615
Use of MWF Oil based (Use1)
Drinking Water Ingestion
                                   1.13E-03
                                      0.5
                                    0.0006
                                    119646

Fish Ingestion
                                   2.20E-02
                                      0.5
                                    0.0110
                                     6145
Use of MWF Water Based 50% Pretreatment (Use1)
Drinking Water Ingestion
                                   5.67E-03
                                      0.5
                                    0.0028
                                     23845

Fish Ingestion
                                   1.10E-01
                                      0.5
                                    0.0550
                                     1229
Use of MWF Water Based 70% Pretreatment (Use1)
Drinking Water Ingestion
                                   3.38E-03
                                      0.5
                                    0.0017
                                     40000

Fish Ingestion
                                   6.60E-02
                                      0.5
                                    0.0330
                                     2048
Use of MWF Water Based 99% Pretreatment (Use1)
Drinking Water Ingestion
                                   1.11E-04
                                      0.5
                                   0.000056
                                    1218018

Fish Ingestion
                                   2.17E-03
                                      0.5
                                    0.0011
                                     62304
Plastics Compounding (Proc2)
Drinking Water Ingestion
                                   1.10E-01
                                      0.5
                                    0.0550
                                     1229

Fish Ingestion
                                   3.78E+00
                                      0.5
                                    1.8900
                                      36
Plastics Converting (Use2)
Drinking Water Ingestion
                                   8.06E-05
                                      0.5
                                    0.0000
                                    1677419

Fish Ingestion
                                   2.45E-03
                                      0.5
                                    0.0012
                                     55184
Formulation of Adhesives and Sealants Off-spec to incineration or landfill; 50% (Proc3)
Drinking Water Ingestion
                                   2.85E-03
                                      0.5
                                    0.0014
                                     47439

Fish Ingestion
                                   9.44E-02
                                      0.5
                                    0.0472
                                     1432
#5 Formulation of Adhesives and Sealants Off-spec to incineration or landfill; 70% (Proc3)
Drinking Water Ingestion
                                   1.71E-03
                                      0.5
                                    0.0009
                                     79064

Fish Ingestion
                                   5.66E-02
                                      0.5
                                    0.0283
                                     2389
#5 Formulation of Adhesives and Sealants Off-spec to incineration or landfill; 99% (Proc3)
Drinking Water Ingestion
                                   5.71E-02
                                      0.5
                                    0.0286
                                     2368

Fish Ingestion
                                   1.89E+00
                                      0.5
                                    0.9450
                                      72
 Use of Adhesives and Sealants (Use3)
Drinking Water Ingestion
                                   4.35E-03
                                      0.5
                                    0.0022
                                     31080

Fish Ingestion
                                   7.50E-02
                                      0.5
                                    0.0375
                                     1803
Shaded rows are scenarios with risk findings.
[a] B = "biota" to represent estimated fish ingestion based on highest reported levels of MCCPs in fish (i.e., 2.63 mg/kg-wet weight). See Table Apx_D-1-4 for levels of MCCPs in biota. Estimates for fish consumption is based on the Exposure Factors Handbook (US EPA, 2011). The highest 95[th] percentile value is used (4.9 grams of fish/kg-bw). The calculation for the three fish ingestion scenarios where modeled results suggest risk were refined using the following equation: 2.63 mg/kg-bw (MCCP concentration in fish) x 0.392 kg of fish intake = 1.03 mg/80 kg-bw = 0.013 mg/kg-bw.
[b]M = "modeled" to represent the estimated fish intake using E-FAST and associated assumptions. See Appendix F.

Table 20: General Population MOEs for P-12-0433 (LCCP):  Drinking Water/Fish Ingestion Risk Estimates (Hazard POD [HED] = 294 mg/kg-bw/day)
Scenario
                                Exposure Routes
                            Exposure (mg/kg bw/day)
                            Absorption Oral Human
                       Estimated Exposure (mg/kg bw/day)
                                      MOE
                         (Risks Identified if <300)
Formulation of MWFs Oil-Based (Proc1)
Drinking Water Ingestion
                                   1.23E-02
                                      0.5
                                    0.0062
                                     47805

Fish Ingestion
                                   3.80E-01
                                      0.5
                                    0.1900
                                     1547
MWF Formulation Water Based 50% Pretreatment (Proc1)
Drinking Water Ingestion
                                   6.41E-03
                                      0.5
                                    0.0032
                                     91732

Fish Ingestion
                                   2.00E-01
                                      0.5
                                    0.1000
                                     2940
MWF Formulation Water Based 70% Pretreatment (Proc1)
Drinking Water Ingestion
                                   3.78E-03
                                      0.5
                                    0.0019
                                    155556

Fish Ingestion
                                   1.20E-01
                                      0.5
                                    0.0600
                                     4900
MWF Formulation Water Based 99% Pretreatment (Proc1)
Drinking Water Ingestion
                                   1.25E-04
                                      0.5
                                    0.0001
                                    4704000

Fish Ingestion
                                   3.87E-03
                                      0.5
                                    0.0019
                                    151938
Use of MWF Oil based (Use1)
Drinking Water Ingestion
                                   9.69E-04
                                      0.5
                                    0.0005
                                    606811

Fish Ingestion
                                   1.76E-02
                                      0.5
                                    0.0088
                                     33409
Use of MWF Water Based 50% Pretreatment (Use1)
Drinking Water Ingestion
                                   4.68E-03
                                      0.5
                                    0.0023
                                    125641

Fish Ingestion
                                   8.52E-02
                                      0.5
                                    0.0426
                                     6901
Use of MWF Water Based 70% Pretreatment (Use1)
Drinking Water Ingestion
                                   2.81E-03
                                      0.5
                                    0.0014
                                    209253

Fish Ingestion
                                   5.11E-02
                                      0.5
                                    0.0256
                                     11507
Use of MWF Water Based 99% Pretreatment (Use1)
Drinking Water Ingestion
                                   9.45E-05
                                      0.5
                                   0.000047
                                    6222222

Fish Ingestion
                                   1.72E-03
                                      0.5
                                    0.0009
                                    341860

Tables 21 and 22 present the findings from estimating risk to the general population following inhalation exposure to each of the two PMN substances from either stack air or fugitive emissions. For all scenarios, the MOEs for P-12-0453 and -0433 all exceed the respective benchmark values, which indicate a finding of low risk to the general population from inhalation exposures (from either stack or fugitive sources of environmental release) that may occur due to the manufacturing, processing, and uses evaluated in this assessment.

Table 21: General Population MOEs for P-12-0453 (MCCP):  Inhalation Exposure to Stack/Fugitive Air Risk Estimates (Hazard POD [HEC] = 14.3mg/m[3])
                                   Scenario
                        (Either Stack or Fugitive Air)
                       Exposure Concentration (mg/m[3])
                          Absorption Inhalation Human
                                   (Percent)
                   Estimated Exposure Concentration (mg/m3)
                                      MOE
                         (Risks Identified if <30)
MWF Formulation Oil Based - Stack Air (Proc1)
                                   1.58E-02
                                      0.5
                                   7.90E-03
                                     1810
MWF Formulation Oil Based - Fugitive Air (Proc1)
                                   8.88E-03
                                      0.5
                                   4.44E-03
                                     3221
MWF Formulation Water Based 50% Pretreatment - Stack Air (Proc1)
                                   8.30E-03
                                      0.5
                                   4.15E-03
                                     3446
MWF Formulation Water Based 50% Pretreatment - Fugitive Air (Proc1)
                                   4.70E-04
                                      0.5
                                   2.35E-04
                                     60851
MWF Formulation Water Based 70% Pretreatment - Stack Air (Proc1)
                                   4.92E-03
                                      0.5
                                   2.46E-03
                                     5813
MWF Formulation Water Based 70% Pretreatment - Fugitive Air (Proc1)
                                   4.70E-04
                                      0.5
                                   2.35E-04
                                     60851
MWF Formulation Water Based 99% Pretreatment - Stack Air (Proc1)
                                   3.30E-04
                                      0.5
                                   1.65E-04
                                     86667
MWF Formulation Water Based 99% Pretreatment - Fugitive Air (Proc1)
                                   8.88E-03
                                      0.5
                                   4.44E-03
                                     3221
Use of MWF Oil based - Stack Air (Use1)
                                   9.30E-05
                                      0.5
                                   4.65E-05
                                    307527
Use of MWF Water Based 50% Pretreatment - Stack Air (Use1)
                                   4.26E-05
                                      0.5
                                   2.13E-05
                                    671362
Use of MWF Water Based 70% Pretreatment - Stack Air (Use1)
                                   2.54E-05
                                      0.5
                                   1.27E-05
                                    1125984
Use of MWF Water Based 99% Pretreatment - Stack Air (Use1)
                                   8.40E-07
                                      0.5
                                   4.20E-07
                                   34047619
Plastics Compounding - Stack Air (Proc2)
                                   2.75E-03
                                      0.5
                                   1.38E-03
                                     10400
Plastics Compounding -  Fugitive Air (Proc2)
                                   1.50E-02
                                      0.5
                                   7.50E-03
                                     1907
Plastics Converting - Stack Air (Use2)
                                   1.30E-04
                                      0.5
                                   6.50E-05
                                    220000
Plastics Converting - Fugitive Air (Use2)
                                   3.69E-02
                                      0.5
                                   1.85E-02
                                      775
Formulation of Adhesives and Sealants Off-spec to incineration or landfill 50% - Stack Air (Proc3)
                                   1.41E-03
                                      0.5
                                   7.05E-04
                                     20284
Formulation of Adhesives and Sealants Off-spec to incineration or landfill 70% - Stack Air (Proc3)
                                   1.39E-03
                                      0.5
                                   6.95E-04
                                     20576
Formulation of Adhesives and Sealants Off-spec to incineration or landfill 99% - Stack Air (Proc3)
                                   1.35E-03
                                      0.5
                                   6.75E-04
                                     21185
Use of Adhesives and Sealants - Stack Air (Use3)
                                   1.50E-05
                                      0.5
                                   7.50E-06
                                    1906667
Use of Adhesives and Sealants - Fugitive Air (Use3)
                                   1.60E-01
                                      0.5
                                   8.00E-02
                                      179

Table 22: General Population MOEs for P-12-0433 (LCCP):  Inhalation Exposure to Stack/Fugitive Air Risk Estimates (Hazard POD [HEC] = 62 mg/m[3])
Scenario
Exposure Concentration (mg/m[3])
Absorption Inhalation Human
Estimated Exposure Concentration (mg/m3)
                       MOE (Risks Identified if <300)
MWF Formulation Oil Based - Stack Air (Proc1)
                                   3.50E-04
                                      0.5
                                   1.75E-04
                                    354286
MWF Formulation Oil Based - Fugitive Air (Proc1)
                                   1.91E-03
                                      0.5
                                   9.55E-04
                                     64921
MWF Formulation Water Based 50% Pretreatment - Stack Air (Proc1)
                                   1.60E-04
                                      0.5
                                   8.00E-05
                                    775000
MWF Formulation Water Based 50% Pretreatment - Fugitive Air (Proc1)
                                   6.60E-04
                                      0.5
                                   3.30E-04
                                    187879
MWF Formulation Water Based 70% Pretreatment - Stack Air (Proc1)
                                   1.00E-04
                                      0.5
                                   5.00E-05
                                    1240000
MWF Formulation Water Based 70% Pretreatment - Fugitive Air(Proc1)
                                   6.60E-04
                                      0.5
                                   3.30E-04
                                    187879
MWF Formulation Water Based 99% Pretreatment - Stack Air(Proc1)
                                   1.58E-05
                                      0.5
                                   7.90E-06
                                    7848101
MWF Formulation Water Based 99% Pretreatment - Fugitive Air (Proc1)
                                   6.60E-02
                                      0.5
                                   3.30E-02
                                     1879
Use of MWF Oil based - Stack Air
                                   8.42E-05
                                      0.5
                                   4.21E-05
                                    1472684
Use of MWF Water Based 50% Pretreatment - Stack Air
                                   3.49E-05
                                      0.5
                                   1.75E-05
                                    3553009
Use of MWF Water Based 70% Pretreatment - Stack Air
                                   2.09E-05
                                      0.5
                                   1.05E-05
                                    5933014
Use of MWF Water Based 99% Pretreatment - Stack Air
                                   7.00E-07
                                      0.5
                                   3.50E-07
                                   177142857

CONCLUSIONS
Based on its assessment of the available surrogate hazard and exposure information on P-12-0453 and P-12-0433, EPA/OPPT concludes the following pertaining to the manufacturing, processing and use of these PMN substances:

 Occupational Exposures: Given the assumptions, data and scenarios evaluated in this assessment, there were no risks found for workers from either dermal or inhalation exposures to either of the PMN substances.
   2. General Population Exposures (from environmental releases): Given the assumptions, data and scenarios evaluated in this assessment, there were no risks found to humans from environmental releases via exposure to drinking water for either of the PMN substances, or from exposure via from fish ingestion (P-12-0433, the LCCP). There were three scenarios (3 out of 44) where potential risks to the general population due to fish ingestion were identified using the E-FAST modeling results. These scenarios were further evaluated using the highest measured values of MCCPs in fish. Using these measured values and high-end (95[th] percentile) fish intake assumptions, there were no risks identified. There were no risks found to humans from environmental releases via inhalation exposures from emissions from facilities for either PMN.

 Environmental Assessment:
a. Using the conventional EPA PMN method of estimating water concentrations, all of the intended processes and uses for P-12-0453 and 0433 are expected to result in releases to the surface water at concentrations that may present an unreasonable risk following acute and chronic exposures to aquatic organisms. Use of additional information submitted in response to comments on a previous draft did result in decreases of estimated risk values for some scenarios.

b. Using available measured concentrations of MCCP and LCCP congener groups in the environment as supporting information, the PMN substances:
                   Are expected to partition to sediment and may partition to soil through land application of biosolids, and
                   May be released to the environment at water concentrations that may present an unreasonable risk following acute and chronic exposures to aquatic organisms.
                   May be released to the environment resulting in sediment concentrations that may present an unreasonable risk following chronic exposures to sediment organisms.

 PBT Assessment: The PMN substances may be very persistent and very bioaccumulative.

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APPENDICES

 ENVIRONMENTAL FATE AND BIOACCUMULATION STUDY SUMMARIES

 ENVIRONMENTAL PERSISTENCE
 Abiotic Degradation
Generally, CPs are stable to hydrolysis and to direct photolysis in air and water, though very limited data exist on hydrolysis and direct and indirect photolysis in soil, water, or air. In studies using aliphatic hydrocarbon solvents, CPs were shown to be poor absorbers of UV light and no direct photodegradation was observed (Friedman and  Lombardo, 1975; Lombardo et al., 1975).
Koh and Thiemann (2001) studied photolysis of aqueous solutions for CPs products with chain lengths ranging from C10 to C24 including an MCCP product, Hoechst CP52, with chain lengths from C12 to C18 and an average of 52 wt% Cl. A mercury vapor lamp with main radiation wavelengths of 254, 302, 313, 366,405/408, and 436 was used in batch experiments. Following a 5 hour radiation time, estimated atmospheric degradation rates showed photolysis half-lives of less than 20 hours based on measurement of free chloride and analysis of degradation products. The MCCP product had a T1/2 of 12.8 hour in aqueous solution. The addition of peroxide or acetone increased the photolysis rate suggesting that indirect photolysis may be significant. The authors also reported that longer chain CPs were formed during this study and speculated that recombination of smaller alkyl radicals could occur under some conditions.

Thermal degradation data for MCCPs and LCCPs are limited, but studies of SCCPs and Polyvinyl chlorides suggest MCCPs are degraded rapidly at 250 - 350 °C (Bergman et al., 1984). Dehydrohalogenation may lead to the formation of a large number of aliphatic and aromatic compounds. Chlorine radical formation can lead to production of highly chlorinated aromatics including polychlorinated biphenyls. Higher Cl content results in production of greater numbers and amounts of chlorinated aromatics (Bergman et al., 1984).

 Fate in Air
As noted above, CPs lack structural components that absorb light in the UV or visible spectrum, so direct photolysis is not expected to occur. The atmospheric half-life has been estimated at 1 - 2 days (EA, 2009; ECB, 2005), based on estimated values for the second order rate constant for reaction with atmospheric hydroxyl radicals for MCCPs with lower chlorine contents between 40 and 56 wt%. EPA/OPPT also estimated atmospheric half-lives for MCCPs (40 and 70 wt% Cl) calculated using EPI Suite(TM)/AOPWIN(TM) (v. 1.92a) that range from about 1 to > 4 days (see Table_Apx A-1). MCCPs with the shorter chain lengths and higher chlorine contents were calculated to be more persistent.

MCCPs have low estimated vapor pressures (4.5 x 10[-8] to 2.27 x 10[-3] Pa at 20 - 25°C) and a Henry's law constant (HLC) (0.014 - 51.3 Pa x m[3]/mol for C14-17 congener groups) and are not expected to partition to air. They may be transported associated with particulate matter, and have been reported in indoor and outdoor air and house dust (Barber et al., 2005; Fridén et al., 2011; Hilger et al., 2013). Wide spread soil contamination and occurrence in artic samples suggest that MCCPs behave similarly to other chlorinated persistent organic pollutants (POPs) with high production volumes and releases, and are subject to long range transport (Dick et al., 2010; Medeiros et al., 2011; Tomy et al., 2000).

                    Table_Apx A-1: Estimated Atmospheric Half Lives Using EPI Suite(TM)/AOPWIN(TM) (v. 1.92a) for Varying MCCP Chain Length and Chlorination Percents Based on Wt.
                                 Chain Length
                                  40 wt% Cl
                                  70 wt% Cl
                                      C14
                                      1.0
                                      4.4
                                      C15
                                      0.8
                                      3.0
                                      C16
                                      0.8
                                      3.0
                                      C17
                                      0.8
                                      2.9

 Biodegradation
EPA/OPPT reviewed studies from the open literature and submitted to EPA/OPPT including those described in the Canada and EU assessments and referenced in Table_Apx A-2 (EC, 2008a; ECB, 2005) to determine biodegradation under a variety of environmental conditions. Some of these studies used modified test conditions to enhance or maximize biodegradation. EPA/OPPT concurs with the EU's conclusions that under these modified test conditions, C14 41.3% by wt. Cl and a C14 45.5% by wt. Cl substances are readily biodegradable. C 15 51% by wt. Cl were found to be inherently degradable and possibly readily degradable in modified OECD 301 and 301D tests. This suggests that CPs with these chain lengths and shorter, and this degree of chlorination and lower, are inherently degradable. More highly chlorinated and longer carbon chain CPs (C14-17 51.7% by wt. Cl, C14 55% by wt. Cl, C14 60.2% by wt. Cl, and C14 -17 63.2% by wt. Cl) biodegraded over a range of 2-54% in 28 days to 4-57% at up to 60 days. The most highly chlorinated, (C14-17, 63.2 wt% Cl) biodegraded 5% in 28 days and 10% at 60 days in the enhanced biodegradation studies, suggesting that longer chain and higher chlorination can contribute to greater persistence under most environmental conditions. (Van Ginkel, 2014 a and b; Van Ginkel 2010 a-d; Van Ginkel and Louwerse 2010 a and b).
 Fate in Wastewater Treatment
In its review of the available measured data on MCCPs in wastewater treatment from data in from other countries, EPA/OPPT determined that CPs are present in the majority of municipal waste water treatment plant (WWTP) influent (Coelhan, 2010; Nicholls et al., 2001; Stevens et al., 2003; Zeng et al., 2013). Low water solubility and relatively high partitioning coefficients suggest that most of the MCCPs and LCCPs entering WWTP systems will associate with solids. Some biodegradation of shorter chain, lower chlorinated MCCP congener groups may occur, while longer chain length, more chlorinated congener groups will be resistant to aerobic and anaerobic degradation. Shorter and lower chlorinated congener groups have higher vapor pressure and may be lost to the vapor phase during aeration. WWTP effluent also contains some particulate-associated MCCPs. Because of their low water solubility, little MCCP or LCCP will be in the dissolved phase, and the majority will be removed along with settled sludge. Once associated with the sludge, the CPs will generally be stable in sludge treatment and remain in the residual biosolids. Land application of biosolids will transfer the MCCPs and LCCPs to agricultural and other soils (Nicholls et al., 2001; Stevens et al., 2003). Because 50 - 60% of biosolids in the US are land applied, the majority of MCCPs and LCCPs entering WWTPs may be released to the environment via application to soil, and may be transported from contaminated soil to other locations and media by soil erosion, runoff, and wind borne particulates, and volatilization.

 Fate in Surface Water, Sediments and Groundwater
Because they generally have low water solubility, high sorption coefficients, and tend to partition to solids, MCCPs and LCCPs released to surface water will partition to surficial sediment where they may be buried and removed from potential degradation processes. This explains what is found in the limited monitoring data that exist - MCCP concentrations in surface water are generally in the low pg/L range, while sediment concentrations are several orders of magnitude higher (EC, 2008a).  The presence could also be partially due to the general observation of slower rates of biodegradation under anaerobic conditions, as can occur in sediments, than under aerobic conditions (Boethling et al. 1995). Applying this observation to the rates of aerobic biodegradation for certain MCCPs reported elsewhere in this document suggests they may be persistent or very persistent in anaerobic environments.

MCCPs may leach from soil and be transported to groundwater, but low solubility and high sorption will act to keep dissolved concentrations very low. Facilitated transport with colloids and particulates may occur so that MCCPs can be transported in groundwater, but in general, concentrations in this compartment are expected to be very low. MCCPs that are introduced to groundwater will tend to partition to the solid phase and not be mobile.
 Fate in Soil
Existing monitoring data suggest that MCCPs are present in soil, probably as a result of atmospheric transport and deposition. Areas near sources, such as land receiving wastewater biosolids, manufacturing and processing facilities, and electronic waste processing and recycling facilities are shown to have higher levels (Wang et al., 2013). MCCPs are expected to be stable in soil, and once deposited, could remain/persist in the soil for years or decades. Burial and advective transport away from the site of deposition are the major dissipation processes. No data are available on soil photolysis, although aqueous photolysis data suggest that indirect photolysis may result in degradation to shorter and less chlorinated CP congener groups. No soil biodegradation data exists, but some strains of bacteria that can co-metabolize MCCPs have been identified (Allpress and  Gowland, 1999). If degradation does occur, it is expected to be slow with T1/2 of at least months to years.

Table_Apx A-2: Review of MCCP and LCCP Biodegradation Studies.

 Overall Conclusions for Table_Apx A-2: Based on the studies summarized below, it is concluded that constituents including those of C 14-17 63% Cl, C 14-17, 60-63% Cl, C 14-17 51%, and 53-56% Cl, C14 60.2 %Cl, and  C 18-20 48 - 70% Cl may be persistent or very persistent.

Table_Apx A-2: Biodegradation Studies on MCCPs (C14-17) and LCCPs (C>18)
                                 Study Authors
                               Publication Date
            MCCP/LCCP Chemicals Evaluated (i.e., C-length, wt% Cl)
                                    Method
                                Study Duration
                      Noteworthy Results and Implications
                                     MCCPs
                                  Van Ginkel
                                     2010d
                                 C14 45 wt% Cl
                                 Closed bottle
                                    28 days
Approximately 64% degraded in 28 days
Based on oxygen demand
                                  Van Ginkel
                                     2010b
                              C14-17 45.6 wt% Cl
                                 Closed bottle
                                    28 days
Approximately 51% in 28 days and 63% in 42 days degradation
Based on oxygen demand
                                  Van Ginkel
                                     2010c
                              C14-17 51.7 wt% Cl
                                 Closed bottle
                                    28 days
Approximately 27% degradation in 28 days and 57% after 60 days
Based on oxygen demand
                                  Van Ginkel
                                     2010a
                              C14-17 63.2 wt% Cl
                                 Closed bottle
                                    28 days
Approximately 5% degradation after 28 days and 10% after 60 days.
                            Van Ginkel and Louwerse
                                     2010a
                        C14 45,50,55,60, 60.2 wt% Cl %
              Closed bottle with river water and sludge inoculum
                                    28 days
Approximately 40% (60.2 wt%Cl) degradation in 84 days in sludge, 21% degradation in 105 days in river water
                           Van Ginkel and Louwerse
                                     2010b
                         C14 41.3,45.5, 50, 60 wt% Cl
                                 Batch reactor
                                21 and 105 days
41.3 wt% Cl: 79% degradation in 21 days and 94% at 105 days.
50 wt% Cl: 14% degradation by
21 days, 5 % in 80 days. 60 wt% Cl <10% degradation in 80 days based on quantitation of released chloride
Conclusions: Quantification of degradation was by oxygen uptake or chloride release. No information on the chemical distribution in the test material or degradates was provided.

These studies used modified test conditions to enhance or maximize biodegradation. Under these modified test conditions, C14 41.3 wt% Cl and a C14 45.5 wt% Cl substances are readily biodegradable. More highly chlorinated and longer carbon chain CPs  (C14-17 51.7 wt% Cl, C14 55 wt% Cl, C14 60.2 wt% Cl, and C14-17  63.2 wt% Cl) biodegraded over a range of 2  -  54% in 28 days to 4  -  57% at up to 60 days. The most highly chlorinated, (C14-17   63.2 wt% Cl) biodegraded 5% in 28 days and 10% at 60 days in the enhanced biodegradation studies, suggesting that longer chain and higher chlorination can contribute to greater persistence under most environmental conditions.
                                  Van Ginkel
                                     2014b
                                C15 51 wt% Cl
                             Closed bottle (301D)
                                    60 day
43% and 63% degradation at 28 and 60 days
                                  Van Ginkel
                                     2014a
                                 C15 51wt% Cl
                              Closed bottle (301)
                                    60 day
37% and 57% degradation at 28 and 60 days
Conclusions: Unlike the 2010 series of studies, these most recent biodegradation studies did not have significant protocol modifications and the C15 51 wt% Cl were found to be inherently degradable and possibly readily degradable in OECD 301 and 301D tests.
                              Madeley and Birtley
                                     1980
                        C14-17 mixed product, 40 wt% Cl
                                   BOD test
                                    25 days
Approximately 15.5% degradation as measured by theoretical BOD in non-acclimated samples and 22.5% degradation in acclimated samples.[1]
                              Madeley and Birtley
                                     1980
                        C14-17 mixed product, 45 wt% Cl
                                   BOD test
                                    25 days
Approximately 10% degradation as measured by theoretical BOD in non-acclimated samples and 30% degradation with acclimated soil microbes added.[1]
                              Madeley and Birtley
                                     1980
                        C14-17 mixed product, 52 wt% Cl
                                   BOD test
                                    25 days
Approximately 4% degradation as measured by theoretical BOD in non-acclimated samples and 6% degradation with acclimated soil microbes added.[1]
                              Madeley and Birtley
                                     1980
                        C14-17 mixed product, 58 wt% Cl
                                   BOD test
                                    25 days
No significant degradation
Conclusions: The data from Madeley and Birtley suggests the potential for biodegradation but has significant limitations. The BOD studies were done on mixed products. No attempt was made to determine which specific congeners were degraded or the reaction products. No identification of the congeners present was provided. The degradation was estimated from the BOD but other compounds may have contributed to the ThBOD in the bottles. BOD measurements are highly variable as evidenced by the decrease in the C20-30 42% of > 50% between day 20 and 25.

[1]The ThOD (theoretical oxygen demand) was estimated (ThOD (g O2/g substance) = 16[2xc+0.5x(h-cl)]/mw; where c=number of carbon atoms, h=number of hydrogen atoms, cl=number of chlorine atoms and MW = molecular weight). This is questionable for a product containing mixture of congeners as was used in all studies.
                                     LCCPs
                              Madeley and Birtley
                                     1980
                        C20-30 mixed product, 42 wt% Cl
                                   BOD test
                                    25 days
Approximately 7.5% degradation as measured by theoretical BOD in non-acclimated samples and 23% degradation with acclimated soil microbes added.[1]
                              Madeley and Birtley
                                     1980
                       C25 "chlorinated pentacosane"
                            [14]C on central carbon
                                8 weeks (mean)
11% of [14]C- released as CO2. Non-acclimated microbes.
Conclusions: The data from Madeley and Birtley suggests the potential for biodegradation but has significant limitations. The BOD studies were done on mixed products. No attempt was made to determine which specific congeners were degraded or the reaction products. No identification of the congeners present was provided. The degradation was estimated from the BOD but other compounds may have contributed to the ThBOD in the bottles. BOD measurements are highly variable as evidenced by the decrease in the C20-30 42% of > 50% between day 20 and 25.

[1]The ThOD (theoretical oxygen demand) was estimated (ThOD (g O2/g substance) = 16[2xc+0.5x(h-cl)]/mw; where c=number of carbon atoms, h=number of hydrogen atoms, cl=number of chlorine atoms and MW = molecular weight). This is questionable for a product containing mixture of congeners as was used in all studies.
                                  Hildebrecht
                                     1972
                        C20-30 mixed product, 42 wt% Cl
                                   BOD test
                                    5 days
25% degradation. Degradation was estimated by the authors as the% of the theoretical BOD based on the total carbon content of the test solution. Substances other than the chlorinated paraffin contributed to this total carbon content.
                                  Hildebrecht
                                     1972
                     > C20-30 mixed product, 70 wt% Cl
                                   BOD test
                                    5 days
2% degradation. Degradation was estimated by the authors as the% of the theoretical BOD based on the total carbon content of the test solution. Substances other than the chlorinated paraffin contributed to this total carbon content.
                                  Hildebrecht
                                     1972
                     > C20-30 mixed product, 70 wt% Cl
                                   BOD test
                                    5 days
65% degradation. Degradation was estimated by the authors as the% of the theoretical BOD based on the total carbon content of the test solution. Substances other than the chlorinated paraffin contributed to this total carbon content.
Conclusions: As described by the (EA, 2009), Hildebrecht's results are questionable (Hildebrecht, 1972). This report is not available so it cannot be reviewed directly, but others have reported that it provided limited details. A surfactant, other carbon sources, and nutrients were added that may have contributed BOD. The extent of degradation was determined by the comparing the oxygen consumption in the test with the theoretical oxygen demand (ThOD) based on oxidation to CO2 of the total organic carbon present in the solution from all sources. This estimation of ThOD does not take into account oxygen consumption by other compounds or the unknown composition. Of the CPs in the mixture, as the UK report concludes, "It is not possible to draw definite conclusions as to the degradability of the chlorinated paraffins in these tests" (EA, 2009).
                                  Hoechst AG
                                 1976 and 1977
                               C18-20, 35 wt% Cl
                                   BOD test
                                    5 days
                               0.7% degradation
                                  Hoechst AG
                                 1976 and 1977
                               C18-20, 44 wt% Cl
                                   BOD test
                                    5 days
                             < 1.2% degradation
                                  Hoechst AG
                                 1976 and 1977
                               C18-20, 49 wt% Cl
                                   BOD test
                                    5 days
                             < 2.3% degradation
                                  Hoechst AG
                                 1976 and 1977
                               C18-20, 52 wt% Cl
                                   BOD test
                                    5 days
                             < 0.6% degradation
Conclusions: The Hoechst reports from early industry studies are not available so it is not possible to directly review the data (Hoechst, 1976, 1977). Others (EA, 2009) have reported the limitations of the studies. Limited details of the studies were apparently reported by Hoechst. These tests were done on mixtures of congeners with unknown composition. They reported that the majority of the CPs were removed by sorption on to the solids so no degradation may have occurred that would have been detected as BOD. The tests were run for 5 days using non-acclimated sludge microbes so degradation may have been possible but had not yet occurred.
                                 Omori et al.
                                     1987
                         C24.5H44.5Cl6.5, 40.5 wt% Cl
                               Chloride release
                                   48 hours
9.9% degradation using bacterial strain HK-3;
13% H15-4;
2.2% HK-6;
3.5% HK-8;
33% using mixed bacterial culture (HK-3, HK-6, HK-8 and HK-10)
                                 Omori et al.
                                     1987
                            C24.5H41Cl10, 50 wt% Cl
                               Chloride release
                                   48 hours
3% degradation using bacterial strain HK-3;
9% H15-4;
1.8% HK-6;
2.6% HK-8
                                 Omori et al.
                                     1987
                            C24.5H30Cl21, 70 wt% Cl
                               Chloride release
                                   48 hours
2.6% degradation using bacterial strain HK-3;
12% H15-4;
1.4% HK-6;
1.7% HK-8;
15% using mixed bacterial culture (HK-3, HK-6, HK-8 and HK-10)
Conclusions: Omori et al. (1987) showed the potential for biodegradation using pure and mixed cultures in short (48 hour) incubations. No information on the starting mixtures were provided except average compositions. No data on the products were reported. Loss of Cl suggests dechlorination can occur and that lower Cl content or shorter chain lengths may be produced.
                             Allpress and Gowland
                                     1999
                               C18-20, 48 wt% Cl
                               Chloride release
                                    71 days
                11% degradation using Rhodococcus sp. bacteria
                             Allpress and Gowland
                                     1999
                              C> 20, 42 wt% Cl
                               Chloride release
                                    71 days
                14% degradation using Rhodococcus sp. bacteria
Conclusions: Allpress and Gowland (1999) also showed that CPs have the potential to biodegrade using pure culture. They used mixed congener products and did not provide any information on the composition of the starting material or the degradation products. They found that the Rhodococcus sp. was able to use CPs as carbon source as well as an energy source.
[1]The ThOD (theoretical oxygen demand) was estimated (ThOD (g O2/g substance) = 16[2xc+0.5x(h-cl)]/mw; where c=number of carbon atoms, h=number of hydrogen atoms, cl=number of chlorine atoms and MW = molecular weight). This is questionable for a product containing mixture of congeners as was used in all studies.

 BIOCONCENTRATION AND BIOACCUMULATION
EPA/OPPT's review of measured data on bioaccumulation of MCCPs are somewhat limited and conclusions vary with type of CP mixture and species evaluated (Bengtsson et al., 1979; CPC, 1980, 1983a, 1983b; Fisk et al., 1999; Fisk et al., 1998; Houde et al., 2008; Madeley and  Maddock, 1983a, 1983b; Madeley and  Thompson, 1983; Renberg et al., 1986; Thompson et al., 2000).

The limited measured data on MCCPs and LCCPs, informed by data on SCCPs, suggests that bioaccumulation is a function of chain length and degree of chlorination (see Table_Apx A-3). Some MCCP chemicals with intermediate chain length and chlorination may be absorbed and retained. The available evidence for MCCP congeners with intermediate chain lengths and chlorination suggests that some may have BCFs or BAFs greater than 1000 or 5000 (EC, 2008b; ECB, 2008). This suggests that some congeners in MCCP product mixtures may be bioaccumulative or very bioaccumulative.

Additional evidence for bioaccumulation of MCCPs is provided by Houde et al. (2008). Field-derived log BAFs for MCCPs (C14-15), ranging from 6.5 to 7.3, were reported for several Lake Ontario aquatic species from multiple trophic levels. Canada's assessment of MCCPs also indicates that modeled BAFs for a number of MCCPs (using the Modified Gobas BAF Model with assumption of no metabolism), were all above 5000, suggesting high to very high bioaccumulation (EC, 2008a). Evidence of bioaccumulation in sediment-dwelling organisms is also provided in a study by Fisk et al. (1998). Biota-sediment accumulation factors (BASFs) ranging from 0.6 to 4.4 were reported for oligochaetes, which indicate bioaccumulation of MCCPs from sediment to biota (USEPA, 2009).

The Houde et al. (2008) study also provides evidence of biomagnification of MCCPs. BMFs derived for food chains in Lake Ontario and Lake Michigan ranged from 1 to 15. More specifically, large BMFs were observed for all MCCP chain lengths in Lake Ontario, and for C14 MCCPs in Lake Michigan, indicating biomagnification. BMFs (2.4  -  7.7) were also above 1 for smelt and lake trout in Lake Michigan.

In laboratory studies with rainbow trout and oligochaetes, lipid-normalized equilibrium BMFs estimated from a first-order bioaccumulation model for constant dietary exposure ranged from 0.4 - 5.0 (Fisk et al., 1996; Fisk et al., 2000; Fisk et al., 1998).

Most of the laboratory-based BCF studies (Bengtsson et al., 1979; CPC, 1980, 1983a, 1983b; Fisk et al., 1999; Fisk et al., 1998; Houde et al., 2008; Madeley and  Maddock, 1983a, 1983b; Madeley and  Thompson, 1983; Renberg et al., 1986; Thompson et al., 2000), were reported to have been conducted at MCCPs concentrations above the water solubility limit and hence likely underestimate the true BCF. Furthermore, acetone was used as a solvent in these tests, so they do not adhere to OECD guidelines. Nonetheless, some BCF values estimated from these studies indicate MCCPs are bioaccumulative (e.g., bleak and rainbow trout (32-2856) and BCF of 6920 for common mussel).

Based on these studies and estimated upper trophic level bioaccumulation factors, EPA has identified constituents including C14 51% Cl and C14 63% Cl and C18 30% Cl through C18 70% Cl as potentially bioaccumulative or very bioaccumulative. Further discussion of these findings can be found in Table _Apx A-3: Review of MCCP and LCCP Bioaccumulation Studies and Table_Apx A-4: Estimated BCF/BAF Values for MCCP and LCCP Constituents C14-C20 30 - 70 wt % Cl.

Table_Apx A-3: Review of MCCP and LCCP Bioaccumulation Studies

Conclusion for Table_Apx A-3: Based on these studies, EPA has identified constituents including C14 51% Cl and C14 63% Cl as potentially bioaccumulative or very bioaccumulative.

Table_Apx A-3: Bioaccumulation studies on MCCPs (C14-17) and LCCPs (> C18)
                                     MCCPs
                                 Study Authors
                               Publication Date
              MCCP/LCCP Chemicals Evaluated (i.e., C-length,% Cl)
                                    Method
                                Study Duration
                      Noteworthy Results and Implications
Houde et al.
2008
C14-15 Only
BAF = ([predator]/[water (filtered)]);

BMF) = [predator]/[prey]) where the concentrations in predator and prey are on a lipid basis
Three sampling periods: October 2000, June 2002, and
July 2004.
Issues related to the temporal variability of water concentrations over the period of biota sampling (1999  -  2004) in this study have been raised (ECB, 2005; EC, 2008) contributing to uncertainties associated with the reported BAF values.

Log BAF =
Plankton: C14=6.2; C15=6.6; ∑=6.5
Alewife: C14=7.0; C15=6.8; ∑=6.9
Sculpin: C14=7.4; C15=7.2; ∑=7.3
Rainbow smelt: C14=7.4; C15=7.1; ∑=7.2
Lake trout: C14=6.8; C15=6.5; ∑=6.6

BMF (Lake Ontario) =
0.25 (lake trout  -  alewife);
0.14  (lake trout  -  smelt);
8.7 (sculpin  - Diporeia)

BMF (Lake Michigan) =
0.22 (lake trout  -  alewife);
0.94 (lake trout  -  sculpin);
0.88 (sculpin  -  Diporeia)
Thompson et al.; as summarized in ECB, 2005
2000
n-pentadecane-8-[14]C, 51% Cl mixed with a non-radio-labelled C14-17, 51% Cl chlorinated paraffin
Freshwater; flow-through; acetone solvent used;
35 days
Steady-state may not have been achieved, so kinetic BCF data considered more reliable.

BCF = 860 L/kg at 35 days when exposed at 0.9 ug/L
BCF = 265 L/kg at 35 days when exposed at 4.9 ug/L
kinetic BCF = 1,087 L/kg at 35 days when exposed at 0.9 ug/L
kinetic BCF = 349 L/kg at 35 days when exposed at 4.9 ug/L
CPC (Madeley et al.); as  summarized in ECB, 2005
1983
commercial product mixed with a n-pentadecane-8-[14]C chlorinated to a similar degree
freshwater; flow-through; rainbow trout; acetone solvent used
60 days
Concentrations above water solubility; hence, water concentrations may be overestimated and BCF underestimated.
Uncertainty as to whether steady-state was reached.

BCF = 32-45 l/kg on a wet weight basis when exposed at 1.05 mg/l;
BCF = 42-67 l/kg on a wet weight basis when exposed at the 4.5 mg/l
CPC (Madeley and Pearson); as summarized in ECB, 2005
1980
C14-17, 45% Cl
freshwater; flow-through; rainbow trout;
28 days
Measured water concentrations questionable; water concentrations may be overestimated and BCF underestimated.

BCF = 50-60 l/kg based on nominal exposure concentrations
BCF = 280-600 l/kg based on measured water concentrations
Madeley and Maddock; as summarized in ECB, 2005
1983
Total  MCCPs
Bioconcentration factors. MCCPs concentrations were above the water solubility limit, using acetone as the co-solvent in the test solutions, and hence are not in compliance with OECD guideline requirements
No Information
BCF = 32  -  2856 for common mussel, bleak and rainbow trout. May not have reached steady-state.
Fisk et al.

1999
Average formula: C14H23.3Cl6.7, 55% Cl
freshwater; medaka eggs
20-days
Uncertainty as to whether steady-state was reached; hence BCFs probably represent lower limit of true value

BCF = 32- 680 L/kg
Fisk et al.
1998
[14]C16  35% Cl and [14]C16  69% Cl
Lake sediments were spiked and worms added after 18 and 32
No Information
Kinetic BAF probably represents the
upper limit of the true bioaccumulation factor

[14]C16  35% Cl
14-day BSAFss = 0.7
Kinetic BSAF = 4.4

[14]C16  69% Cl
14-day BSAFss = 0.2
Kinetic BSAF = 0.6

Bengtsson et al.

1979
C14-17, 50% Cl
seawater; semi-static; bleak;
acetone solvent used
14 days
Measured water concentrations questionable; water concentrations may be overestimated and BCF underestimated.

BCF  40 L/kg
Madeley and Thompson; as summarized in ECB, 2005
1983
commercial C14-17, 52% Cl
seawater; flow-through; mussel
acetone solvent used
60 days
BCFs = 2,182 L/kg (parent compound analysis) or 2,856 L/kg ([14]C-measurements) when exposed to 0.22 mg/l

BCF = 339 L/kg (parent compound analysis) or 429 l/kg ([14]C measurements)
when exposed to 3.8 mg/l.
Renberg et al.
1985
C16H30.7Cl3.3 (34% Cl) and C12H16Cl9.8 (68.5% Cl) mixture synthesized with [14]C radiolabel
Flow through exposure to mussel (Mytilus edulis)
C16 - 0.13 and 5.0 ug/L
C16 - 28 day uptake
C12 - 21 day uptake followed by 28 day depuration
Steady state BCF about 7000 for C16 and 140,000 for C12 based on 14C quantification.
No chemical specific analysis for CPs. Metabolism and accumulation of degradation products may have accounted for high values.
                                     LCCPs
Bengtsson et al.; as summarized in ECB, 2005

1979
C18 - 26
concentrations were above the water solubility limit and hence are not in compliance with OECD guideline requirements
No Information
Concentrations above water solubility; hence, water concentrations may be overestimated and BCF underestimated. Uncertainty as to whether steady-state was reached.

BCF reported  = 8  -  16 L/kg

Table_Apx A-4: Estimated BCF/BAF Values for MCCP and LCCP Constituents

Very limited data were found on BCF/BAF for MCCPs and LCCPs. To supplement available data EPA estimated BCFs and BAFs for individual constituents of the MCCPs using the Arnot-Gobas BCF and BAF model in EPISuite. The Arnot-Gobas model estimates steady-state bioconcentration factor (BCF; L/kg) and bioaccumulation factor (BAF; L/kg) values for non-ionic organic chemicals in three general trophic levels of fish (i.e., lower, middle and upper) in temperate environments. The model calculations represent general trophic levels (i.e., not for a particular fish species) and are derived for "representative" environmental conditions (e.g., dissolved and particulate organic carbon content in the water column, water temperature). Thus, it provides general estimates for these conditions in absence of site-specific measurements or estimates. The model includes mechanistic processes for bioconcentration and bioaccumulation such as chemical uptake from the water at the gill surface (BCFs and BAFs) and the diet (BAFs only), and chemical elimination at the gill surface, fecal egestion, growth dilution and metabolic biotransformation. Other processes included in the calculations are bioavailability in the water column (only the freely dissolved fraction can bioconcentrate) and absorption efficiencies at the gill and in the gastrointestinal tract. The model requires the octanol-water partition coefficient (KOW) of the chemical and the normalized whole-body metabolic biotransformation rate constant (kM, N; /day) as input parameters to predict BCF and BAF values. The required kM, N value must be normalized to a fish of 10 g.

Table_Apx A-4: Estimated BCF/BAF Values for MCCP and LCCP Constituents C14-C20 30 - 70 wt % Cl[1]

                                    Formula
                                    Log BCF
                                   Log P (E)
                                 t 1/2 (days)
                                   Log BAF
                                    SMILES
                                     % Cl

                                   Upper TL
                                   Middle TL
                                   Lower TL

C14Cl2
3.2
7.6
15
5.0
5.1
5.3
CC(Cl)CCCCCCCCCC(Cl)CC
27
C14Cl3
3.2
7.8
20
5.2
5.2
5.3
CC(Cl)CCCCC(Cl)CCCCC(Cl)CC
35
C14Cl4
3.1
7.9
27
5.4
5.4
5.4
CC(Cl)CC(Cl)CC(Cl)CC(Cl)CCCCCC
42
C14Cl5
3.0
8.1
33
5.4
5.4
5.4
CC(Cl)CC(Cl)CC(Cl)CC(Cl)CCC(Cl)CCC
48
C14Cl6
3.5
8.3
46
5.6
5.5
5.4
CC(Cl)CC(Cl)C(Cl)CC(Cl)C(Cl)CC(Cl)CCCC
53
C14Cl7
3.4
8.5
55
5.6
5.4
5.3
CC(Cl)CC(Cl)C(Cl)C(Cl)CC(Cl)CC(Cl)CC(Cl)CC
56
C14Cl8
3.3
8.7
71
5.6
5.4
5.3
CC(Cl)CC(Cl)C(Cl)C(Cl)C(Cl)CC(Cl)CC(Cl)C(Cl)CC
60
C14Cl9
3.2
8.8
92
5.6
5.4
5.2
CC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC(Cl)CC(Cl)C(Cl)CC
63
C14Cl10
3.1
9.0
120
5.6
5.4
5.2
CC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC(Cl)C(Cl)C(Cl)C(Cl)CC
65
C14Cl11
3.0
9.2
155
5.6
5.3
5.1
CC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC
68
C14Cl12
2.9
9.5
209
5.5
5.2
5.0
C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC
70
C15Cl3
2.9
8.3
27
5.2
5.2
5.2
CCC(Cl)CCCCCC(Cl)CCC(Cl)CCC
34
C15Cl4
2.8
8.4
35
5.2
5.2
5.2
CCC(Cl)CC(Cl)CCCC(Cl)CCC(Cl)CCC
40
C15Cl5
2.7
8.7
47
5.3
5.2
5.1
C(Cl)CC(Cl)CC(Cl)CCCC(Cl)CCC(Cl)CCC
46
C15Cl6
2.7
8.8
58
5.4
5.2
5.1
CCC(Cl)CC(Cl)CC(Cl)CC(Cl)CC(Cl)CC(Cl)CC
51
C15Cl7
3.2
9.0
76
5.4
5.2
5.0
CCC(Cl)CC(Cl)C(Cl)C(Cl)CC(Cl)CC(Cl)CC(Cl)CC
55
C15Cl8
3.1
9.2
98
5.4
5.1
5.0
CC(Cl)CC(Cl)CC(Cl)CC(Cl)CC(Cl)C(Cl)C(Cl)C(Cl)CC
58
C15Cl9
3.0
9.3
127
5.4
5.1
4.9
CC(Cl)CC(Cl)C(Cl)C(Cl)CC(Cl)CC(Cl)C(Cl)C(Cl)C(Cl)CC
61
C15Cl10
2.9
9.5
165
5.3
5.0
4.8
CC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC(Cl)CC(Cl)C(Cl)C(Cl)C(Cl)CC
64
C15Cl11
2.8
9.7
213
5.3
5.0
4.7
CC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC(Cl)C(Cl)C(Cl)C(Cl)CC
66
C15Cl12
2.7
9.9
276
5.2
4.9
4.6
CC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC
68
C15Cl13
2.6
10.1
>1yr
5.1
4.7
4.5
C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC
70
C16Cl3
2.7
8.7
40
5.1
5.0
5.0
CC(Cl)CCCCCC(Cl)CCCC(Cl)CCCC
32
C16Cl4
2.6
8.9
52
5.2
5.0
4.9
CC(Cl)CCC(Cl)CCC(Cl)CCCC(Cl)CCCC
39
C16Cl5
2.5
9.1
62
5.1
4.9
4.8
CC(Cl)CCC(Cl)CCC(Cl)CCCC(Cl)CC(Cl)CC
44
C16Cl6
2.4
9.3
87
5.2
5.0
4.8
CC(Cl)CC(Cl)CC(Cl)CC(Cl)CC(Cl)CC(Cl)CCCC
49
C16Cl7
2.3
9.5
104
5.11
4.9
4.7
CC(Cl)CC(Cl)CC(Cl)CCC(Cl)C(Cl)CC(Cl)C(Cl)CCC
53
C16Cl8
2.8
9.6
135
5.1
4.8
4.6
CC(Cl)C(Cl)CC(Cl)C(Cl)C(Cl)CCC(Cl)CC(Cl)CC(Cl)CC
56
C16Cl9
2.7
9.8
175
5.1
4.8
4.5
CC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CCC(Cl)CC(Cl)CC(Cl)CC
59
C16Cl10
3.0
9.3
127
5.4
5.1
4.9
CC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CCC(Cl)C(Cl)CC(Cl)CC
62
C16Cl11
2.6
10.2
294
4.9
4.6
4.4
CC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CCC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC
64
C16Cl12
2.5
10.4
>1yr
4.8
4.5
4.2
CC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC(Cl)CC
66
C16Cl13
2.4
10.6
>1yr
4.7
4.4
4.1
CC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC
68
C16Cl14
2.3
10.8
>1yr
4.6
4.2
3.9
C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC(Cl)C(Cl)C
70
C17Cl3
2.4
9.2
51
4.8
4.7
4.6
CC(Cl)CCCCCCCC(Cl)CCCC(Cl)CCC
31
C17Cl4
2.4
9.4
66
4.9
4.7
4.6
CCC(Cl)CCCC(Cl)CCCCC(Cl)CC(Cl)CCC
37
C17Cl5
2.3
9.6
86
4.9
4.6
4.5
CC(Cl)CC(Cl)CCCC(Cl)CCCC(Cl)CCC(Cl)CC
43
C17Cl6
2.2
9.8
111
4.9
4.6
4.4
CC(Cl)CC(Cl)CC(Cl)CC(Cl)CCCC(Cl)CCC(Cl)CC
48
C17Cl7
2.1
10.0
144
4.8
4.5
4.4
CC(Cl)CC(Cl)CC(Cl)CC(Cl)CCC(Cl)CC(Cl)CC(Cl)CC
52
C17Cl8
2.0
10.1
186
4.8
4.5
4.3
CC(Cl)CC(Cl)CC(Cl)CCC(Cl)CC(Cl)CC(Cl)C(Cl)C(Cl)CC
55
C17Cl9
2.5
10.3
241
4.7
4.4
4.2
CC(Cl)CC(Cl)CC(Cl)CC(Cl)CC(Cl)CC(Cl)C(Cl)C(Cl)C(Cl)CC
58
C17Cl10
2.4
10.5
313
4.6
4.3
4.1
CC(Cl)CC(Cl)CC(Cl)C(Cl)C(Cl)CC(Cl)CC(Cl)C(Cl)C(Cl)C(Cl)CC
61
C17Cl11
2.3
10.7
>1yr
4.5
4.2
3.9
CC(Cl)C(Cl)C(Cl)CC(Cl)C(Cl)C(Cl)CC(Cl)CC(Cl)C(Cl)C(Cl)C(Cl)CC
63
C17Cl12
2.2
10.9
>1yr
4.4
4.1
3.8
CC(Cl)C(Cl)C(Cl)CC(Cl)C(Cl)C(Cl)CC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC
65
C17Cl13
2.2
11.0
>1yr
4.3
4.0
3.7
CC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC
67
C17Cl14
2.1
11.2
>1yr
4.2
3.8
3.6
CC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC
69
C17Cl15
1.9
11.5
>1yr
4.0
3.6
3.4
C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC
70
C18Cl3
2.2
9.7
76
4.7
4.5
4.3
CC(Cl)CCCCCCC(Cl)CCCC(Cl)CCCCC
 30
C18Cl4
2.1
9.9
99
4.7
4.4
4.2
CC(Cl)CC(Cl)CCCCC(Cl)CCC(Cl)CCCCCC
 36
C18Cl5
2.0
10.1
118
4.6
4.3
4.1
CC(Cl)CC(Cl)CC(Cl)CCCCCC(Cl)CCCC(Cl)CC
 42
C18Cl6
1.9
10.3
153
4.6
4.3
4.1
CC(Cl)CC(Cl)CCC(Cl)CC(Cl)CCCC(Cl)CC(Cl)CCC
 46
C18Cl7
1.8
10.4
198
4.5
4.2
4.0
CC(Cl)CC(Cl)CC(Cl)CCC(Cl)CCC(Cl)CC(Cl)CC(Cl)CC
 50
C18Cl8
1.8
10.6
257
4.4
4.1
3.9
CC(Cl)CC(Cl)CC(Cl)CCCC(Cl)CC(Cl)CC(Cl)C(Cl)C(Cl)CC
 54
C18Cl9
1.7
10.8
332
4.4
4.0
3.8
CC(Cl)CC(Cl)CC(Cl)CC(Cl)C(Cl)CC(Cl)CC(Cl)C(Cl)CC(Cl)CC
 57
C18Cl10
2.2
11.0
>1yr
4.3
3.9
3.7
CC(Cl)CC(Cl)CC(Cl)C(Cl)CC(Cl)CC(Cl)C(Cl)C(Cl)C(Cl)CC(Cl)CC
 59
C18Cl11
2.1
11.2
>1yr
4.2
3.8
3.5
CC(Cl)CC(Cl)C(Cl)C(Cl)C(Cl)CC(Cl)C(Cl)C(Cl)CC(Cl)C(Cl)CC(Cl)CC
 62
C18Cl12
2.0
11.4
>1yr
4.0
3.6
3.3
C(Cl)C(Cl)CC(Cl)CC(Cl)C(Cl)CC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC(Cl)CC
 64
C18Cl13
1.9
11.6
>1yr
3.8
3.5
3.2
C(Cl)C(Cl)CC(Cl)C(Cl)C(Cl)CC(Cl)C(Cl)CC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC
 66
C18Cl14
1.8
11.8
>1yr
3.7
3.3
3.1
C(Cl)C(Cl)C(Cl)C(Cl)CC(Cl)C(Cl)C(Cl)C(Cl)CC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC
 67
C18Cl15
1.7
12.0
>1yr
3.5
3.2
2.9
C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC
 69
C18Cl16
1.6
12.1
>1yr
3.4
3.0
2.8
C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)CC(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C(Cl)C
 70
C19Cl3
2.0
9.7
76
4.7
4.5
4.3
CC(Cl)CCCCCCC(Cl)CCCC(Cl)CCCCC
 30
C19Cl4
1.8
9.9
99
4.7
4.4
4.2
CC(Cl)CC(Cl)CCCCC(Cl)CCC(Cl)CCCCCC
 36
C18Cl5
1.8
10.1
118
4.6
4.3
4.1
CC(Cl)CC(Cl)CC(Cl)CCCCCC(Cl)CCCC(Cl)CC
 42
C19Cl5
1.8
10.6
176
4.3
4.0
3.8
CC(Cl)CCCC(Cl)CC(Cl)CC(Cl)CCCC(Cl)CCCCC

C19Cl6
1.7
10.8
237
4.2
3.9
3.6
C(Cl)C(Cl)CCCC(Cl)CC(Cl)CC(Cl)CCCC(Cl)CCCCC
 46
C19Cl7
1.6
10.9
273
4.2
3.8
3.6
CC(Cl)CC(Cl)CC(Cl)CCCC(Cl)CCC(Cl)CC(Cl)CC(Cl)CC
 50
C19Cl8
1.5
11.1
>1yr
4.1
3.7
3.5
CC(Cl)CC(Cl)CC(Cl)CCC(Cl)CCCC(Cl)CC(Cl)C(Cl)C(Cl)CC
 54
C20Cl5
1.5
11.1
242
4.0
3.6
3.4
CC(Cl)CCCC(Cl)CC(Cl)CC(Cl)CCCCC(Cl)CCCCC
 42
C20Cl6
1.4
11.3
326
3.8
3.5
3.2
C(Cl)C(Cl)CCCC(Cl)CC(Cl)CC(Cl)CCCCC(Cl)CCCCC
 46
C20Cl7
1.4
11.4
>1yr
3.8
3.4
3.2
CC(Cl)CC(Cl)CC(Cl)CCCCC(Cl)CCC(Cl)CC(Cl)CC(Cl)CC
 50
C20Cl8
1.3
11.6
>1yr
3.7
3.3
3.1
CC(Cl)CC(Cl)CC(Cl)CCC(Cl)CCCCC(Cl)CC(Cl)C(Cl)C(Cl)CC
 54

[1] USEPA 2012 Estimation Programs Interface Suite (TM) Version 4.11 BCF/BAF V 3.01

 ECOTOXICITY STUDY SUMMARIES

 MCCP ECOTOXICITY DATA
 Acute Fish Toxicity
(1) A series of 96-hour acute fish toxicity studies were conducted by Mayer an Ellersieck (1986) with Paroil 1048 (50-52% Cl, C15H26Cl6) similarly to ASTM (1980). Bluegill sunfish (Lepomis macrochirus) and yellow perch (Perca flavescens) were exposed to the test substance in a flow-through test system and channel catfish (Ictalurus punctatus) and rainbow trout (Oncorhynchus mykiss) were exposed to the test substance in a static test system. Solvent use was not specified for this compound. The average pH level was between 7.4 and 7.5 for all tests. Test temperature was 12 ºC for bluegill sunfish, rainbow trout, and yellow perch and 20 ºC for channel catfish. Dilution water hardness was 44 mg CaCO3/L in the rainbow trout and channel catfish test system and 314 mg CaCO3/L for the bluegill sunfish and yellow perch test system. Reported effect levels are considered to be nominal with LC50 values of >10 mg/L for bluegill sunfish, channel catfish, and yellow perch and >0.011 mg/L for rainbow trout; all values are greatly above the limit of solubility.

                  EPA/OPPT Conclusion
                  Using a weight-of-evidence approach, these studies were considered acceptable to characterize the acute fish toxicity endpoint.
                  96-hr LC50 = NES

(2) A 96-hour acute fish toxicity study was published by Linden et al. (1979). Groups of 10 Bleak (Alburnus alburnus) were exposed to six nominal unspecified concentrations of Cereclor S52[(R)]  (C14-17, 52% Cl), Chloroparaffin huls 40G (C15.5, 40% Cl), and Witaclor 50 (C14-17, 50% Cl) under static test conditions. Salinity was 7 ppt, pH was 7.8, temperature was 10 ºC, and dissolve oxygen was considered by study authors to be satisfactory. EPA/OPPT requires reporting of dissolved oxygen concentrations to determine study adequacy. EPA/OPPT also does not consider the test species, the bleak, a standard test species. The 96-hour fish LC50 values were >10,000 mg/L, >5,000, and >5,000 for Cereclor S52[(R)], Chloroparaffin huls 40G, and Witaclor 50.

                  EPA/OPPT Conclusion
                  Given effect levels observed in Mayer and Ellersieck (1986) and the reported water solubility of medium chain paraffins, these studies were considered acceptable using a weight-of-evidence approach to characterize the acute saltwater fish toxicity endpoint.
                  96-hr LC50 = NES

(3) Bengtsson et al. (1979) also studied the toxicity of a medium-chain chlorinated paraffin to Bleak (Alburnus alburnus) as part of a bioaccumulation study. The chlorinated paraffin tested was a C14-17, 50% wt. Cl substance. The tests were performed at 10 °C using a semi-static procedure in which the test solutions containing 125 μg/L of the substance were renewed every two to three days over the 14-day exposure period. The water used in the experiment was Baltic Sea water with a salinity of 7%., and acetone was present in all aquaria, including controls at a concentration of 0.1 ml/l. The fish used in the experiment had an average weight of 4.5 g and were not fed during the exposure period. Six groups of 15 fish were used for both the exposure and control solutions. No mortality or effect on behavior was seen in fish exposed to the medium-chain chlorinated paraffin during the test.

                  EPA/OPPT Conclusion
                  This data review was part of a BAF study and as such will be used as a weight of evidence to support other data for this category of organisms.

 Acute Aquatic Invertebrate Toxicity
(1) A 48-hour acute Daphnia magna toxicity study was conducted by Thompson et al. (1996) according to OECD TG 202 (1984) with GLP compliance using a static test system. The test substance was identified as Cereclor S52[(R)], a C14-17 chlorinated paraffin with 52% chlorination that contained 0.3% epoxy soya bean oil stabilizer as well as a small amount of radiolabelled n-pentadecane-8-[14]C (51% chlorinated). Four replicates of 5 Daphnia magna Straus (<24 hours old) were exposed to nominal concentrations of 0 (dilution water control), 0 (solvent control), 0.0032, 0.0056, 0.01, 0.018, 0.032, 0.056, and 0.1 mg/L test substance in acetone (0.1 mL/L). Test solutions were prepared by adding the appropriate stock solution to dilution water while continuously and vigorously stirring with a magnetic follower. Appearance of test solutions was not provided. Corresponding mean measured concentrations determined by radiochemical methods were 0.0025, 0.0041, 0.0094, 0.015, 0.024, 0.047, and 0.095 mg/L. Daphnid loading was 25 daphnids/L. Over the course of the study dissolved oxygen concentrations remained between 9 and 9.2 mg/L, pH remained within 8 and 8.1, and temperatures were 20 +-1 ºC. Dilution water had a total water hardness of 248 mg CaCO3/L. At 48 hours, 0%, 45%, 90%, 75%, 85%, 100%, and 100% immobilization was observed at the mean measured concentrations of 0.0025, 0.0041, 0.0094, 0.015, 0.024, 0.047, and 0.095 mg/L, respectively. Red coloration on parts of the exoskeleton was observed in animals exposed to each of the test substance treatments, which the laboratory notes as being of an uncertain significance.

                  EPA/OPPT Conclusion
                  The study is acceptable.
                  48-hr EC50 = 0.0059 mg/L

(2) A 48-hour acute Daphnia magna toxicity study was conducted the University of Bremen, Department of Physical and Environmental Chemistry with CP 52 (C12-18, 52% chlorination) according to DIN 38412 by Koh and Thiemann (2001). Study methods were not fully characterized. Additional communications with the study author Wolfram Thiemann clarified that a static test system was used with nominal test concentrations. Based on communications with the study author, local (Bremen, Germany) tap water was used without adjustments. Presumed pH was between 5 and 6 and water hardness was between 35.7 and 53.5 mg CaCO3/L. Ambient laboratory air temperature was around 21 ºC. The solvent acetone was used to maintain test substance in solution. Floating effects at the surface of the water were observed in individual cases due to undissolved oil slicks, but communications with the study author noted that there was no significant loss of daphnids due to mechanical trapping since most daphnid swam away from these occasional slicks observed at the higher test concentrations.

                  EPA/OPPT Conclusion
                  This study is considered acceptable.
                  48-hr EC50 = 0.052 mg/L

(3) A 48-hour acute Daphnia magna toxicity study was conducted by Thompson et al. (1994) according to OECD TG 202 (1984) with GLP compliance using a static test system. The test substance was identified as Cereclor S52[(R)], a C14-17 chlorinated paraffin with 52% chlorination that was mixed with an equal weight of radiolabeled n-pentadecane-8-[14]C (51% chlorinated). Four replicates of 5 Daphnia magna (<24 hours old) were exposed to 0% (dilution water control), 6.3%, 12.5%, 25%, 50%, and 100% of stock solution containing test substance. The test substance was prepared in solution by (1) combining 0.75 g test substance and 25 mL acetone to a borosilicate glass conical flask, (2) evaporation of the acetone using a stream of nitrogen, (3) addition of 1.5 L dilution water, (4) stirring for three days, and (5) filtration of the aqueous phase. Radiochemical methods were used to determine the concentration of test substance in solution. Nominal concentrations of 0 (dilution water control), 0.14, 0.28, 0.55, 1.1, and 2.2 mg/L were within 86-100% of measured concentrations. Concerns regarding test solution preparation methods and analytical technique were identified by the submitter that included increasing the level of more soluble impurities (i.e., short chain chlorinated paraffins), questionable analytical monitoring results due to the presence of radio-labeled impurities, and abnormally low recovery of the chlorinated paraffin into hexane. Over the course of the study dissolved oxygen concentrations remained between 8 and 9 mg/L, pH remained within 8 and 8.1, and temperatures were 20 +-1 ºC. Dilution water had a total water hardness of 237 mg CaCO3/L. Observed immobilization was limited to the highest test concentration (100% solution) with 55% immobilization.

                  EPA/OPPT Conclusion
                  The study is unacceptable since EPA/OPPT agrees that methods used to prepare the test solution and analyze the test concentrations were questionable.

4) The following study summary (Frank, 1993; Frank and Steinhäuser, 1994) provided in the 2005 European Chemical Bureau Risk Assessment of MCCP was considered supportive of the aquatic invertebrate hazard determination. The chlorinated paraffin used in these studies was a commercial C14-17 product with a 52% by weight chlorine content. Daphnia magna were exposed to nominal concentrations of either 100 mg/L or 10,000 mg/L. The 100 mg/L solution was sonicated for 1 hour and then left to stand in the dark for 48 hours before use. The 10,000 mg/L solution also stood for 48 hours in the dark before use, but this time without sonication. After this period, both solutions were filtered firstly with glass filters and then with membrane filters to remove undissolved test substance. The concentrations of medium-chain chlorinated paraffin in the water soluble fractions were then determined by AOX (adsorbable organic halogen) analysis (detection limit of 10 μg/L Cl was equivalent to around 20 μg/L of the chlorinated paraffin). This analysis showed that the concentration of chlorinated paraffin present in the water soluble fraction was around 0.404-0.500 mg/L for the 10,000 mg/L nominal solution and 0.071-0.142 mg/L L for the 100 mg/L stock solution. The acute (48-hour) toxicity tests were carried out using dilutions of the two prepared water soluble fractions. The method used was DIN 38 412, Teil 11, which is equivalent to OECD 202.

In the tests using the water soluble fraction from the 100 mg/L nominal solutions no toxicity was seen at concentrations up to the undiluted stock solution (i.e. no effects up to around 0.071-0.142 mg/L). In experiments using the water soluble fraction from the 10,000 mg/L stock solution, an EC0 of 0.140 mg/L (also reported as 0.100-0.110 mg/L in the paper) and an EC25 of 0.423 mg/L (also reported as 0.420-0.470 mg/L in the paper) was determined (maximum mortality seen was 25%) (Frank, 1993). The latter results for the 10,000 mg/L stock solution were reported by Frank and Steinhäuser (1994) as EC0 = 0.140 mg/L and EC25 = 0.339 mg/L, and it was noted that some of the Daphnia were floating on the surface of the test solution. In the later study (Frank and Steinhäuser, 1994), the results of further acute toxicity studies were reported using the same test method. An EC50 of 0.037 mg/L and an EC0 of 0.009 mg/L were determined using the water soluble fraction from the 100 mg/L stock solution and no toxic effects were seen in tests with the water soluble fraction from the 10,000 mg/L stock solution (approximately EC0 >=0.525 mg/L). The authors noted that the effects seen in the acute tests showed poor reproducibility, probably because effects were seen only around the water solubility limit of the substance. However, the authors thought that the possibility of undissolved droplets affecting the results could be ruled out, as floating Daphnia were only sporadically observed in the test.

                  EPA/OPPT Conclusion
                  Tthe results of these studies should be treated with caution, as the effects were mainly seen in the saturated solutions only.
                  48-hour EC50 = 0.037 mg/L; 100 mg/L stock  (Frank and Steinhäuser, 1994)

5) The following study summary (Thompson and Gore, 1999) provided in the 2005 European Chemical Bureau Risk Assessment of MCCP was considered supportive of the aquatic invertebrate hazard determination. The acute toxicity of C14-17, 52% wt. Cl substance was tested using the freshwater crustacean Gammarus pulex and the freshwater daphnid, Daphnia magna. The medium-chain chlorinated paraffin used was dissolved in acetone and then added to beakers in two separate studies containing either Gammarus or D. magna to give nominal concentrations of 0.1, 0.32, and 1.0 mg/L. A control and solvent control (containing 0.1 mL/L acetone) were also run. The tests were carried out for 96 hours at 15 ºC, with the solutions being renewed after 48 hours. The water used in the study had a hardness of 220 mg/L as CaCO3 and had a pH of 8.0-9.2. No mortalities of the Gammarus were seen in any of the test substance solutions or control. One animal died in the solvent control. Therefore, no significant toxic effects were seen with the medium-chain chlorinated paraffin over the concentration range tested. This contrasted markedly to the situation when Daphnia magna were exposed using the same test system at 20 ºC over 48 hours, where complete immobilization was seen at the lowest test concentration (0.1 mg/L).

                  EPA/OPPT Conclusion
                  The high immobilization rate observed in Daphnia magna in this study appears consistent with the other studies and Gammarus pulex appear to be a less sensitive to medium chained chlorinated paraffins then Daphnia magna. EPA/OPPT reserves judgment on the acceptability of this study until further details become available.
                  96-hr EC50 (Gammarus pulex) > 1 mg/L
                  48-hr EC50 (Daphnia magna) < 0.1 mg/L

6) The following study summary (Tarkpea et al., 1981; as quoted in WHO, 1996) provided in the 2005 European Chemical Bureau Risk Assessment of MCCP was considered supportive of the aquatic invertebrate hazard determination. The results of tests with the brackish water harpacticoid Nitocra spinipes have been reported (Tarkpea et al., 1981). No other details of the test were reported but the test method was probably the same as reported by Tarkpea et al. (1986), where a static method was employed using water of salinity 7%. at a temperature of 20-22 ºC without aeration, probably using acetone as cosolvent.

                  EPA/OPPT Conclusion
                  The results are considered supportive to address aquatic invertebrate acute toxicity.
                  96-hour LC50 = 9 mg/L (C14-17, 45% wt Cl)
                  96-hour LC50 >10,000 mg/L (C14-17, 52% wt. Cl)

 Algae Toxicity
(1) A 72-hour algae toxicity study was conducted by the University of Bremen, Department of Physical and Environmental Chemistry with CP 52 (C12-18, 52% chlorination) according to DIN 38412 by Koh and Thiemann (2001). Study methods were not fully characterized. Additional communications with the study author Wolfram Thiemann clarified that a static test system was used with nominal test concentrations. Scenedesmus subspicatus were exposed to the test substance and cell density was determined using a particle counter. Based on communications with the study author, local (Bremen, Germany) tap water was used without adjustments. Presumed pH was between 5 and 6 and water hardness was between 35.7 and 53.5 mg CaCO3/L. Ambient laboratory air temperature was around 21 ºC. The solvent acetone was used to maintain test substance in solution. Effects were calculated based on growth rate. No effects were observed up to 0.1 mg/L.

                  EPA/OPPT Conclusion
                  Due to deficiencies/missing details in the study methods, the study alone was not acceptable to characterize aquatic toxicity to plants.
                  72-hr NOEC = 0.1 mg/L (Highest Test Concentration)

(2) A 96-hour algae toxicity study was conducted according to OECD TG 201 (2006). The test substance was a commercial product of a C14-17 chlorinated paraffin with 52% chlorination that contained 0.3% epoxy soya bean oil stabilizer as well as a small amount of radiolabeled n-pentadecane-8-[14]C (51% chlorinated). Selenastrum capricornutum were exposed to nominal concentrations of 0 (dilution water control), 0 (solvent control), 0.1, 0.18, 0.32, 0.56, 1, 1.8, and 3.2 mg/L test substance in the solvent acetone. Six replicates were tested for each control and three replicates were tested for each treatment. A mean measured concentration of 0.49, 0.77, and 1.2 mg/L was determined using radiochemical analysis for the nominal concentrations of 1, 1.8, and 3.2 mg/L, respectively, but effects were reported based on nominal test concentrations. At the start of the test, the pH was 7.4-7.5, but had reached 10.0-10.3 by the end of the test. The shift in pH was thought to be a function of the high control growth rates observed in the test according to the study summary. The section-by-section coefficient of variation for the solvent control remained below 35% indicating acceptable control growth rates throughout the duration of the study.

                  EPA/OPPT Conclusion
                  The maximum inhibition in the growth rate and biomass seen was 3% and 18%, respectively, but a dose response relationship was not seen. The nominal NOEC was 0.1 mg/L and the nominal LOEC based on 18% biomass inhibition was 0.18 mg/L. A GMATC of 0.134 mg/L was calculated. The study was considered acceptable.
                  72-hour EC50 = >3.2 mg/L (nominal); 1.2 mg/L (mean measured).
                  96-hour EC50 = >3.2 mg/L (nominal); 1.2 mg/L (mean measured).
                  72-hr NOECb = 0.1 mg/L
                  72-hr LOECb = 0.18 mg/L
                  72-hr GMATC = 0.134 mg/L
 Chronic Fish Toxicity
(1) A 60-day fish toxicity study was conducted by Brixham Laboratories in 1983 with radio-labeled chlorinated (52%) n-pentadecane (Trade Name: Cereclor S52[(R)] ) under flow through testing conditions. A full non-CBI study report was submitted under TSCA in 1983 as DCN 40-8332184 (OTS Fiche 0507258). Two replicates of 3 immature rainbow trout (Salmo gairdneri) per concentration were exposed to nominal concentrations of 0 (dilution water control), 0 (acetone control, 500 ppm), 1, or 5.6 mg/L in 500 ppm acetone. Corresponding mean measured concentrations were 0, 0, 1.05, and 4.5 mg/L. Test concentrations were determined by radio activity measurements. Flow rate of the test system was 0.25 mL/minute for exposure concentrations. No mortality or adverse sub-lethal behavioral effects were observed for the duration of the 60-day exposure period. Effects observed were limited to the highest test concentration and involved sluggish movements. The measured NOEC was identified as 4.5 mg/L. In addition to the hazard assessment, the submitter provided an assessment of bioconcentration which indicated that analytically determined exposure concentrations of 1.05 and 4.5 mg/L resulted in fish tissue concentrations of 34 and 190 ug/g wet weight, respectively.

                  EPA/OPPT Conclusion
                  This study appears to have been previously reviewed by EPA in 1985. The previous conclusion that "a fish full life cycle toxicity test or modification thereof is needed to address the effects of CPs present in fish eggs during embryonic development" (U.S. EPA Memorandum, 1991) is still relevant for MCCPs. Thus, this study is considered unacceptable to characterize chronic population-level effects in fish.
                  60-day NOEC = 4.5 mg/L

(2) A 28-day fish toxicity study was conducted by Brixham Laboratories in 1978 with a C14-17 chlorinated paraffin having 45% chlorination under unspecified testing conditions. The study report was submitted under TSCA in 1992 as DCN<PHONE_NUMBER>2 (OTS Fiche 0545375). Rainbow trout (Salmo gairdneri) per concentration were exposed to nominal concentrations of 0 (dilution water control), 0.1, or 1 mg/L in acetone. The age and size of the rainbow trout used in the study were not specified in the study. The specific environmental conditions of the test, such as pH, temperature and water quality were not specified in the report. Concentrations of the chlorinated paraffin in the test water were measured using TLC analytical procedures resulting in mean measured concentrations of 0.01 and 0.18 mg/L. Mortality and behavior (response to food, general behavior, swimming behavior and pigmentation) were assessed during the 28-day study. Survival was 96.6 and 100% for the mean measured exposures of 0.01 and 0.18. No behavioral effects were seen over the course of the study.

                  EPA/OPPT Conclusion
                  The study was considered unacceptable to characterize the chronic fish toxicity endpoint since insufficient study details were provided including the age and/or the life-stages of the exposed organisms.

(3) A 20-day Japanese medaka (Oryzias latipes) embryo toxicity study was conducted with the formulation C14H24.9Cl5.1, 48%Cl (composition: 10.5% 1, 2, 13, 14-tetrachlorotetradecane (42.3% Cl); 74.3% x, 1, 2, 13, 14-pentachlorotetradecane (47.7% Cl); 14.2% x, y, 1, 2, 13, 13-hexachlorotetradecane (52.6% Cl); 1.0% x, y, z, 1, 2, 13, 14-heptachlorotetradecane (56.4% Cl)) by Fisk et al. (1999) under static testing conditions. Five sets of 10 vials containing 1 egg each were exposed to nominal concentrations of 0.001, 0.010, 0.100, 1, or 10 mg/L test substance starting after fertilization and terminating approximately 3 days post-hatch. No adverse effects were reported in exposed embryos.

                  EPA/OPPT Conclusion
                  The study was considered unacceptable primarily due to insufficient exposure duration and insufficient number of eggs per exposure concentration.

(4) A 20-day Japanese medaka (Oryzias latipes) embryo toxicity study was conducted with the formulation [14]C-C14H23.3Cl6.7, 55% Cl (composition: 0.2% C14H26Cl4 (42.3% Cl), 4.4% C14H25Cl5 (47.7% Cl), 34% C14H24Cl6 (52.6% Cl), 45% C14H23Cl7 (56.4% Cl), 14% C14H22Cl8 (59.9% Cl), and 1.9% C14H21Cl9 (62.8% Cl)) by Fisk et al. (1999) under static testing conditions. Five sets of 10 vials containing 1 egg each were exposed to measured concentrations of 0.0014, 0.012, 0.120, 0.420, or 1.6 mg/L test substance starting after fertilization and terminating approximately 3 days post-hatch. No adverse effects were reported in exposed embryos. Concentrations of the test substance were found in larvae and eggs in a dose-dependent manner (with exception of the highest concentration) suggesting that the substance can diffuse through the egg. Corresponding measured concentrations in eggs were 0.04, 8.4, 63, 110, and 72 mg/kg and corresponding measured concentrations in larvae were 0.24, 8.2, 45, 84, and 51 mg/L.

                  EPA/OPPT Conclusion
                  The study was considered unacceptable primarily due to insufficient exposure duration and insufficient number of eggs per exposure concentration.

(5) The following summary provided in the 2005 European Chemical Bureau Risk Assessment of MCCP was considered supportive, but did not characterize all fish life-cycle stages. Cooley et al. (2001) studied the toxicity of C14H24.9Cl5.1, 48%Cl (as described in Fisk et al., 1999) to juvenile rainbow trout (Oncorhynchus mykiss) through dietary exposure. Treatment groups of 10 fish were exposed to 0.78 and 2.9 mg/kg for 21 days and 0.082 mg/kg for 85 days. Three control groups were also run. Histological examination and analysis of the chlorinated paraffin concentration was performed in five fish per treatment after 21 days in the two higher test concentrations and in three fish per treatment after 85 days in the lowest test concentration. Three fish were also sacrificed from each low exposure group and the remaining control group (but were not analyzed) after 21 days of exposure. Quantitative histomorphological measurements were also carried out on livers and thyroid of the exposed fish in the middle exposure group after 21 days, and also the low exposure group after 85 days. The parameters investigated included hepatocyte nuclear diameter, hepatocyte volume index, nucleus:cytoplasm
area ratio and thyroid epithelium cell height. Livers displaying mild hepatocyte necrosis and moderate to severe depletion of glycogen/lipids were reported for the 0.78 mg/kg exposure. At 2.9 mg/L abnormal behavior was observed from day 3 onwards. Quantitative effects following 21 days of exposure were limited to a significantly (p=0.05) reduced mean hepatocyte volume in 2.9 mg/L exposure group.

                  EPA/OPPT Conclusion
                  This study is considered unacceptable to characterize chronic mortality in fish because it did not characterize life stages but instead characterized physiological effects.

(6) Cooley et al. (2001) studied the toxicity of another medium chain chlorinated paraffin with a slightly different chemical composition and at slightly different concentration levels. The chemical formula was [14]C-C14H23.3Cl6.7, 55% Cl (as described in Fisk et al., 1999) and was  juvenile rainbow trout (Oncorhynchus mykiss) were exposed through the diet. Treatment groups of 10 fish were exposed to 29 and 78 mg/kg for 21 days and 5.7 mg/kg for 85 days. Three control groups were also run. Histological examination and analysis of the chlorinated paraffin concentration was performed in five fish per treatment after 21 days in the two higher test concentrations and in three fish per treatment after 85 days in the lowest test concentration. Three fish were also sacrificed from each low exposure group and the remaining control group (but were not analyzed) after 21 days of exposure. Quantitative histomorphological measurements were also carried out on livers and thyroid of the exposed fish in the middle exposure group after 21 days, and also the low exposure group after 85 days. The parameters investigated included hepatocyte nuclear diameter, hepatocyte volume index, nucleus:cytoplasm area ratio and thyroid epithelium cell height. At 29 mg/kg abnormal behavior was observed from day 2 onwards and livers exhibited mild to moderate hepatocyte necrosis and moderate to severe depletion of glycogen lipids. Abnormal behavior from day 3 onward was also observed at 78 mg/kg.

                  EPA/OPPT Conclusion
                  This study is considered unacceptable to characterize chronic mortality in fish because it did not characterize life stages but instead characterized physiological effects.

(7)  The Dow Chemical Company (2009)
Study title: Great Stuff(TM) Pond and Stone Waterfall Foam Filler: Evaluation of Potential Prolonged Toxicity to Freshwater Fish. Dow conducted a 14-day exposure of Great Stuff(TM) Pond and Stone Water Foam Filler to the fathead minnow (Pimephales promelas). The test substance used was Great Stuff(TM) Pond and Stone Water Foam Filler which is a urethane foam product dispensed from a pressurized steel canister using a finger-actuated valve/nozzle. Three 12 oz. canisters containing different developmental foam formulations (differing primarily in the colorant additive) were used. The test duration was 14 days and the exposure scenario was a static system which was renewed after 7 days. The test concentrations used were 0.15 and 0.63 g dry foam/: for each product tested and a water control. The test concentrations were equivalent to approximately 10 and 40 times the expected minimum foam loading for a typical pond application. Carrier solvents were not used in the test. The test solution volume was 15 L and the loading was 10 fish/15 L. The three foam samples were directly applied on the inside bottoms of identical 20 L glass aquaria and misted with MilliQ water to promote reaction/adhesion of the foam on the glass surface. The foam was applied along a longitudinal center line of the aquarium bottom, in a single continuous bead of approximately 2 cm diameter. Following application, the aquaria were loosely covered and foam was allowed to cure for 24 hours. After curing, the aquaria were rinsed, and then filled, with laboratory dilution water. Dissolved oxygen levels ranged from 6.8 - 7.9 mg/L (84 - 98% oxygen saturation) over the 14-day exposure period. Temperature, as measured daily from the individual test vessels and continuously measured from one surrogate test vessel, remained at 25°C throughout the study. The pH ranged from 7.1 - 7.7 and the light intensity ranged from 701 - 1,263 lux. Over the 14-day exposure period, no sublethal
effects were observed in any of the treatments and only a single mortality was observed (observed on day 10 in one 40x treatment) and was believed to be incidental and non-treatment related, since no other fish in that test level exhibited signs of stress or sublethal effects during the test. Only DOC concentrations were measured to determine release of foam associated components. After seven days of contact with water, the foam-associated DOC resulting from the "10X" loading ranged from 0.6 to 0.9 mg/L for the three foam samples, and that from the "40X" loading ranged from 1.1 to 2.1 mg/L. None of the three foam products was consistently associated with the lowest or highest foam-associated DOC concentration, indicating that the three foam products did not have notable differences in their water-extractable components. The study did not completely characterize the chemical composition of the foam and did not fully identify the chlorinated paraffin composition, thus it is not possible to determine or characterize potential effects from chlorinated paraffin exposure. Only the chain length of the chlorinated paraffin was identified (C14-17) and the % Weight of the chlorinated paraffin in the foam product along with the chlorine content was not identified. Also, many of the components of the foam and % composition were also unidentified. In addition, the study duration was 14-days, a sub-chronic duration, and is not sufficient to characterize chronic population-level effects.
                  EPA/OPPT Conclusion
                  This study is considered unacceptable to characterize chronic population-level effects of MCCPs in fish.

 Chronic Aquatic Invertebrate Toxicity