Support Documents for 

Significant New Use Rule (SNUR) on 

Premanufacture Notice (PMN) 

P-10-285 

EPA Docket EPA-HQ-OPPT-2011-0577 

EPA SANITIZED Page 1 of 33
Index

A-001 Structure Activity 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 

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A-001 

Structure Activity Team (SAT) Report

for PMN P-10-285 

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A-002 

Initial Review Engineering Report

for PMN P-10-285 

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Support - 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

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Support - 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)

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Support - 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

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Support - 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

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Support - 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

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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 6

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Support - 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

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A-003 

Initial Review Exposure Report

for PMN P-10-285 

EPA SANITIZED Page 18 of 33
May 26, 2010 

This report was prepared using the engineering report “Post-Focus 

Draft Revision 1” dated 5/19/2010.

POST FOCUS REVIEW EXPOSURE REPORT 

 Chemical ID: P-10-0285 Reviewer: Cinalli/JB 

 

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 = 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 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. 

Remarks: 

EPA SANITIZED Page 19 of 33
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: 

EPA SANITIZED Page 20 of 33
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 Sites: 1 RELEASE ACTIVITY:mfg/use: 

Max ADR 

SIC-CODE DESCRIPTION: Organic 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. (μg/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 INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water Results Drinking 

Water Units Fish Ingestion Results 

Fish 

Ingestion 

Units 

50% 10% 50% 10% 

Cancer 

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

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

Acute 

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

SIC Code Comments: 

EPA SANITIZED Page 21 of 33
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/m3

Max 24 Hour Average Air 

Concentration(Fugitive): 

1310.00 μg/m3

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 Concentration (Stack): 0.00 μg/m3

Max 24 Hour Average Air Concentration (Stack): 0.00 μg/m3

ASSUMPTIONS 

Exposure Units 

Results 

(Stack) 

Results 

(Fugitive) ED 

(years) 

AT 

(years) 

BW 

(kg) 

Inh. Rate 

(m3/hr) 

Cancer 

LADDpot (mg/kg/day) N/A 1.69E-03 30.00 75.00 71.80 0.55 

LADCpot (mg/m3) N/A 9.20E-03 30.00 75.00 NA NA 

Acute 

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

Inhalation Comments: 

EPA SANITIZED Page 22 of 33
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 

EPA SANITIZED Page 23 of 33
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/m3

Max 24 Hour Average Air 

Concentration(Fugitive): 

N/A μg/m3

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 Concentration (Stack): 11.30 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) 8.31E-04 1.69E-03 30.00 75.00 71.80 0.55 

LADCpot (mg/m3) 4.52E-03 9.20E-03 30.00 75.00 NA NA 

Acute 

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

Inhalation Comments: 

EPA SANITIZED Page 24 of 33
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 K 

EPA SANITIZED Page 25 of 33
May 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: 

EPA SANITIZED Page 26 of 33
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 Sites: 1 RELEASE ACTIVITY:mfg/use: 

PDM1 

SIC-CODE DESCRIPTION: Organic 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. (μg/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 INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water Results Drinking 

Water Units Fish Ingestion Results 

Fish 

Ingestion 

Units 

50% 10% 50% 10% 

Cancer 

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

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

Acute 

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

SIC Code Comments: 

EPA SANITIZED Page 27 of 33
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: Organic Chemicals Manufacture 

ASSOCIATED SIC CODES: 2865,2869 

SIC CODE RESULTS 

COC (μg/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 High 

EPA SANITIZED Page 28 of 33
May 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: 

EPA SANITIZED Page 29 of 33
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 Sites: 1 RELEASE ACTIVITY:mfg/use: 

Max LADD 

SIC-CODE DESCRIPTION: Organic 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. (μg/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 INGESTION EXPOSURE ESTIMATES 

Exposure Units 

Drinking Water Results Drinking 

Water Units Fish Ingestion Results 

Fish 

Ingestion 

Units 

50% 10% 50% 10% 

Cancer 

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

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

Acute 

ADRpot N/A N/A mg/kg/day N/A N/A mg/kg/day 

SIC Code Comments: 

EPA SANITIZED Page 30 of 33
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 

SLUDGE1 

AND DAYS OF 

RELEASE 

(kg/site/day)/(days)

MIGRATION 

DESCRIPTOR2

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 

LADDpot (mg/kg/day) 3.56E-04 30.00 75.00 71.80 1.40 

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

REMARKS: 

 

EPA SANITIZED Page 31 of 33
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/m3

Max 24 Hour Average Air 

Concentration(Fugitive): 

N/A μg/m3

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 Concentration (Stack): 0.00 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) N/A 1.69E-03 30.00 75.00 71.80 0.55 

LADCpot (mg/m3) N/A 9.20E-03 30.00 75.00 NA NA 

Acute 

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

Inhalation Comments: 

EPA SANITIZED Page 32 of 33
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 

EPA SANITIZED Page 33 of 33