hour immobilization test, water fleas (Daphnia magna) (5 daphnia/replicate x 4 

replicates) were exposed to nominal concentrations of 18, 29, 47, 75, and 120 mg/l (and a 

control) of the PMN under semi-static conditions (closed system). The mean-measured 

concentrations were 14, 23, 35, 50 and 93 mg/L (and a control). Sub-lethal effects (reduced 

activity) were observed in test concentrations of 35, 50 and 93 mg/L. Over the course of the 

study, water temperature ranged from 20.1-20.2°C; pH ranged from 7.5 – 7.6; O2 levels ranged 

from 8.6-8.7 mg/L and water hardness was 44 mg CaCO3/L (in the dilution water). The 

measured 48-hour EC50 (immobilization) for D. magna is > 93 mg/L. The measured NOEC for 

immobilization is 93 mg/L. 

In a 72-hour limit test for algal growth and inhibition rate, an initial cell concentration of 0.5E+4 

cells/ml (6 replicates/control and test concentration) of green algae (Pseudokirchneriella 

subcapitata) were exposed to nominal concentrations of 100 mg/l (and a control) of the PMN 

under static conditions. The mean-measured concentrations were 0 and 22 mg/L for this limit 

test. The test occurred with continuous light (102-104 μE/m/s) and continuous agitation. The 

temperature ranged from 23.4-23.6°C. The pH ranged from 7.9 – 9.0. Cell growth was 

measured microscopically using a particle counter. The measured 72-hour algal EC50 for 

growth is > 22 mg/L. The measured 72-hour algal NOEC for growth was 22 mg/L.

All three acute ecotoxicity studies are considered valid. Adverse effects were observed in fish 

(lethal and sub-lethal) and daphnid (sub-lethal) tests. No adverse effects were observed in the 

algal test. The measured chronic concern concentration for fish, the most sensitive species of the 

three, is based on the measured 96-hour LC50 for fish (0.89 mg/L). The chronic concern 

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concentration is derived by dividing the 96-hour LC50 for fish by an acute to chronic ratio of 10, 

which is then divided by an uncertainty factor of 10. The chronic concern concentration is 9 

ppb. The acute concern concentration is derived by dividing the 96-hour LC50 for fish by an 

uncertainty factor of 5. The acute concern concentration is 178 ppb. For comparative purposes, 

the chronic and acute concern concentrations for P-11-0224 are 320 ppb and 4500 ppb, 

respectively, based on the ECOSAR-based predictions. As a result of the valid test data, the 

updated chronic and acute concern concentrations are 9 ppb and 178 ppb, respectively.

Ecotox Study Reviewer: J. Gallagher QA/QC: L. Newsome

31 March 2011

Factors Values Comments

Assessment Factor 10

Concentration of Concern 

(ppb)

9

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-11-224 

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INITIAL REVIEW ENGINEERING REPORT 

PMN: 11-0224

Focus Ready Draft 3/17/2011

ENGINEER: Arnold \ JD

PV (kg/yr): 

SUBMITTER: 

USE:

OTHER USES:

MSDS: Label: 

CRSS :

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Consumer Use: No

SAT (concerns) (03/11/2011):

Migration to groundwater: Rapid

PBT rating: P3B1T1 .

Health: 1-2 Dermal, Inhalation

Eco: 2 Water (All releases to water with a CC = 320 ppb.)

OCCUPATIONAL EXPOSURE RATING: 2-3A

NOTES & KEY ASSUMPTIONS:

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

POLLUTION PREVENTION CONSIDERATIONS:

P2 Claims: 

EXPOSURE-BASED REVIEW: 

 

No

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INITIAL REVIEW ENGINEERING REPORT 

PMN: 11-0224

Number of Sites/ Location: 

Days/yr: 

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources

to the same medium.

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OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

 

 

 

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INITIAL REVIEW ENGINEERING REPORT 

PMN: 11-0224

Use: 

Number of Sites/ Location: 

Days/yr: 

Process Description: 

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: 

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OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 

Basis:

MEMORANDUM of CBI TELEPHONE CONVERSATION

CALL BY: 

Organization: 

CALL TO: 

Organization: 

Date: 03/14/2011

Time: 1:30PM

Phone: 

Concerning what ?

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A-003 

Initial Review Exposure Report 

for PMN P-11-224 

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INITIAL REVIEW EXPOSURE REPORT (IRExR) 

 Chemical ID: P-11-0224 Reviewer: Delpire/SS 

 

 

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 7Q104 

CC = 9 

PDM 

Days 

Exceede

d 

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 

Max 

ADR --- --- 1.08E-04 --- 6.22 --- --- 0.11 --- 0.14 --- 

PDM1 --- --- --- --- 6.22 --- --- --- --- --- --- 

PDM2 --- --- --- --- 0.10 --- --- --- --- --- --- 

Max 

LADD --- --- --- 9.38E-07 --- --- 2.23E-03 --- 1.38E-03 --- 3.11E-03 

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. 

4 This column displays concentration values for the 7Q10 streamflow, which is defined as the average daily 

streamflow of the seven consecutive days of lowest flow within a ten year period. 

Results Table: Exposure Based (XB)/Persistent (P2B2) Criteria 

Parameter Exp Based Persistent Exceedance Value 

Drinking (Surface) Water Dose (mg/kg/day) No NA

Fish Ingestion Dose (mg/kg/day) No NA

Inhalation Dose (mg/kg/day) Yes NA 0.14 

Groundwater Dose (mg/kg/day) No NA

Surface Water Release After Treatment (kg/yr) No NA

Total Release After Treatment (kg/yr) Yes NA 1.6E+04 

Consumer Use? No NA 

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INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P-11-0224 Assessor: Delpire/SS 

ENVIRONMENTAL RELEASES 

 Scenario#:1 Number of Release Sites 

 Release Activity: Max ADR 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 0.00 

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

Non-sludge/Sludge 

Release Days/yr: 0.00/0.00 

Per Site Release: 0.00/0.00 

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

Remarks: 

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INITIAL REVIEW EXPOSURE REPORT 

CHEMICAL ID: P-11-0224 

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

LAKES, BAYS, ESTUARIES, AND OCEANS 

SCENARIO #: 1 RELEASE ACTIVITY: Max ADR 

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 

CHRONIC SCENARIO 

FISH INGESTION EXPOSURE ESTIMATES 

ASSUMPTIONS 

Exposure Units Results ED 

(years) 

AT 

(years) 

BW 

(kg) 

IR 

 (g/day) 

Cancer 

LADDpot (mg/kg/day) 9.23E-07 30.00 75.00 71.80 6.00 

LADCpot (mg/kg) 1.10E-02 30.00 75.00 NA NA 

Acute 

ADRpot (mg/kg/day) 1.08E-04 NA 1 day 71.80 129.00 

Comments: 

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INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P-11-0224 

INHALATION EXPOSURE ESTIMATES (POST-TREATMENT) 

SCENARIO #: 1 RELEASE ACTIVITY : Max ADR 

RELEASE DESCRIPTION: 

METHOD OF CALCULATION: Screen3 

EXPOSED POPULATION: Adult 

Number of Sites: 

Per Site Fugitive Release: kg/site/day 

Fugitive Release Days per Year: days 

% Removal via Fugitive Release: 0.00 % 

Total Fugitive Release: kg/yr 

Max Annual Average Air Concentration 

(Fugitive): 

μg/m3

Max 24 Hour Average Air 

Concentration(Fugitive): 

μg/m3

Per Site Stack Release: kg/site/day 

Stack Release Days per Year: days 

% Removal via Stack Release: % 

Total Stack Release: kg/yr 

Max Annual Average Air Concentration (Stack): μg/m3

Max 24 Hour Average Air Concentration (Stack): μg/m3

ASSUMPTIONS 

Exposure Units 

Results 

(Stack) 

Results 

(Fugitive) ED 

(years) 

AT 

(years) 

BW 

(kg) 

Inh. Rate 

(m3/hr) 

Cancer 

LADDpot (mg/kg/day) 2.43E-05 2.08E-03 30.00 75.00 71.80 0.55 

LADCpot (mg/m3) 1.32E-04 1.13E-02 30.00 75.00 NA NA 

Acute 

ADRpot (mg/kg/day) 0.11 0.14 NA 1 day 71.80 0.55 

Inhalation Comments: 

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 Stack Parameter Data Fugitive Parameter Data 

Stack Height 10.00 m Release Height: 3.00 m 

Inside Stack 

Diameter: 

0.10 m Length of Release 

Opening: 

10.00 m 

Stack Gas Exit 

Velocity: 

0.10 m/sec Width of Release 

Opening: 

10.00 m 

Stack Gas 

Temperature: 

293.00 K 

 

 Meteorological and Terrain Information: 

Surrounding Land Use: Rural 

Terrain Height: 0.00 m 

Distance to Residence of Interest: 100.00 m 

Meteorological Class: Full 

Stability Class: NA 

Wind Speed: NA 

 

 Do wnwash Information: 

Facility Length: NA m 

Facility Width: NA m 

Facility Height: NA m 

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INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P-11-0224 Assessor: Delpire/SS 

ENVIRONMENTAL RELEASES 

 Scenario#:2 Number of Release Sites: 

 Release Activity: PDM1 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 0.00 0.00 0.00 

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

Non-sludge/Sludge 

Release Days/yr: 0.00/0.00 0.00 0.00 

Per Site Release: 0.00/0.00 0.00 0.00 

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

Remarks: 

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INITIAL REVIEW EXPOSURE REPORT 

CHEMICAL ID: P-11-0224 

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

LAKES, BAYS, ESTUARIES, AND OCEANS 

SCENARIO #: 2 RELEASE ACTIVITY: PDM1 

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 

CHRONIC SCENARIO 

FISH INGESTION EXPOSURE ESTIMATES 

ASSUMPTIONS 

Exposure Units Results ED 

(years) 

AT 

(years) 

BW 

(kg) 

IR 

 (g/day) 

Cancer 

LADDpot (mg/kg/day) 9.23E-07 30.00 75.00 71.80 6.00 

LADCpot (mg/kg) 1.10E-02 30.00 75.00 NA NA 

Acute 

ADRpot (mg/kg/day) 1.08E-04 NA 1 day 71.80 129.00 

Lakes Comments: 

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INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P-11-0224 Assessor: Delpire/SS 

ENVIRONMENTAL RELEASES 

 Scenario#:3 Number of Release Sites: 

 Release Activity: : PDM2 

 Release Description: WATER LANDFILL 

Non-sludge/Sludge 

STACK FUGITIVE 

Total Releases: 0.00 0.00 0.00 

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

Non-sludge/Sludge 

Release Days/yr: 0.00/0.00 0.00 0.00 

Per Site Release: 0.00/0.00 0.00 0.00 

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

Remarks: 

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INITIAL REVIEW EXPOSURE REPORT 

CHEMICAL ID: P-11-0224 

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

LAKES, BAYS, ESTUARIES, AND OCEANS 

SCENARIO #: 3 RELEASE ACTIVITY: PDM2 

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 

CHRONIC SCENARIO 

FISH INGESTION EXPOSURE ESTIMATES 

ASSUMPTIONS 

Exposure Units Results ED 

(years) 

AT 

(years) 

BW 

(kg) 

IR 

 (g/day) 

Cancer 

LADDpot (mg/kg/day) 2.97E-08 30.00 75.00 71.80 6.00 

LADCpot (mg/kg) 3.56E-04 30.00 75.00 NA NA 

Acute 

ADRpot (mg/kg/day) 1.75E-06 NA 1 day 71.80 129.00 

Lakes Comments: 

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INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P-11-0224 Assessor: Delpire/SS 

ENVIRONMENTAL RELEASES 

 Scenario#:4 Number of Release Sites: 

 Release Activity: Max LADD 

 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: P-11-0224 

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

LAKES, BAYS, ESTUARIES, AND OCEANS 

SCENARIO #: 4 RELEASE ACTIVITY: Max LADD 

FACILITY NAME: 

FACILITY LOCATION: 

RECEIVING WATER NAME: 

REACH NUMBER: 3 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 

CHRONIC SCENARIO 

FISH INGESTION EXPOSURE ESTIMATES 

ASSUMPTIONS 

Exposure Units Results ED 

(years) 

AT 

(years) 

BW 

(kg) 

IR 

 (g/day) 

Cancer 

LADDpot (mg/kg/day) 9.38E-07 30.00 75.00 71.80 6.00 

LADCpot (mg/kg) 1.12E-02 30.00 75.00 NA NA 

Acute 

ADRpot (mg/kg/day) N/A NA 1 day 71.80 129.00 

Lakes Comments: 

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INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P-11-0224 

DRINKING WATER EXPOSURE ESTIMATES FROM LANDFILL RELEASES 

SCENARIO #: 4 ACTIVITY: : Max LADD 

RELEASE DESCRIPTION: 

EXPOSED POPULATION: Adult 

NUMBER 

OF 

SITES 

NON-SLUDGE 

LANDFILL 

RELEASE AND 

DAYS OF 

RELEASE 

(kg/site/day)/(days) 

 LANDFILLED 

SLUDGE1 

AND DAYS OF 

RELEASE 

(kg/site/day)/(days)

MIGRATION 

DESCRIPTOR2

ADSORPTION 

TO 

WASTEWATER 

SLUDGE 

 (%) 

DRINKING 

WATER 

TREATMENT 

 (%) 

 0.00 

 1 Landfilled sludge equals the fraction adsorbed to wastewater treatment sludge times the surface 

 water pre-treatment release.

 

 2 Migration Descriptor Log Koc Groundwater Concentration (GWC) 

 (mg/L per kg release)

 Negl igible no migration None 

Negligible to slow > 4.5 3.21E-6 

Slow <4. 5 to 3.5 2.67E-5 

Moderate <3.5 to 2.5 5.95E-5 

Rapid <2. 5 7. 55E-5 

 

ASSUMPTIONS 

 Exposure Units Results ED 

(years) 

AT 

(years) 

BW 

(kg) 

IR 

 (L/day) 

Cancer 

LADDpot (mg/kg/day) 2.23E-03 30.00 75.00 71.80 1.40 

LADCpot (mg/L) 0.11 30.00 75.00 NA NA 

REMARKS: 

 

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INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P-11-0224 

INHALATION EXPOSURE ESTIMATES (POST-TREATMENT) 

SCENARIO #: 4 RELEASE ACTIVITY Max LADD 

RELEASE DESCRIPTION: 

METHOD OF CALCULATION: Screen3 

EXPOSED POPULATION: Adult 

Number of Sites: 

Per Site Fugitive Release: kg/site/day 

Fugitive Release Days per Year: days 

% Removal via Fugitive Release: 0.00 % 

Total Fugitive Release: kg/yr 

Max Annual Average Air Concentration 

(Fugitive): 

μg/m3

Max 24 Hour Average Air 

Concentration(Fugitive): 

N/A μg/m3

Per Site Stack Release: kg/site/day 

Stack Release Days per Year: days 

% Removal via Stack Release: % 

Total Stack Release: kg/yr 

Max Annual Average Air Concentration (Stack): μg/m3

Max 24 Hour Average Air Concentration (Stack): N/A μg/m3

ASSUMPTIONS 

Exposure Units 

Results 

(Stack) 

Results 

(Fugitive) ED 

(years) 

AT 

(years) 

BW 

(kg) 

Inh. Rate 

(m3/hr) 

Cancer 

LADDpot (mg/kg/day) 1.38E-03 3.11E-03 30.00 75.00 71.80 0.55 

LADCpot (mg/m3) 7.48E-03 1.69E-02 30.00 75.00 NA NA 

Acute 

ADRpot (mg/kg/day) N/A N/A NA 1 day 71.80 0.55 

Inhalation Comments: 

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4/4/11 page of 

 Stack Parameter Data Fugitive Parameter Data 

Stack Height 10.00 m Release Height: 3.00 m 

Inside Stack 

Diameter: 

0.10 m Length of Release 

Opening: 

10.00 m 

Stack Gas Exit 

Velocity: 

0.10 m/sec Width of Release 

Opening: 

10.00 m 

Stack Gas 

Temperature: 

293.00 K 

 

 Meteorological and Terrain Information: 

Surrounding Land Use: Rural 

Terrain Height: 0.00 m 

Distance to Residence of Interest: 100.00 m 

Meteorological Class: Full 

Stability Class: NA 

Wind Speed: NA 

 

 Do wnwash Information: 

Facility Length: NA m 

Facility Width: NA m 

Facility Height: NA m 

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A-004 

TSCA Section 5(e) Consent Order and Determinations 

Supporting Consent Order for PMN P-11-224 

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