Support Documents for 

Significant New Use Rules (SNURs) on 

Premanufacture Notices (PMNs) 

P-09-146 and P-09-147 

EPA Docket EPA-HQ-OPPT-2010-1075 

 

EPA SANITIZED Page 1 of 68
Index

A-001 Structure Activity Team (SAT) Reports for 

PMNs P-09-146 and P-09-147 

A-002 Initial Review Engineering Reports for 

PMNs P-09-146 and P-09-147 

A-003 Initial Review Exposure Reports for 

PMNs P-09-146 and P-09-147 

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

Determinations Supporting Consent Order for 

PMNs P-09-146 and P-09-147 

EPA SANITIZED Page 2 of 68
A-001 

Structure Activity Team (SAT) Reports 

 for PMNs P-09-146 and P-09-147 

 

EPA SANITIZED Page 3 of 68
SAT Report

PMN Number: P-09-0146

SAT Date: 1/16/2009

Related cases:

Health related cases: 

Ecotox related cases: 

Concern levels:

Type of Concern: Health Eco Comments

Level of Concern: 2-3 3 Health: ; Eco: chronic only

 Persistence Bioaccum Toxicity Comments

 3 1 1

Exposure Based Review:

Health: Yes Exposure based testing (health): Generation of 

Ecotox: Yes

Routes of exposure: Health: Dermal, inhalation

Ecotox: All releases to water

Fate: ;

Keywords:

 Keywords: CORR-E,S,MM,L; SENS (UNCERT); AQUATOX

Summary of Assessment:

 Fate:

Fate Summary: P-09-0146-47

FATE: MW = 933 with 2% < 500 and 74.7% < 1000

Solid 

S > 10 g/L at 25 C (E) 

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

BP > 400 EC (E)

H < 1.00E-8 (E)

POTW removal (%) = 90 via sorption

Time for complete ultimate aerobic biodeg = mo

Sorption to soils/sediments = v.strong

PBT Potential: P3B1

*CEB FATE: Migration to ground water = negl

 Health:

EPA SANITIZED Page 4 of 68
 Health Summary: Not absorbed from the skin, absorbed from the lung 

(pchem), low molecular weight fractions poorly absorbed from the GI tract (pchem). Concern 

for corrosion to all tissues based on the pH of the materials (146: pH = 10 - 11; 147: pH = 11 - 

12). Uncertain concern for sensitization based on low molecular weight 

 Ecotox:

Test 

Organism

Test 

Type

Test End 

Point

Predicted Measured Comments

fish 96-h LC50 *

daphnid 48-h LC50 *

green algal 96-h EC50 *

fish _ chronic value 0.032

daphnid _ chronic value 0.003

algal _ chronic value *

Sewage Sludge 3-h EC50 _

Sewage Sludge Chronic Value

Ecotox Values Comments: Predictions are based on SARs for 

; SAR chemical class = ; log Kow = 7.76 

(EPI, a=2, mw=937); MW 933 with 74.7% < 1000 and 2% < 500; 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;

Factors Values Comments

Assessment Factor 10

Concentration of Concern 

(ppb)

1

SARs

SAR Class

Ecotox Factors Comments: 

 SAT Chair: L Keifer 564-8916

EPA SANITIZED Page 5 of 68
SAT Report

PMN Number: P-09-0147

SAT Date: 1/16/2009

Related cases:

Health related cases: 

Ecotox related cases: 

Concern levels:

Type of Concern: Health Eco Comments

Level of Concern: 2-3 1

 Persistence Bioaccum Toxicity Comments

3 11

Exposure Based Review:

Health: Yes Exposure based testing (health): Generation of 

Ecotox: No

Routes of exposure: Health: Dermal, inhalation

Ecotox: No releases to water

Fate: ;

Keywords:

 Keywords: CORR-E,S,MM,L; SENS (UNCERT)

Summary of Assessment:

 Fate:

Fate Summary: P-09-0146-47

FATE: MW = 933 with 2% < 500 and 74.7% < 1000

Solid 

S > 10 g/L at 25 C (E) 

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

BP > 400 EC (E)

H < 1.00E-8 (E)

POTW removal (%) = 90 via sorption

Time for complete ultimate aerobic biodeg = mo

Sorption to soils/sediments = v.strong

PBT Potential: P3B1

EPA SANITIZED Page 6 of 68
*CEB FATE: Migration to ground water = negl

 Health:

 Health Summary: Not absorbed from the skin, absorbed from the lung 

(pchem), low molecular weight fractions poorly absorbed from the GI tract (pchem). Concern 

for corrosion to all tissues based on the pH of the materials (146: pH = 10 - 11; 147: pH = 11 - 

12). Uncertain concern for sensitization based on low molecular weight 

 Ecotox:

Test 

Organism

Test 

Type

Test End 

Point

Predicted Measured Comments

fish 96-h LC50 *

daphnid 48-h LC50 *

green algal 96-h EC50 *

fish _ chronic value *

daphnid chronic value *

algal _ chronic value *

Sewage Sludge 3-h EC50

Sewage Sludge _ Chronic Value _

Ecotox Values Comments: Predictions are based on SARs for 

; SAR chemical class = mw>1000; MW 

1636 with 22.3% < 1000 and 1.9% < 500; 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;

Factors Values Comments

Assessment Factor 10

Concentration of Concern 

(ppb)

*

SARs

SAR Class

Ecotox Factors Comments: 

 SAT Chair: L Keifer 564-8916

EPA SANITIZED Page 7 of 68
A-002 

Initial Review Engineering Reports 

for PMNs P-09-146 and P-09-147 

 

EPA SANITIZED Page 8 of 68
INITIAL REVIEW ENGINEERING REPORT

P-09-0146

Focus Ready Draft 2/5/2009

ENGINEER: Austin \ CPW/AH

PV (kg/yr): 

Revision Notes/Assessment Overview:

SUBMITTER:

USE:

OTHER USES:

MSDS: LABEL: 

Gen Eqpt:

Respirator:

Health Effects:

TLV/PEL: 

CRSS: 

Chemical Name: 

S-H2O: g/L @ 

VP: torr @ 

MW: %<500 %<1000

Physical State and Misc CRSS Info:

Neat: Mfg: 

Proc/Form End Use:

Consumer Use

SAT (concerns):

Migration to groundwater:

PBT rating:

Health:

Eco:

OCCUPATIONAL EXPOSURE RATING:

EPA SANITIZED Page 9 of 68
NOTES & KEY ASSUMPTIONS:

Generated by the 06/07/2005 version of ChemSTEER

POLLUTION PREVENTION CONSIDERATIONS:

P2 REC:

 

 

EPA SANITIZED Page 10 of 68
P-09-0146

 

 

EPA SANITIZED Page 11 of 68
.

EPA SANITIZED Page 12 of 68
P-09-0146

.

EPA SANITIZED Page 13 of 68
INITIAL REVIEW ENGINEERING REPORT

P-09-0147

Focus Ready Draft 2/5/2009

ENGINEER: Austin \ CPW/AH

PV (kg/yr): 

Revision Notes/Assessment Overview:

SUBMITTER:

USE:

OTHER USES:

MSDS: Yes LABEL: No

Gen Eqpt:

Respirator:

Health Effects:

TLV/PEL: - 

CRSS: 

Chemical Name: 

salts

S-H2O: 430 g/L @ 

VP: 1.0E-6 torr @ 

MW: 1686 1.9%<500 22.3%<1000

Physical State and Misc CRSS Info:

 

 

Consumer Use: No

SAT (concerns): (1/16/2009):

Migration to groundwater: Negligible

PBT rating: P3 B1 T1

Health: 2-3, Dermal, Inhalation, 

Eco: 1, No releases to Water 

EPA SANITIZED Page 14 of 68
OCCUPATIONAL EXPOSURE RATING: 2-3B

NOTES & KEY ASSUMPTIONS:

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

POLLUTION PREVENTION CONSIDERATIONS:

P2 REC:

 

 

 

EPA SANITIZED Page 15 of 68
P-09-0147

Manufacturing

Number of Sites/Location: 1 submitter site(s) 

Basis: 

Process Description:

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

RELEASE TOTAL

 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 3

Basis:

Dermal:

Exposure to Liquid 

High End: 2.5E+2 mg/day over 130 days/yr

Number of workers (all sites) with Dermal exposure: 3

Basis: 

EPA SANITIZED Page 16 of 68
P-09-0147

Use: 

Number of Sites/Location: 1 submitter site(s) 

 

Basis:

Process Description:

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

Water or Incineration

High End: 8.7E+2 kg/site-day over 1 day/yr from 1 sites or 8.7E+2 kg/yr

to: 

from: 

basis: 

Incineration

Conservative: 4.8E+2 kg/site-day over 250 day/yr from 1 sites or 1.2E+5 kg/yr

to: burned on site as fuel or waste (amendment)

from: 

basis:

RELEASE TOTAL

1.2E+5 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 22

Basis:

Dermal:

Exposure to Solid 

High End: 8.7E+2 mg/day over 250 days/yr

EPA SANITIZED Page 17 of 68
Number of workers (all sites) with Dermal exposure: 1

Basis:

Dermal:

Exposure to Liquid 

High End: 4.9E+2 mg/day over 250 days/yr

Number of workers (all sites) with Dermal exposure: 3

Basis: 

Inhalation:

negligible (VP < 0.001 torr)

Exposure to Particulate 

Upper Bound: 6.4E+1 mg/day over 250 days/yr

Number of workers (all sites) with Inhalation exposure: 18

Basis: 

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit, or data not specific to industry): Yes

2) (a) Exposure level > 1 mg/day? Yes

 (b) Hazard Rating for health of 2 or greater? No

Inhalation Monitoring Data Desired? No

EPA SANITIZED Page 18 of 68
A-003 

Initial Review Exposure Reports 

for PMNs P-09-146 and P-09-147 

 

EPA SANITIZED Page 19 of 68
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INITIAL REVIEW EXPOSURE REPORT (IRExR) 

 Chemical ID: P090146 Reviewer: Flessner 

 

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=1 

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 

USE: max acute eco, 

max ADR (stack and 

dw/ing.), and LADD 

(dw/ing. Only) 

2.46 1.1.E-04 --- --- 5.38E+04 --- --- 9.91E-04 --- --- --- 

USE: max LADD 

(stack) --- --- --- --- --- --- --- --- 1.57E-05 --- --- 

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: 

Fate test recommendations?: (default is NA) 

EPA SANITIZED Page 20 of 68
2/4/09 Page of 

 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P090146 Assessor: Flessner 

ENVIRONMENTAL RELEASES 

 Scenario#:1 Number of Release Sites: 1. 

 

 

 

 

 

 

EPA SANITIZED Page 21 of 68
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INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P090146 

SIC-CODE BASED HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

 

 

 

 

Comments: 

EPA SANITIZED Page 22 of 68
2/4/09 Page of 

INITIAL EXPOSURE REVIEW REPORT 

Chemical ID: P090146 

INHALATION EXPOSURE ESTIMATES (POST-TREATMENT) 

SCENARIO #: 1 RELEASE ACTIVITY:USE: max acute eco, max ADR (stack and 

dw/ing.), and LADD (dw/ing. Only) 

RELEASE DESCRIPTION: 

METHOD OF CALCULATION: Screen3 

EXPOSED POPULATION: Adult 

Number of Sites: 1. 

Per Site Fugitive Release: NA kg/site/day 

Fugitive Release Days per Year: NA days 

% Removal via Fugitive Release: 0.00 % 

Total Fugitive Release: NA kg/yr 

Max Annual Average Air Concentration 

(Fugitive): 

0.00 μg/m3

Max 24 Hour Average Air 

Concentration(Fugitive): 

0.00 μg/m3

Per Site Stack Release: 800.00 kg/site/day 

Stack Release Days per Year: 1.00 days 

% Removal via Stack Release: 99.90 % 

Total Stack Release: 800.00 kg/yr 

Max Annual Average Air Concentration (Stack): 2.95E-03 μg/m3

Max 24 Hour Average Air Concentration (Stack): 5.39 μg/m3

ASSUMPTIONS 

Exposure Units 

Results 

(Stack) 

Results 

(Fugitive) ED 

(years) 

AT 

(years) 

BW 

(kg) 

Inh. Rate 

(m3/hr) 

Cancer 

LADDpot (mg/kg/day) 2.17E-07 N/A 30.00 75.00 71.80 0.55 

LADCpot (mg/m3) 1.18E-06 N/A 30.00 75.00 NA NA 

Acute 

ADRpot (mg/kg/day) 9.91E-04 N/A NA 1 day 71.80 0.55 

EPA SANITIZED Page 23 of 68
2/4/09 Page of 

Inhalation Comments: 

 Stack Parameter Data Fugitive Parameter Data 

Stack Height 10.00 m Release Height: N/A 

Inside Stack 

Diameter: 

0.10 m Length of Release 

Opening: 

N/A 

Stack Gas Exit 

Velocity: 

0.10 m/sec Width of Release 

Opening: 

N/A 

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 

 

 Downwash Information: 

Facility Length: NA m 

Facility Width: NA m 

Facility Height: NA m 

EPA SANITIZED Page 24 of 68
2/4/09 Page of 

 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P090146 Assessor: 

ENVIRONMENTAL RELEASES 

 

 

 

 

EPA SANITIZED Page 25 of 68
2/4/09 Page of 

INITIAL EXPOSURE REVIEW REPORT 

Chemical ID: P090146 

INHALATION EXPOSURE ESTIMATES (POST-TREATMENT) 

SCENARIO #: 2 RELEASE ACTIVITY:USE: max LADD (stack) 

RELEASE DESCRIPTION: 

METHOD OF CALCULATION: Screen3 

EXPOSED POPULATION: Adult 

Number of Sites: 1. 

Per Site Fugitive Release: NA kg/site/day 

Fugitive Release Days per Year: NA days 

% Removal via Fugitive Release: 0.00 % 

Total Fugitive Release: NA kg/yr 

Max Annual Average Air Concentration 

(Fugitive): 

0.00 μg/m3

Max 24 Hour Average Air 

Concentration(Fugitive): 

0.00 μg/m3

Per Site Stack Release: 5.81E+04 kg/site/day 

Stack Release Days per Year: 1.00 days 

% Removal via Stack Release: 99.90 % 

Total Stack Release: 5.81E+04 kg/yr 

Max Annual Average Air Concentration (Stack): 0.21 μg/m3

Max 24 Hour Average Air Concentration (Stack): 

ASSUMPTIONS 

Exposure Units 

Results 

(Stack) 

Results 

(Fugitive) ED 

(years) 

AT 

(years) 

BW 

(kg) 

Inh. Rate 

(m3/hr) 

Cancer 

LADDpot (mg/kg/day) 1.57E-05 N/A 30.00 75.00 71.80 0.55 

LADCpot (mg/m3) 8.56E-05 N/A 30.00 75.00 NA NA 

Acute 

ADRpot (mg/kg/day) 

Inhalation Comments: 

EPA SANITIZED Page 26 of 68
2/4/09 Page of 

 Stack Parameter Data Fugitive Parameter Data 

Stack Height 10.00 m Release Height: N/A 

Inside Stack 

Diameter: 

0.10 m Length of Release 

Opening: 

N/A 

Stack Gas Exit 

Velocity: 

0.10 m/sec Width of Release 

Opening: 

N/A 

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 

 

 Downwash Information: 

Facility Length: NA m 

Facility Width: NA m 

Facility Height: NA m 

EPA SANITIZED Page 27 of 68
2/4/09 Page of 

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. 

EPA SANITIZED Page 28 of 68
2/4/09 Page of 

INITIAL REVIEW EXPOSURE REPORT (IRExR) 

 Chemical ID: P090147 Reviewer: Flessner 

 

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=n/a 

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 

max ADR, 

LADD (dw/ing. only) 3.75 1.67E-04 --- --- 8.21E+04 --- --- 1.67E-03 --- --- --- 

max LADD 

(stack) --- --- --- --- --- --- --- --- 3.28E-05 --- --- 

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: 

Fate test recommendations?: (default is NA) 

EPA SANITIZED Page 29 of 68
2/4/09 Page of 

 

 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P090147 Assessor: Flessner 

ENVIRONMENTAL RELEASES 

 Scenario#:1 Number of Release Sites: 

 Release Activity: max ADR, LADD (dw/ing. only) 

 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: 

EPA SANITIZED Page 30 of 68
2/4/09 Page of 

INITIAL REVIEW EXPOSURE REPORT 

 Chemical ID: P090147 

SIC-CODE BASED HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES 

SCENARIO #: 1 Number of Sites: RELEASE ACTIVITY max 

ADR, LADD (dw/ing. only) 

SIC-CODE DESCRIPTION: POTW's (All facilities) 

SIC-CODE (S): 4952 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 

PLANT 

TYPE 

% ILE 

FACILITY 

STREAM FLOW (MLD) STREAM CONC. (μg/l) 

Harmonic 

Mean 30Q5 7Q10 1Q10 

Harmonic 

Mean 30Q5 7Q10 1Q10 

ALL 50 125.56 44.02 26.80 22.53 692.90 1976.37 3246.27 3861.52 

ALL 10 11.11 1.94 1.06 0.96 7830.78 4.48E+04 8.21E+04 9.06E+04

DRINKING WATER AND FISH INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water Results Drinking 

Water Units Fish Ingestion Results 

Fish 

Ingestion 

Units 

50% 10% 50% 10% 

Cancer 

LADDpot 1.48E-05 1.67E-04 mg/kg/day 0.00 0.00 mg/kg/day 

LADCpot 7.59E-04 8.58E-03 mg/L 0.00 0.00 mg/kg 

Acute 

ADRpot 0.17 3.75 mg/kg/day 0.00 0.00 mg/kg/day 

SIC Code Comments: 

EPA SANITIZED Page 31 of 68
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INITIAL EXPOSURE REVIEW REPORT 

Chemical ID: P090147 

INHALATION EXPOSURE ESTIMATES (POST-TREATMENT) 

SCENARIO #: 1 RELEASE ACTIVITY max ADR, LADD (dw/ing. only) 

RELEASE DESCRIPTION: 

METHOD OF CALCULATION: Screen3 

EXPOSED POPULATION: Adult 

Number of Sites: 

Per Site Fugitive Release: NA kg/site/day 

Fugitive Release Days per Year: NA days 

% Removal via Fugitive Release: 0.00 % 

Total Fugitive Release: NA kg/yr 

Max Annual Average Air Concentration 

(Fugitive): 

0.00 μg/m3

Max 24 Hour Average Air 

Concentration(Fugitive): 

0.00 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): 4.98E-03 μg/m3

Max 24 Hour Average Air Concentration (Stack): 9.09 μg/m3

ASSUMPTIONS 

Exposure Units 

Results 

(Stack) 

Results 

(Fugitive) ED 

(years) 

AT 

(years) 

BW 

(kg) 

Inh. Rate 

(m3/hr) 

Cancer 

LADDpot (mg/kg/day) 3.66E-07 N/A 30.00 75.00 71.80 0.55 

LADCpot (mg/m3) 1.99E-06 N/A 30.00 75.00 NA NA 

Acute 

ADRpot (mg/kg/day) 1.67E-03 N/A NA 1 day 71.80 0.55 

Inhalation Comments: 

EPA SANITIZED Page 32 of 68
2/4/09 Page of 

 Stack Parameter Data Fugitive Parameter Data 

Stack Height 10.00 m Release Height: N/A 

Inside Stack 

Diameter: 

0.10 m Length of Release 

Opening: 

N/A 

Stack Gas Exit 

Velocity: 

0.10 m/sec Width of Release 

Opening: 

N/A 

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 

 

 Downwash Information: 

Facility Length: NA m 

Facility Width: NA m 

Facility Height: NA m 

EPA SANITIZED Page 33 of 68
2/4/09 Page of 

 INITIAL REVIEW EXPOSURE REPORT 

Chemical ID: P090147 Assessor: 

ENVIRONMENTAL RELEASES 

 Scenario#:2 Number of Release Sites: 

 Release Activity: max LADD (stack) 

 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: 

EPA SANITIZED Page 34 of 68
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INITIAL EXPOSURE REVIEW REPORT 

Chemical ID: P090147 

INHALATION EXPOSURE ESTIMATES (POST-TREATMENT) 

SCENARIO #: 2 RELEASE ACTIVITY max LADD (stack) 

RELEASE DESCRIPTION: 

METHOD OF CALCULATION: Screen3 

EXPOSED POPULATION: Adult 

Number of Sites: 

Per Site Fugitive Release: NA kg/site/day 

Fugitive Release Days per Year: NA days 

% Removal via Fugitive Release: 0.00 % 

Total Fugitive Release: NA kg/yr 

Max Annual Average Air Concentration 

(Fugitive): 

0.00 μg/m3

Max 24 Hour Average Air 

Concentration(Fugitive): 

0.00 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): 0.45 μg/m3

Max 24 Hour Average Air Concentration (Stack): 

ASSUMPTIONS 

Exposure Units 

Results 

(Stack) 

Results 

(Fugitive) ED 

(years) 

AT 

(years) 

BW 

(kg) 

Inh. Rate 

(m3/hr) 

Cancer 

LADDpot (mg/kg/day) 3.28E-05 N/A 30.00 75.00 71.80 0.55 

LADCpot (mg/m3) 1.78E-04 N/A 30.00 75.00 NA NA 

Acute 

ADRpot (mg/kg/day) 

Inhalation Comments: 

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 Stack Parameter Data Fugitive Parameter Data 

Stack Height 10.00 m Release Height: N/A 

Inside Stack 

Diameter: 

0.10 m Length of Release 

Opening: 

N/A 

Stack Gas Exit 

Velocity: 

0.10 m/sec Width of Release 

Opening: 

N/A 

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 

 

 Downwash Information: 

Facility Length: NA m 

Facility Width: NA m 

Facility Height: NA m 

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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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A-004 

TSCA Section 5(e) Consent Order

and Determinations Supporting Consent Order

for PMNs P-09-146 and P-09-147

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