# Support Documents for Significant New Use Rules (SNUR) on Premanufacture Notice (PMN)

P-11-224

EPA Docket EPA-HQ-OPPT-2011-0942

# 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

# A-001 Structure Activity Team (SAT) Report
for PMN P-11-224

## 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: N EURO; 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)

### 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; p H7; 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:

### 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, p H, 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; p H ranged fro m 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; p H ranged fro m 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. N o 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

### 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 p pb. 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 p pb. For comparative purposes, the chronic and acute concern concentrations for P-11-0224 are 320 p pb an d 4500 p pb, respectively, based on the ECOSAR-based predictions. As a result of the valid test data, the updated chronic and acute concern concentrations are 9 p pb an d 178 p pb, respectively.

Ecotox Study Reviewer: J. Gallagher QA/QC: L. N ewsome 31 March 2011

Factors Values Comments Assessment Factor 10 Concentration of Concern ( p pb) 9

SARs SAR Class

Ecotox Factors Comments:

SAT Chair: L Keifer 564-8916

# A-002 Initial Review Engineering Report
for PMN P-11-224

### 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 :

### 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

### 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.

### OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

### INITIAL REVIEW ENGINEERING REPORT PMN: 11-0224

Use:

Number of Sites/ Location:
Days/yr:

Process Description:

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY IRER Note:

### 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 ?

# A-003 Initial Review Exposure Report
for PMN P-11-224

### INITIAL REVIEW EXPOSURE REPORT (IRExR)
Chemical ID: P-11-0224 Reviewer: Delpire/SS

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

Exposure Scenario 1 Water Landfill Stack Air Fugitive Air Drinking Water Fish Ingestion
ADR LADD ADR LADD 7Q10 4
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 Manuf acturing (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 (A DR), Lifetime Average Daily Dose (LADD), and Probabilistic Dilution Model (PDM). Th ere 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 7Q 10 streamflow, which is defined as the average daily streamflow of the seven consecutive days of lowest flow within a ten year period.

Resul ts Table: Exposure Based (XB)/Persistent (P2B2) Criteria

Parameter Exp Based Persistent Exceedance Value Drinking (Surface) Wate r 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 NAINITIAL REV I EW EX POSURE 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:INITIAL REV IEW EX POSURE 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 LADD pot (mg/kg/day) 9.23E-07 30.00 75.00 71.80 6.00

LADC pot (mg/kg) 1.10E-02 30.00 75.00 NA NA Acute ADR pot (mg/kg/day) 1.08E-04 NA 1 day 71.80 129.00 Comments:INITIAL REV I EW EX POSURE REPORT Chemical ID: P-11-0224

INHALATION EXPOSURE ESTIMATES (POST-TREATMENT)

SCENARIO #: 1 RELEASE AC TIVITY : Max ADR

RELEASE DESCRIPTION:

METHOD OF CALCULATION: Screen3

EXPOSED POPULATION: Adult

Number of Sites:
Per Site Fugitive Release: kg/site/d ay Fugitive Release Days per Year: days

% Remov al via Fugitive Release: 0.00 % Total Fugitive Release: kg/yr
Max Annual Average Air Concentration (Fugitive): μg/m 3

Max 24 Hour Average Air Concentration(Fugitive): μg/m 3

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 Con centration (Stack): μg/m 3
Max 24 Hour Average Air Concentration (Stack): μg/m 3

ASSUMPTIONS
Exposure Units Results (Stack) Results (Fugitive) ED (years) AT (years) BW (kg) Inh. Rate (m 3 /hr)

Cancer

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

LADC pot (mg/m 3 ) 1.32E-04 1.13E-02 30.00 75.00 NA NA

Acute

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

Inhalation Comments:Stack Param eter 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 mINITIAL REV IEW EX POSURE 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:INITIAL REV I EW EX POSURE 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 LADD pot (mg/kg/day) 9.23E-07 30.00 75.00 71.80 6.00

LADC pot (mg/kg) 1.10E-02 30.00 75.00 NA NA Acute ADR pot (mg/kg/day) 1.08E-04 NA 1 day 71.80 129.00 Lakes Comments:INITIAL REV IEW EX POSURE 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:INITIAL REV IEW EX POSURE 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 LADD pot (mg/kg/day) 2.97E-08 30.00 75.00 71.80 6.00

LADC pot (mg/kg) 3.56E-04 30.00 75.00 NA NA Acute ADR pot (mg/kg/day) 1.75E-06 NA 1 day 71.80 129.00 Lakes Comments:INITIAL REV IEW EX POSURE 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:INITIAL REV IEW EX POSURE 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 LADD pot (mg/kg/day) 9.38E-07 30.00 75.00 71.80 6.00

LADC pot (mg/kg) 1.12E-02 30.00 75.00 NA NA Acute ADR pot (mg/kg/day) N/A NA 1 day 71.80 129.00 Lakes Comments:INITIAL REV IEW EX POSURE 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 SLUDGE 1 AND DAYS OF RELEASE (kg/site/day)/(days) MIGRATION DESCRIPTOR 2 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
LADD pot (mg/kg/day) 2.23E-03 30.00 75.00 71.80 1.40
LADC pot (mg/L) 0.11 30.00 75.00 NA NA

REMARKS:INITIAL REV I EW EX POSURE 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/d ay Fugitive Release Days per Year: days

% Remov al via Fugitive Release: 0.00 % Total Fugitive Release: kg/yr
Max Annual Average Air Concentration (Fugitive): μg/m 3

Max 24 Hour Average Air Concentration(Fugitive): N/A μg/m 3

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 Concen tration (Stack): μg/m 3
Max 24 Hour Average Air Concentration (Stack): N/A μg/m 3

ASSUMPTIONS
Exposure Units Results (Stack) Results (Fugitive) ED (years) AT (years) BW (kg) Inh. Rate (m 3 /hr)

Cancer

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

LADC pot (mg/m 3 ) 7.48E-03 1.69E-02 30.00 75.00 NA NA

Acute

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

Inhalation Comments: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

# A-004 TSCA Section 5(e) Consent Order and Determinations Supporting Consent Order for PMN P-11-224