# Support Documents for

Significant New Use Rule (SNUR) on

Premanufacture Notice (PMN)

P-10-285

EPA Docket EPA

- HQ

- OPPT -2011-0577

# Index

A-001 Structure Ac tivity Team (SAT) Report for

PMN P-10-285

A-002 Initial Review Engineering Report for

PMN P-10-285

A-003 Initial Review Exposure Report for

PMN P-10-285

# A-001

Structure Activity Team (SAT) Report

for PMN P-10-285

# A-002

Initial Review Engineering Report

for PMN P-10-285Support - P-10-0285 engineering.3.txt

INITIAL REVIEW ENGINEERING REPORT PMN: 10-0285 Post-Focus Draft Revision 3 7/14/2010

ENGINEER: El-Zoobi \ CLM\JAS\DDH PV (kg/yr): 77,000

Revision Notes / Assessment Overview: IRER was updated on 4/7/10 based on information from technical contact- see contact report. =====> Rev. (1): Manufacturing: media of release for release from premix and release from dryer changed from water to incineration PMN page correction sent by submitter to dated 5/6/10.=====>Rev.(2): as per telephone conversation with , submitter, under a non 5 e SNUR, will release to incineration or deep well injection all releases assessed to water. =====>Rev. (3): as per fax from submitter dated 7/13/10, releases from dusting currently released to water will be sent to incineration or deep well injection. Hence, the release assessment was changed accordingly.

SUBMITTER: Syngenta Crop Protection, Inc.

USE: Chemical intermediate to prepare the fungicide Acibenzolar [CASRN 126448-41-7]. Synthetic sequence: P-10-285

.

OTHER USES:

MSDS: Yes Label: No

Gen Eqpt: Dust-proof chemical goggles. Chemical resistant (nitrile or butyl) gloves, coveralls, socks and chemical-resistant footwear. Respirator: Combination particulate/organic vapor respirator should be used until effective engineering controls are installed to comply with OELs, or until exposure limits are established. Use a NIOSH certified respirator with an organic vapor cartrdige or canister with any R, P, or HE filter. Health Effects: May be harmful if inhaled or swallowed. May be irritating to eyes, respiratory tract and skin. TLV/PEL: none established

CRSS :Chemical Name: Benzoic acid, 3-amino-2-mercaptoS-H20: 4.74 g/L @ VP: 2.7E-5 torr @ MW: 169.00 %<500 %<1000 Physical State and Misc CRSS Info: Neat: Solid Mfg: Solid Proc/Form: NA End Use: Destroyed. Submitted Data: Solid; BP = 337°C (640°F) at 760 torr; density = 1.387 g/cm3; flash point = 154°C (306°F). Estimated Data (NOMO5 with BP entered as 337°C at 760 Page 1Support - P-10-0285 engineering.3.txt torr): VP = 0.000027 torr.Estimated Data (EPI with BP entered as 337°C at 760 torr): WS = 4.744 g/L; log P = 1. 31; BP = 349.70°C; VP = 0.0000272 torr. Estimated Data (STN/ACD Labs): WS = 2.2 g/L; log P = 1.468; BP = 369.7°C; VP = 4.05E-06 torr. The submitter clarified by phone that this PMN is the third in a 3-step synthesis to prepare the fungicide Acibenzolar. He also clarified that there is a final acidification step with hydrochloric acid to yield the PMN substance in the acid form (see phone log). Cont'd on p.6.

Consumer Use: No

SAT (concerns) (03/26/2010): Related Cases and Related Cases and Misc SAT Info:

Migration to groundwater: Moderate PBT rating: P1B1T2 - Health: 1-2 Dermal, Drinking Water, Inhalation Eco: 3 Water (All releases to water with a CC = 5 ppb)

OCCUPATIONAL EXPOSURE RATING: 2-3A

NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER. This PMN is within a series of reaction intermediates:

current PMN . Both and were previously separately assessed. Changes to this assessment may affect related assessments. // This PMN is a site-limited chemical intermediate. submitter was contacted for additional information -- see Contact Reports. This IRER presents releases to incineration during mfg and use, per submission (consistent with and which are also manufactured and used at the same site as this PMN). This IRER aslo presents releases to water based on discussions with the technical contact (see Contact Reports). This IRER presents dermal exposure to solid PMN; inhalation exposure to solid particulate was assessed.

POLLUTION PREVENTION CONSIDERATIONS:
None.

EXPOSURE-BASED REVIEW: No

INITIAL REVIEW ENGINEERING REPORT PMN: 10-0285

Manufacturing

Number of Sites/ Location: 1 Albemarle Fine Chemistry Services Tyrone PA 16686 Days/yr: 80 Basis: Submission specifies 80 bt/yr, 24 hr/bt, 986 kg/bt, 100% PMN as manufactured. ChemSTEER calculates 963 kg/bt.

Process Description: Raw materials charged to reactor --> Series of reactions with additional materials --> PMN formed (liquid, 13.7%) --> Product is filtered and dried (solid powder, 100%) --> Assume intermediate storage in drums. (Submission) Page 2Support - P-10-0285 engineering.3.txt

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY Submission specifies all releases that are not reused/recycled (including solvents, PPE, filter cloths) are sent to incineration. Note, incineration releases total <28,000 kg/site-day.

Air or Incineration Output 2: 4.8E+0 kg/site-day over 80 days/yr from 1 site or 3.8E+2 kg/yr to: uncertain from: Loading Solid Product into Transport Containers basis: User-Defined Loss Rate Model. EPA/OPPT Generic Model to Estimate Dust Releases from Transfer/Unloading Operations of Solid Powders (Nov 2006) estimates 0.5% PV released to water, incineration, air or land.

Incineration Conservative: 1.9E+1 kg/site-day over 80 days/yr from 1 site or 1.5E+3 kg/yr to: incineration (submission) from: Equipment Cleaning Losses of Liquids from Multiple Vessels basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual. Submission specifies all releases that are not reused/recycled (including solvents, PPE, filter cloths) are sent to incineration.

Incineration Output 2: 4.6E+0 kg/site-day over 80 days/yr from 1 site or 3.6E+2 kg/yr to: WWTP (technical contact) from: Water release from Premix Step basis: EPA/OPPT Water Saturation Loss Model. The technical contact indicated that PMN would be present in the waste stream from the premix step to biological treatment (>99.99% DVE). CEB conservatively assesses the water saturation loss model.

Incineration Output 2: 2.9E+1 kg/site-day over 80 days/yr from 1 site or 2.4E+3 kg/yr to: WWTP (technical contact) from: Water release from Dryer (Centrifuge) basis: EPA/OPPT Water Saturation Loss Model. The technical contact indicated that some PMN would be dissolved in the mother liquor (filtrate) removed during the centrifuge step. CEB performed a mass balance around the dryer (centrifuge) to obtain the amount of PMN in the waste (7,186 kg in - 968 kg out as product = 6,218 kg in waste. This value was used in the Water Saturation Loss Model to determine the amount of PMN dissolved in the filtrate. This liquid waste stream is sent to biological treatment (>99.99% DVE).

Deepwell Injection Output 2: 4.8E+0 kg/site-day over 80 days/yr from 1 site or 3.8E+2 kg/yr to: uncertain from: Loading Solid Product into Transport Containers basis: User-Defined Loss Rate Model. EPA/OPPT Generic Model to Estimate Dust Releases from Transfer/Unloading Page 3Support - P-10-0285 engineering.3.txt Operations of Solid Powders (Nov 2006) estimates 0.5% PV released to water, incineration, air or land.

RELEASE TOTAL 5.0E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 3 Basis:

Inhalation:

Exposure to Particulate (Class I) Upper Bound: 1.5E+2 mg/day over 80 days/yr Number of workers (all sites) with inhalation exposure: 3 Basis: Loading Solid Product into Transport Containers; OSHA PNOR PEL-Limiting Model. NOTE: The respirator class is: I. Particulate (including solid or liquid droplets).

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

OR b) Hazard Rating for health of 2 or greater? 1-2 No Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal:

Exposure to Solid at 100.00% concentration High End: 3.1E+3 mg/day over 80 days/yr Number of workers (all sites) with dermal exposure: 3 Basis: Loading Solid Product into Transport Containers; EPA/OPPT Direct 2-Hand Dermal Contact with Solids Model.

INITIAL REVIEW ENGINEERING REPORT PMN: 10-0285

Use: Chemical intermediate

Number of Sites/ Location: 1 Albemarle Fine Chemistry Services Tyrone PA 16686 Days/yr: 80 Basis: CEB assumes same mass balance parameters as for mfg: 80 bt/yr, same 1 site.

Process Description: Unload PMN from intermediate storage (solid powder, 100%) --> Charge to premix reactor --> Product formed , PMN consumed --> Dryer to produce solid (Submission)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY Submission specifies all releases that are not reused/recycled (including solvents, PPE, filter cloths) are sent to incineration. Note, incineration releases total <28,000 kg/site-day.

Air or Incineration Output 2: 4.8E+0 kg/site-day over 80 days/yr from 1 site or 3.8E+2 kg/yr Page 4Support - P-10-0285 engineering.3.txt to: uncertain from: Unloading Solid Raw Material from Transport Containers basis: User-Defined Loss Rate Model. EPA/OPPT Generic Model to Estimate Dust Releases from Transfer/Unloading Operations of Solid Powders (Nov 2006) estimates 0.5% PV released to water, incineration, air or land.

Incineration Output 2: 9.6E+0 kg/site-day over 80 days/yr from 1 site or 7.7E+2 kg/yr to: incineration (per technical contact) from: Cleaning Solid/ Powder Residuals from Containers Used to Transport the Raw Material basis: EPA/OPPT Solid Residuals in Transport Containers Model, CEB standard 1% residual. The technical contact indicated that the drums would be lined, and the liner disposed of by incineration.

Deepwell Injection Output 2: 4.8E+0 kg/site-day over 80 days/yr from 1 site or 3.8E+2 kg/yr to: uncertain from: Unloading Solid Raw Material from Transport Containers basis: User-Defined Loss Rate Model. EPA/OPPT Generic Model to Estimate Dust Releases from Transfer/Unloading Operations of Solid Powders (Nov 2006) estimates 0.5% PV released to water, incineration, air or land.

RELEASE TOTAL 1.5E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 3 Basis: Submission estimates 2 workers exposed to PMN. CEB assesses minimum default 3 workers/site.

Inhalation:

Exposure to Particulate (Class I) Upper Bound: 1.5E+2 mg/day over 80 days/yr Number of workers (all sites) with inhalation exposure: 3 Basis: Unloading Solid Raw Material from Transport Containers; OSHA PNOR PEL-Limiting Model. NOTE: The respirator class is: I. Particulate (including solid or liquid droplets).

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

OR b) Hazard Rating for health of 2 or greater? 1-2 No Inhalation Monitoring Data Desired? Yes (both criteria met)

Dermal:

Exposure to Solid at 100.00% concentration High End: 3.1E+3 mg/day over 80 days/yr Number of workers (all sites) with dermal exposure: 3 Page 5Support - P-10-0285 engineering.3.txt Basis: Unloading Solid Raw Material from Transport Containers; EPA/OPPT Direct 2-Hand Dermal Contact with Solids Model.



CALL BY: Casey MacQueen / Jason A Sese Organization: ERG for CEB

CALL TO: Alex Polinsky

Organization: Syngenta Crop Production, Inc.

Date: 04/05/2010

Time: 4pm

Phone: 336-632-2918

PMN: 10-0285

Mr. Polinsky's was available on April 5, 2010...| | Q1: It appears that stated physical forms on pp. 9 and 10 are describing materials other than the current PMN (based on associated diagrams on pp. 11 and 12). Confirm that solid chemical is actually , which this current PMN is used to manufacture? Also, current PMN is solid in neat form; however, based on information provided it is never an isolated solid?| A1: The PMN is produced in dry powder form, after filtration and drying steps. | | Q2: Submission states all releases to incineration (or reuse/recycle) -- confirm this applies to equipment and container cleaning?| A2: Yes, wastes are disposed via incineration. | | Q3: Confirm that releases 1, 3, 4 which are sent to bio tmt do not contain PMN? | A3: The PMN is not formed until after waste streams 1 and 2. There will be PMN in waste stream 3, but all PMN will be recovered from waste stream 4. | | Q4: Confirm this PMN is completely consumed in the reaction to product ?| A4: The PMN is added to the reaction vessel and completely reacted. || Q5: For the premix step, the mass balance does not look to be correct - can you clarify? A5: I'm not sure - we were working off a process from 10 years ago in the UK. There will be both liquid (with PMN) and gas (CO2; H2S) streams coming from this operation.

CALL BY: M. El-Zoobi Organization: ERG for CEB Page 6Support - P-10-0285 engineering.3.txt

CALL TO: Alex Polinsky

Organization: Syngenta Crop Production, Inc.

Date: 04/06/2010

Time:

Phone: 336-632-2918

PMN: 10-0285

Q1: describe last step| A1: process stream enters a centrifuge where pmn is separated from liquid. the liquid effluent of the centrifuge is called filtrate or mother liqeour. this stream may have pmn dissolved in it. it is not expected to have solid pmn in it because the centrifuge has a cloth that stops pmn from passing.| | Q2: | A2: | | Q3: | A3: | | Q4: | A4:

Page 7

# A-003

Initial Review Exposure Report

for PMN P-10-285May 26, 2010



## This report was prepared using the engineering report “ **Post-Focus Draft Revision 1” dated 5/19/2010.** 

POST FOCUS REVIE W EXPOSURE REPORT
Chemical ID: P-10-0285 Reviewer: Cinalli/JB

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 = 5 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

mfg/use: Max ADR:

max acute eco 4.28E-02 --- 5.39E-04 --- 887 --- --- 4.78E-02 8.31E -04 2.40E-01 ---

mfg/use: PDM1 --- --- --- --- 887 76 --- --- --- --- --- mfg/use: Max LADD --- 1.62E-04 --- 2.20E-06 --- --- 3.56E-04 --- --- --- 1.69E-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). 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 7Q 10 streamflow, which is defined as the average daily streamflow of the seven consecutive days of lowest flow within a ten year period.

Remarks:May 26, 2010

POST FOCUS REVIEW EXPOSURE REPORT

Chemical ID: P-10-0285 Assessor: Sherer/JB

ENVIRONMENTAL RELEASES

Scenario#:1 Number of Release Sites: 1.

Release Activity: mfg/use: Max ADR

Release Description: WATER LANDFILL

Non-sludge/Sludge STACK FUGITIVE

Total Releases: 768.00 0.00 N/A 768.00

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

Non-sludge/Sludge

Release Days/yr: 80.00 0.00/0.00 N/A 80.00

Per Site Release: 9.60 0.00/0.00 N/A 9.60

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

Remarks:May 26, 2010

POST FOCUS REVIEW EXPOSURE REPORT

Chemical ID: P-10-0285

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

SCENARIO #: 1 Number of Site s: 1 RELEASE ACTIVITY:mfg/use:

Max ADR

SIC-CODE DESCRIPTION: Orga nic Chemicals Manufacture

SIC-CODE (S): 2865,2869 EXPOSED POPULATION: Adult

WWT

REMOVAL (%) RELEASE

DAYS PRETREATMENT

RELEASE (kg/site/day) POSTTREATMENT

RELEASE (kg/site/day) DWT

(%) BCF (L/kg)

50.00 80. 9.6 4.80 0.00 3.16

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER

PLANT

TYPE % ILE

FACILITY STREAM FLOW (MLD) STREAM CONC. ( μ g/l)

Harmonic

Mean 30Q5 7Q10 1Q10 Harmonic

Mean 30Q5 7Q10 1Q10

ALL 50 2825.61 935.49 634.16 514.20 1.70 5.13 7.57 9.33

ALL 10 50.57 9.38 5.41 4.53 94.92 511.73 887.25 1059.60

DRINKING WATER AND FISH IN GESTION EXPOSURE ESTIMATES

Exposure Units Drinking Water Results Drinking

Water Units Fish Ingestion Results Fish Ingestion

Units

50% 10% 50% 10%

Cancer

LADD pot 2.90E-06 1.62E-04 mg/kg/day 3.93E-08 2.20E-06 mg/kg/day

LADC pot 1.49E-04 8.32E-03 mg/L 4.71E-04 2.63E-02 mg/kg

Acute

ADR pot 4.29E-04 4.28E-02 mg/kg/day 9.64E-06 5.39E-04 mg/kg/day

SIC Code Comments:May 26, 2010

POST FOCUS REVIEW EXPOSURE REPORT

Chemical ID: P-10-0285

INHALATION EXPOSURE ESTIMATES (POST-TREATMENT)

SCENARIO #: 1 RELEASE ACTIVITY mfg/use: Max ADR

RELEASE DESCRIPTION:

METHOD OF CALCULATION: Screen3

EXPOSED POPULATION: Adult

Number of Sites: 1.

Per Site Fugitive Release: 9.60 kg/site/day

Fugitive Release Days per Year: 80.00 days

% Removal via Fugitive Release: 0.00 %

Total Fugitive Release: 768.00 kg/yr

Max Annual Average Air Concentration (Fugitive): 23.00 μg/m 3

Max 24 Hour Average Air Concentration(Fugitive): 1310.00 μg/m 3

Per Site Stack Release: NA kg/site/day

Stack Release Days per Year: NA days

% Removal via Stack Release: 99.90 %

Total Stack Release: NA kg/yr

Max Annual Average Air Con centration (Stack): 0.00 μg/m 3

Max 24 Hour Average Air Concentration (Stack): 0.00 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) N/A 1.69E-03 30.00 75.00 71.80 0.55

LADC pot (mg/m 3 ) N/A 9.20E-03 30.00 75.00 NA NA

Acute

ADR pot

(mg/kg/day) N/A 0.24 NA 1 day 71.80 0.55

Inhalation Comments:May 26, 2010

Stack Parameter Data Fugitive Parameter Data

Stack Height 10.00 Release Height: 3.00 m

Inside Stack

Diameter: 0.10 Length of Release Opening: 10.00 m

Stack Gas Exit Velocity: 0.10 Width of Release Opening: 10.00 m

Stack Gas Temperature: 293.00

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 mMay 26, 2010

POST FOCUS REVIEW EXPOSURE REPORT

Chemical ID: P-10-0285

INHALATION EXPOSURE ESTIMATES (POST-TREATMENT)

SCENARIO #: 3 RELEASE ACTIVITY:Mfg-Use: Max LADD

RELEASE DESCRIPTION:

METHOD OF CALCULATION: Screen3

EXPOSED POPULATION: Adult

Number of Sites: 1.

Per Site Fugitive Release: 768.00 kg/site/day

Fugitive Release Days per Year: 1.00 days

% Removal via Fugitive Release: 0.00 %

Total Fugitive Release: 768.00 kg/yr

Max Annual Average Air Concentration (Fugitive): 23.00 μg/m 3

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

Per Site Stack Release: 3056.00 kg/site/day

Stack Release Days per Year: 1.00 days

% Removal via Stack Release: 0.00 %

Total Stack Release: 3056.00 kg/yr

Max Annual Average Air Concen tration (Stack): 11.30 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) 8.31E-04 1.69E-03 30.00 75.00 71.80 0.55

LADC pot (mg/m 3 ) 4.52E-03 9.20E-03 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:May 26, 2010

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 KMay 26, 2010

POST FOCUS REVIEW EXPOSURE REPORT

Chemical ID: P-10-0285 Assessor: Sherer/JB

ENVIRONMENTAL RELEASES

Scenario#:2 Number of Release Sites: 1.

Release Activity: mfg/use: PDM1

Release Description: WATER LANDFILL

Non-sludge/Sludge STACK FUGITIVE

Total Releases: 768.00 0.00 N/A 0.00

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

Non-sludge/Sludge

Release Days/yr: 80.00 0.00/0.00 N/A 0.00

Per Site Release: 9.60 0.00/0.00 N/A 0.00

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

Remarks:May 26, 2010

POST FOCUS REVIEW EXPOSURE REPORT

Chemical ID: P-10-0285

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

SCENARIO #: 2 Number of Site s: 1 RELEASE ACTIVITY:mfg/use:

PDM1

SIC-CODE DESCRIPTION: Orga nic Chemicals Manufacture

SIC-CODE (S): 2865,2869 EXPOSED POPULATION: Adult

WWT

REMOVAL (%) RELEASE

DAYS PRETREATMENT

RELEASE (kg/site/day) POSTTREATMENT

RELEASE (kg/site/day) DWT

(%) BCF (L/kg)

50.00 80. 9.6 4.80 0.00 3.16

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER

PLANT

TYPE % ILE

FACILITY STREAM FLOW (MLD) STREAM CONC. ( μ g/l)

Harmonic

Mean 30Q5 7Q10 1Q10 Harmonic

Mean 30Q5 7Q10 1Q10

ALL 50 2825.61 935.49 634.16 514.20 1.70 5.13 7.57 9.33

ALL 10 50.57 9.38 5.41 4.53 94.92 511.73 887.25 1059.60

DRINKING WATER AND FISH IN GESTION EXPOSURE ESTIMATES

Exposure Units Drinking Water Results Drinking

Water Units Fish Ingestion Results Fish Ingestion

Units

50% 10% 50% 10%

Cancer

LADD pot 2.90E-06 1.62E-04 mg/kg/day 3.93E-08 2.20E-06 mg/kg/day

LADC pot 1.49E-04 8.32E-03 mg/L 4.71E-04 2.63E-02 mg/kg

Acute

ADR pot 4.29E-04 4.28E-02 mg/kg/day 9.64E-06 5.39E-04 mg/kg/day

SIC Code Comments:May 26, 2010

POST FOCUS REVIEW EXPOSURE REPORT

Chemical ID: P-10-0285

SIC CODE EXPOSURES TO SURFACE WATER RELEASES

SCENARIO #: 2 RELEASE ACTIVITY: mfg/use: PDM1

SIC CODE DESCRIPTION: Orga nic Chemicals Manufacture

ASSOCIATED SIC CODES: 2865,2869

SIC CODE RESULTS

COC ( μ g/L) Percent of

Year COC

Exceeded Number of Days COC

Exceeded Release days/year Loading (kg/site/day) Waste Water Treatment (%) High/Avg Analysis

5.00 21 76 80.00 9.60 50.00 HighMay 26, 2010

POST FOCUS REVIEW EXPOSURE REPORT

Chemical ID: P-10-0285 Assessor: Sherer/JB

ENVIRONMENTAL RELEASES

Scenario#:3 Number of Release Sites: 1.

Release Activity: mfg/use: Max LADD

Release Description: WATER LANDFILL

Non-sludge/Sludge STACK FUGITIVE

Total Releases: 768.00 768.00 N/A 768.00

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

Non-sludge/Sludge

Release Days/yr: 1.00 1.00/0.00 N/A 1.00

Per Site Release: 768.00 768.00/0.00 N/A 768.00

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

Remarks:May 26, 2010

POST FOCUS REVIEW EXPOSURE REPORT

Chemical ID: P-10-0285

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

SCENARIO #: 3 Number of Site s: 1 RELEASE ACTIVITY:mfg/use:

Max LADD

SIC-CODE DESCRIPTION: Orga nic Chemicals Manufacture

SIC-CODE (S): 2865,2869 EXPOSED POPULATION: Adult

WWT

REMOVAL (%) RELEASE

DAYS PRETREATMENT

RELEASE (kg/site/day) POSTTREATMENT

RELEASE (kg/site/day) DWT

(%) BCF (L/kg)

50.00 1. 768. 384.00 0.00 3.16

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER

PLANT

TYPE % ILE

FACILITY STREAM FLOW (MLD) STREAM CONC. ( μ g/l)

Harmonic

Mean 30Q5 7Q10 1Q10 Harmonic

Mean 30Q5 7Q10 1Q10

ALL 50 2825.61 935.49 634.16 514.20 N/A N/A N/A N/A

ALL 10 50.57 9.38 5.41 4.53 N/A N/A N/A N/A

DRINKING WATER AND FISH IN GESTION EXPOSURE ESTIMATES

Exposure Units Drinking Water Results Drinking

Water Units Fish Ingestion Results Fish Ingestion

Units

50% 10% 50% 10%

Cancer

LADD pot 2.90E-06 1.62E-04 mg/kg/day 3.93E-08 2.20E-06 mg/kg/day

LADC pot 1.49E-04 8.32E-03 mg/L 4.71E-04 2.63E-02 mg/kg

Acute

ADR pot N/A N/A mg/kg/day N/A N/A mg/kg/day

SIC Code Comments:May 26, 2010

POST FOCUS REVIEW EXPOSURE REPORT
Chemical ID: P-10-0285

DRINKING WATER EXPOSURE ESTIMATES FROM LANDFILL RELEASES

SCENARIO #: 3 ACTIVITY: mfg/use: 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 (%)

1. 768.00/1.00 0.00/0.00 Moderate 0.00 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) Negligible 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) 3.56E-04 30.00 75.00 71.80 1.40

LADC pot (mg/L) 1.83E-02 30.00 75.00 NA NA

REMARKS:May 26, 2010

POST FOCUS REVIEW EXPOSURE REPORT

Chemical ID: P-10-0285

INHALATION EXPOSURE ESTIMATES (POST-TREATMENT)

SCENARIO #: 3 RELEASE ACTIVITY mfg/use: Max LADD

RELEASE DESCRIPTION:

METHOD OF CALCULATION: Screen3

EXPOSED POPULATION: Adult

Number of Sites: 1.

Per Site Fugitive Release: 768.00 kg/site/day

Fugitive Release Days per Year: 1.00 days

% Removal via Fugitive Release: 0.00 %

Total Fugitive Release: 768.00 kg/yr

Max Annual Average Air Concentration (Fugitive): 23.00 μg/m 3

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

Per Site Stack Release: NA kg/site/day

Stack Release Days per Year: NA days

% Removal via Stack Release: 99.90 %

Total Stack Release: NA kg/yr

Max Annual Average Air Con centration (Stack): 0.00 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) N/A 1.69E-03 30.00 75.00 71.80 0.55

LADC pot (mg/m 3 ) N/A 9.20E-03 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:May 26, 2010

Stack Parameter Data Fugitive Parameter Data

Stack Height 10.00 Release Height: 3.00 m

Inside Stack

Diameter: 0.10 Length of Release Opening: 10.00 m

Stack Gas Exit Velocity: 0.10 Width of Release Opening: 10.00 m

Stack Gas Temperature: 293.00

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