Document N2w0Bn1qGwwKOeyd6wawboVpb

tM um m sm m m iH *; . TSCA N0N-C0NF1DENTIAL BUSINESS INFORMATION D O CU M EN T D ESCRIPTIO N 8 6 t t f c . - o ' o -\V > V l8 11' J J ' ! '" " U J.tf.M im ! 'L' DOCUMENT CONTROL NUMBER 8 < \\c > o o O o \H ^ DATE RECEIVED 3 l l'o \ \ 0 D 0C 8 NOT CONTAIN CBI M / U k 3 3 .!*y s r i 8EH Q -0 3 1 0 -1 6 4 7 8 L 89100000149 March 15,2010 DuPont Haskell Global Centers for Health and Environmental Sciences 1090 Elkton Road, P.O. Box 50 Newark, DE 19714-0050 Via Federal Express Document Processing Center (Mail Code 7407M) Room 6428 Attention: 8(e) Coordinator Office o f Pollution Prevention and Toxics U.S. Environmental Protection Agency, ICC Building 1201 Constitution Ave., NW Washington, DC 20004 Dear 8(e) Coordinator: Ijik 3 S3 P C ? C3 j-1 3 en X 3C rH 0 C3' O JET \X3 8EHQ-06-16436/8EHQ-06-16478 This letter is to inform you o f the results o f an inherent biodegradation test with the above referenced test substance. This test substance is subject to a Consent Order, PMN P-08-509. The purpose of this test was to evaluate the inherent biodegradability of the test substance via a 28-day test. The test was designed to meet the requirements o f SEPA HJ/T 153-2004, "the guidelines for the testing o f chemicals", OECD Procedure 302C, "Inherent Biodegradability: Modified MITI Test (II), adopted May 1981. In the test, the test substance and micro-organisms not adapted to the test substance were added into the aerobic, aqueous medium in BOD bottles. Test solutions were prepared in an inorganic salts medium, inoculated with a number o f micro organisms collected from 10 places in Nanjing, China, and kept in BOD bottles in the dark at 25C 1C. Then the Biochemical Oxygen Demand (BOD) and residual chemicals in BOD bottles were measured during the 28-day period. Based on the residue analysis, the biodegradation o f the test substance was 0% and there was hardly any change for the test substance in the "abiotic" vessel during the testing period. The BOD results showed that biodegradation of the test substance was both <1% after 14 and 28 days. The test was valid because the level o f biodegradation o f the reference substance aniline exceeded 40% after 7 days, and 65% after 14 days. Therefore, the test substance was not inherently biodegradable under this test condition. This information is submitted in accordance with current guidance issued by EPA indicating EPA's interpretation of Section 8(e) o f the Toxic Substances Control Act or, where it is not clear that reporting criteria have been met, it is submitted as a precautionary measure and because it is information in which EPA may have an interest. Sincerely, A. Michael Kaplan, Ph.D. Director - Regulatory Affairs AMK/WRB: clp (302) 366-5260 8EHQ-06-16478 1 6 4. / O Contains No CBI 89100000149 8 9 1 0000 I 'iV -jh mmmt 4a Express Package Service *To mostlocations. P a ck a g e s up to ISO lbs. FedEx Priority Overnight Next business morning 'Friday shipments! be delivered on Monday unless SATURDAY Delivery is selected r - j J e d E x Standard Overnight N e business afternoon* SaOirdayOetrvaryNOT available FedEx First Overnight Earliest ne business morning deliveryto select locations * Saturday Delivery NOT available. FedEx 2Day Second business day Tfiursday shipmentswill be delivered on Monday unless SATURDAY Delivery is selected. I-- i FedEx Express.Saver Third busmessday* 1-- Saturday DeliveryNOT available, 4b Express Freight Service Fe d ExID ay Freight N e business day * * Fndayshipments will be delivered on Monday unless SATURDAY Deliveryis selected. FedEx 1DayFreightBooking No P a ck a g e s ovar 150 lbs. ,__ , FedEx 2D ay Freight Second business day. Thursday shipments will be delivered I___I on Monday unless SATUROAY Deliveryis selected 5 Packaging PI FedEx -- ' Envelope* *Declared value limit$500. I I FedEx Pak* -- Includes FedEx S.mall Pak, FedEx large Pak, and FedEx Sturdy Pak. FedEx 3Day Freight Third business cay.** Saturdi ay Delivery NOT available I I FedEx Box Q FedEx Tube Q Other 6 Special Handling and Delivery Signature Options n SA T U R D AY Delivery I-- I NOT available for FedEx Standard Overnight, FedEx First Overnight, FedEx Express Saver, or FedEx 3Day Freight N o Signature Required Package maybe leftwithout obtaining s signature tor delivery Direct Signature Someone atrecipient'saddress maysignfordelivery FeeappHes. Does this shipment contain dangerous goods? ------------------ One box must be checked ----------------------- Indirect Signature Ifnooneisavailableatrec, .... address, someone ata neighboring address may sign fordelvery For Faeapphas. No I 1 Asjferattached ( ) Shippers Declaration 1-- I SShtiupnpneer'ssDDeecclalarraattiioonn I--1 1 notreouired Dangerous goodsimcludmg dry ice)cannotbe shipped in FedEx packaging orplaced in a FedEx Express Drop Box I I Dry Ice '-- ' Dryice, 9,Uf I I Cargo Aircraft Only 7 Payment B ill to: , Sender Q T SK d " Enter FedEx A ect No. or Credit Card No. helow. - C U Recipient Q Third Party Q Credit Card Obtain R e a p r-- i A cct N o (__J Q Cash/Check *0ur liabilityis limitedto$100 unless you declare a highervalue. See the currentFedEx Setvice Guidefor details Rev Date2/08*Part#158279>1994-2008FedEx*PRINTED IN U S A *S R S