Document NX7yEMwEVEqRbexxMKpgyzpR
JIM:JOE:TOM:RF XF:
Interoffice Communication
to Distribution
From Tom Grumbles
ate October 13, 1983
Subject CCPTAC MEETING OF OCTOBER 11, 1983
The subject meeting was held in Ponca City with Bill Broddle, Bill Groves, Carl Kerfoot, and myself attending. A meeting agenda is attached. Minutes of the meeting follow.
1. Action items from the April 14 meeting were reviewed. All items have been completed. Discussion was held concerning inhalation and skin testing protocols. Bill Broddle prepared memos concerning these items and testing protocols in general. These were distributed at the meeting. In summary, inhalation testing for surfactant products is generally done infrequently and 24-hour skin exposures should be used when doing skin irritation testing. I will summarize Bill's memos into a concise testing protocol guideline for Conoco Chemicals' products. This will be distributed for review.
2. Toxicology testing results received since the last meeting were reviewed. This included testing on 1214 HA-30, n-550L Sulfonate, n-600L Sulfonate, and ALFOL 4. The ALFOL 4 results were from testing done at Scientific Associates in 1979, however, the report was just received (this is discussed later). A table of these results is attached.
3. Currently the only outstanding testing is the skin irritation comparison work being done on n-550L Sulfonate and other similar commercial products.
No future testing needs are anticipated at this time.
4. Aquatic toxicity testing was discussed in terms of general protocols, recent requests, and available data on Conoco products and in the literature.
Bill Broddle did a literature review and found that there is a fair amount of data in the open literature. A partial summary is attached. Also Conoco does have some "old" data available from work in the '60s and early '70s. In general, requests received over the last six months have been answered by citing data available in the open literature or the A. D. Little SDA report.
There appears to be no specific need to routinely develop aquatic testing data on Chemicals1 products. Specific projects, such as ODC development, can be achieved in a reasonable time frame.
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Distribution Page 2 October 13, 1983
A general principle of aquatic toxicity of surfactant appears to be as follows: Acute toxicity increases with carbon number, however, so does biodegradability. Therefore, overall toxicity or environmental impact is lessened as the carbon number increases.
5. The determination that no tox testing would be necessary for Molex Raffinate if it were made commercial was reviewed. In summary, data on LPA and kerosenes could be used to develop representative statements. (WDB memo to TGG, 8/1/83)
6. The continuing obligation to report under TSCA Section 8(a) as new chemicals are added to the list was discussed. In the recent addition, (CF-R 5/19/83) of 57 chemicals, no chemicals related to our operations were listed.
7. EPA is considering a TSCA Section (4) Test Rule on Cg Aromatics. Based on their definition of Cg streams in the proposed rule it is not yet clear if Ethylene Unit Cg's are included. There is a Cg product at Chocolate Bayou.
8. Recent toxicology study results on 1-3 Butadiene were reviewed. Animal tumors have now been seen at exposures as low as 650 ppm. DuPont has lowered its AEL to 100 ppm. Exposure data at Chocolate Bayou indicates exposure to be below 10 ppm. OSHA is being pressured to lower the current PEL of 1 ,000 ppm.
9. Marshall Thomas Inc., Lexington, KY asked to negotiate reimbursement for use of Tabacco Sucker registration data for ALF0L 810 and 10. An agreement was reached and a letter sent to him for use with EPA.
10. Outstanding bills from Scientific Associates were discussed. Reports on testing done for Cio-12 paraffins and ALF0L 4 were not received for 3-4 years after sample submittal. Also SA tested more animals than generally requested. Negotiations have been held with Bob Moulton of SA on these issues. The final position of the Laboratory is that a 30% discount will be given for the testing due to late reports, but no other bill reduction will be given. It now appears there is also a descrepancy in the price per animal charged.
Tom Grumbles will present the issues to the business area to resolve payment.
11. Based on new data, the ALF0L 4 and 1-3 Butadiene MSDS will be reviewed to determine if changes are needed.
Please contact me if there are additions or correntions to these minutes.
Thomas G. Grumbles ajo Distribution: W. D. Broddle, Attachments
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W. D. Broddle 10/83
SELECTED ARTICLES ON AQUATIC TOXICITY OF SURFACTANTS AND ORGANICS
1) Z. F. Wasser und Ab. Forsch, 5/78, p 161- , Golden Orfe Fish:
Ethyl benzene t-butyl benzene Dodecyl benzene Dodecyl benzene, sodium 1,2 Diethyl benzene
LCsq, mg/1 44 65
796 22 32
2) ASTM, Special Tech Publication #634, K. Macek & B. Sleight
Fathead minnow: LAS Cl4 C13
x c 11-|3 Cl 1 ClO
LCe;n, mg/1
0.5 1.8 6.6 4.8 21.9 57.5
Minimum threshold concentration
> 0.05 > 0.12 > 1.08 > 0.63 > 7.2 > 14.0
< 0.10 <0.28 < 2.45 < 1.2 < 14.5 < 28.0
3) Journal American Oil Chemical Society, 1/78, 55, J. Alabaster
a) Rainbow trout LC^q 4 days 0.36 mg/1
C11 " Cl5 LAS
b) Nonionics:
chain length = toxicity to fish
A. Maki & W. Bishop, Arch. Enfironmental Contamination
Toxicology 8_, 599-, 1979
EO * toxicity (K. Macek, S. Krzeminski, Bull. Environmental Contamination Toxicology _13_, 377 (1975) and B. Reiff; Effect of Biodegradible on 3 Nonionic Surfactants on Toxicity to Rainbow Trout. Proc. 7th International Congress on Surfactants Active Substitutes, Moscow, 9/76
Daphnia magna, LC50 mg/1 (48 hr)
Nonionic ethoxylates
AE2 :2 AE4 :3 AEg :6 AEj 0:10
LABS Cu = 20 mg/1 C14 = 10 mg/1 C10 = 0.1 mg/1
4) RTECS, 1978
Methyl Benzene Ethyl Benzene Dodecyl Benzene
Toxic Level; 96 hr 10-100 ppm 10-100 ppm 10-100 ppm
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W. D. Broddle 10/83
5) Conoco data:
Alfonics 1012-60 1412-40 1412-60 1412-70 1618-65
D. magna, L^sn (mg/1)
7 1.3 2.2 7.1 1.7
Alkyl ethoxylated phenol Alcohol ethoxylated sulfate Alfonic 1412 ether sulfate
C12 16 sulfonate Cl4_18 sulfonate
21-32 10 13-15
8-11 4-6
6) Hazardous Information Rev., TSCA Comm., 7/81 (EPA)
Fathead minnow, LC5Q, 96 hr Ci LAB > 1000 ppm Ci3 LAB > 1000 ppm C14 LAB > 1000 ppm
Rainbow trout, LCso* 96 hr C12 LAB > 1000 ppm
Bluegill sunfish, LC50, 96 hr C12 LAB > 1000 ppm
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