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BIODEGRADATION (301E) TEST SUBSTANCE Identity:A mixturecontainingperfluorooctanesulfonatweh,ich may alsobe referredto as PFOS, FC-95, or as a component ofFC-203. (IOctanesulfoniaccid)(CAS # 2795-39-3). Remarks: The 3M productionlotnumber was notnoted. The testsample isFC-203. Currentinformatioinndicatesitisa mixtureof 1.34% PFOS, 35% diethyleneglycolbutylether,37.85% water,20% ethyleneglycol,2.66 % Sultonefoamer, 3% sodium octylsulfate0,.1% sodium laurylsulfatea,nd 0.05% tolyltriazole. The followingsummary applies to a mixture with incompletely characterized concentrations of impurities.Data may not accurately reflectdegradation potentialof the fluorochemical component of the testsample. METHOD Method: ModifiedOECD Screening Test,OECD 301 E, withDOC Analysis, 1981 version. Test type: Ready Biodegradability GLP: No Year Completed: 1982 Analyticalmonitoring: Dissolvedorganiccarbon (DOC) Statisticamlethods: Resultswere determinedby calculatioonfthe % DOC removal and graphicinterpretation. Test organism source: A 50:50 mix ofsoilextractand secondary effluent. The secondary effluenwtas the supernatantfrom an activatedsludge aerationbasinatthe Metro Wastewater Treatment Plant,St.Paul,MN, while the soilwas from the CityofWhite Bear Lake, Ramsey County, MN. Test condition: Dilutionwater: Deionizedwater Mineral NutrientMedium: Nutrientmedium per OECD 301E method (1981).InitipaHl 7.0. Reference and testsolutionpreparation:The testmaterialwas prepared by dissolving153 mg intwo literosf mineralnutrienmtedium. This solutiongivesa finaltestconcentratioonf 20 mg DOC/L. The referencesubstance,sodium benzoate,was prepared by dissolving 30.3 mg inone liteorfmineralnutrienmtedium. This solutiongivesa finaltestconcentrationof 20 mg DOC/L. Test vessels: Not given. Incubation conditions:Constant dark conditions Temperature: 23.5- 240C Agitation: Continuously Number ofconcentrations1:plussodiumbenzoate(reference substance)and blank,allinduplicate. lnoculum conditionon testinitiationN:ot given . Element Basis: Decrease indissolvedorganiccarbon compared to the blanks. Test substance flaskconditions:Not given. RESULTS Nominal concentrations: Blank control,sodium benzoate at-20 mg DOC/L and at-20 mg DOC/L plusHgCL2 (inhibitedt)e,stmaterialat-20 mg DOC/L and at-20 mg DOC/L plusHgC12,allinduplicate. Element values: 27-day Degradation= 76.7% duplicate1 and 81.3% duplicate2. Mean value = 79% Remarks: Testingwas conducted on the mixtureas describedinthe Test Substance Remarks field.The values reportedapplytothatmixtureand not the fluorochemicalproportionalone. CONCLUSIONS The FC-203 % degradationbased on the mean DOC removal value was 79 after27 days. Submifter: 3M Company, EnvironmentalLaboratory,P.O. Box 33331, St. Paul,Minnesota,55133 DATA QUALITY ReliabilitKyl:imischranking= 2. This s-tudymeets the criterifaorquality testing.However, the sample puritywas notproperlycharacterizedand the study lacksanalyticaclonfirmatioonfthe amount offluorochemicalproportion inthe solution. REFERENCES The studieswere conducted by the3M Company, EnvironmentalLaboratory, St.Paul,MN, Lab Request number 8483, 1982. OTHER Last changed: 6/27/00 interCnoarlrespondence .cc: vD. L. Bacon/R.L. Bohon - 21-2W-05 VR. Gritzky - 3M Neuss VD. R. Ricker 236-2B-01 VJ. A. Pignato 2362A-01 "To: K. F. SCHROEDER - 3M NEUSS, GERMANY From:E. A. REINER - ENVIRONMENTAL LABORATORY/EE SubjectB:IODEGRADATION TESTS Date:APRIL 21, 1983 & PC 21-2W-5 3M .Envir. Assess..,Inq. #823,26,.,3M Neuss, Germany FC-203, FC-600 Attached is a copy of our report on the modified OECD screening tests on FC-600 and FC-203. While the results of this testing does not precisely repeat those which we obtained on FC-203 in 1980, they do confirm that FC-203 is readily biodegradable according to the test method criteria. The present results also show that FC-600 is readily biodegradable. The reason that these results do not precisely match those of our previous testing is not known, but biodegradation test results are characteristically somewhat variable. This variability is often explained by one or more of the following three factors: 1. Differences in the bacterial species or strains present in the inocula of tests started at different times. 2. Variations in the formulation of a product from one lot to another. 3. The presence of inhibitory materials such as possibly toxic byproducts or inadvertent contaminants. K. F. Schroeder Page 2 April 21, 1983 The percent biodegradation results given in the attached report are equally app@icable to both the concentrated AP'FF products, as sold, and the diluted products, as used. Dilution with pure water would have no effect. The reason for this is that testing is actually done on a very dilute portion of the concentrate (20 ppm as TOC). llot-.tIt,i(,ciotic(-.@ntrciotre lli(@3 or 61 tisago Iov(.,lwoul.(]1)(-' diluted to this same concentration for testing. The dilution factor is not considered when calculating the results. I have reviewed the table of biodegradation data that you sent us. Some of the variability in results which you show is not unexpected. This is particularly the case with the 5-day BOD test results. Biodegradation of AFFF products is usually only partially completed within the first five days of a BOD test and.the percent of biodegradation that has been completed in this time period is highly dependent upon both the viability of the microbial inoculum and the fraction of the organisms in the inoculum which are capable of degrading the organic compounds. Results of 20-day BOD tests are less variable because biodegradation is usually more nearly complete and proportion of organisms capable of degrading AFFF products has increased through growth. But, 20-day BOD tests are susceptible to another type of problem, "nitrification." In these longer tests, populati-ons of bacteria can develop which can oxidize the ammonia,in the BOD dilution water making it appear that the test material is more biodegradable than it actually is. In the Environmental Laboratory we are now taking precautions to avoid this problem by using "nitrification inhibitors," chemicals which inhibit,the oxidiation of ammonia. A point of confusion in your table of BOD data is the reporting of different BOD5 to COD ratios for both the undiluted and diluted AFFF products. This doesn't make sense because BOD and COD would decrease proportionally with dilution with the ratio remaining the same. These differences which you indicated were reported in Hellmann's work must therefore be due to variability between one ROD test run and another and not to dilution. K. F. Schroeder Page 3 April 21, 1983 We hope the attached OECD test results and this explanation of the biodegradation data in the table which you provided are helpful to you in dealing with potential customers concerned about biodegradation. If you or your customers have any further questions about biodegradation test restilts on 3M AFFF products, feel free to contact li@;. Wo'll. do otir best: in trying to get a satisfactory answer for you.and your customers. For our own benefit and at our expense, we are in the process of repeating the OECD screening tests on the FC-600 and FC-203 samples used in this testing. We are interested in seeing how repeatable our testing results are when the same samples are used in two separate tests. We will inform you of the results of this test. EAR/mb Attachment: Report on the Biodegradation FC-203 by the OECD Screening of FC-600 and Test Form 6747-11-E TECHNICAL REPORT SUMMARY TO: TECHNICAL COMMUNICATIONS CENTER - 201-2C-12 (Important-Ifreporitsprinteodn bothsideosfpaper,sendtwo copiesto TCCJ Guidelinesorneversseide. Division 3M Environmental Laboratory (EE & PC) St. Paul Minnesota 3M Germany Roport Title Biodegradation Testing on FC-600 and FC-203 To K. Fe SchrQeder, 3M Neuss, Germany Au thor(s) E. A.@keliner, Environmental Laboratory - 21-2W-05 Notebook Reference None - See 3M Environmental Lab Request 8483 Dept Number 0535 Project Numbor 9972410100 We-po-r-t-wu-mso-r C()I ForladCoveredor Date 4/18/83 Employee Number(s) 47816 No. of PagesincludingCoversheat 15 SECURITY 10. KEYWORDS: Lab Code OLI)erKeywords []Open Report& Summary 0 Closed Re'port-ODen Summary CURRENT OBJECTIVE: 3M CHEMICAI. 1 REGISTRY- b, [3 Check box ifnow chemicals are reported.Use Chemi- Xcal Registry Form 6092 to report all new substances, 1. To measure the biodegradability of two "Light Water" products using the internation@klly recognized Modified OECD Screening Test. 2. To compare results with those previously obtained using the same test method. REPORT ABSTRACT: This abstractinformationisdistributebdy theTechnicalCommunications Centertoalert3M'ersto Company R&D. This study used the Modified OECD Screening Test with dissolved organic carbon (DOC) analysis to measure the biodegradability of "Light Water" Brand AFFF products; FC-203 and FC-600. In 28 days, the DOC levels of FC-60&, degraded by 80% and 92% for an average of 86%@'in two parallel'tests. In 27 days the DOC of FC-203 degraded-by 77% and 81% for an average of 79%. The FC-203 result differed from a similar test done in 1980 in which 93% DOC degradation occurred within 21 days. In the present study parallel sterile controls proved that the DOC loss was not du e to chemical-or physical procetses such as adsorption, vo'latilization, or precipitation of the organic compounds. InformationLiais Initials: FC-600/FC-203 P,cg-ie 2 April 18, 1983 Introduction The 3M Environmental Laboratory undertook this study of the biodegradability of "Light Water" products, FC-600 and PC-203, I-)(-@cause of concern expressed by 3M Germany about inconsistencies in 1),ISL biodegradation test results. Modified OECD Screening Tests conducted in 1980 by the 3M Environmentzkl,L.@4I)oratoryshowed that three "Light Water" products were highly biodegradable. FC-203A, FC-206, and FC-3017 (FC-206 P) all were shown to have 90% of their dissolved organic carbon removed in the OECD Screening Test. These results, however, contradict those of .H. Hellmann and D. Muller(l) usin a similar yet not identical test method, the TOC Degradation Test( ). In their study FC-206 and FC-3017 were found to have total organic carbon reductions of only 6% and 8%, respectively, in 21 days. These low biodegradation results of Hellmann, however, were also contradicted by his own work. iiis BOD5/COD ratios for FC-3017 and FC-206 were 0.5 and 0.4, respectively. This showed that 50% and 40% of the theoretical oxygen demand was expressed within only 5 days. These levels of biodegradation are much greater than the 8% and 6% TOC removals which he observed in the even longer (21 day) TOC degradation test. This is clearly an inexplicable discrepa,ncy in his work. Hellmann's TOC degradation results are also contradicted by BOD20/COD measurements made by the 3M Environmental Laboratory and other independent laboratories on 3M AFFF products. Such results typically show BOD20 values to range between 60 and 190% of the COD. For example, a collection of such data on 3 U.S. military specification AFFF products made by 3M is shown in table 1. Pag@ 3 TABLE I BOD, CARDONACEOUS BOD, AND COD DATA ON MIL-SPEC Ai,'Ft-i'-litODUC-1- BOD20 C-BOD COD BOD20 C-BOD20 Lab (mg/kg) (mg/kq (mg/kg) -TO-D COD FC-203C Lot 501 3M scolooo 600,000 730,000 .79 .81 740rOOO Pace .8OOtOOO* 7301000*, 810,000 1 730rOOO Serco 440,000 440,000 737,000 .60 .60 Ca sule 5701,000 620,000 950rOOO .6 .65 Ga@braith 616,000 67loOOO 776,450 .79 .86 S & W Seed Galbraith 670,000 641,000 776,450 .06 .02 Knoxville Average S. D. 575,000 594,000 782,000 .73 .75 85,000 90,000 Borooo .12 .12 Calculated BOD's from different dilutions were very inconsistent. Pace agreed to repeat this work but inadvertently lost their repeated test results as well. We did not recjuest a third testing nor did we include these values in the averages. FC-206C Lot 502 3M Pace Serco Capsule Galbraith S & W Seed Galbraith Knoxville 290,000 350,000 240,000 260,000 416,500 395,500 290,000 370,000 260,000 320'000 411:000 374,000 380,000 360rOOO 450,000 370,000 410,000 407,250 407,250 0.78 0.78 0.65 0.63 1.02 .97 0.78 0.82 0.70 0'.78 1.01 .92 Average So Do 3M Pace Serco Capsule 325,000 338,000 396,000 .81 .83 73,000 57rOO 33rOOO .16 .11 FC-780B Lot 501 240,000 230,000 320,000 .74 .71 330,000 250,000 250,000 350,000 .71 .71 210,000 220,000 287,000 .73 .77 240,000 230,000 360,000 .67 .64 Average so Do 235,000 232,000 329,000 .71 .71 17,000 13,000 28rOOO .03 .05 FC-600/FC-203 Page 4 April 18, 1983 Methods and Materials 1. Procedure Testing was perforin(-,@i(ni accur(lanc(--witli tlio01!,'CD testing of chemicals adopted May 12, 1981. I.or 2. Chemicals The reference material used was laboratory grade sodium benzoate (C7H5NaO2) F.W. = 144.11. A 30.3 mg sample of this compound was diluted to 1.0 liters with the nutrient solution described by the method to yield A theoretical DOC of 20 mg/l. The "Light water" samples used were supplied by G. Piessens, E.T.S.L. and consisted of FC-203 and FC-600. Lot numbers were not provided. Nutrient solutions of the "I.ight Wc-iter"products with DOC's of approximately 20 mg/l (based on calculations from the formulation) were prepared by bringing both 527 mg of FC-600 and 153 mg of FC-203 to 2.0 liters with nutrient solution. 3. Inoculum The inoculum was a 50/50 mixture of the soil and secondary effluent inocula each prepared in accordance with the OECD procedure. The soil used was fresh loamy sand garden soil obtained from White Bear Lake, Minnesota, and the water for the soil extraction was chlorine-free well, water. The secondary effluent sample was the supernatant from an activated slud(c aeration basin at the St. Paul Metro Wastewater Treatment Plant. The combined inoculum was passed through WhatmanD 54,filter paper prior to usage. 4. Sterile Controls Replicate vessels containing 400 mg/l HgCl2 served as sterile controls for both test materials and the reference compound. The sterile controls were handled in the same-way as the viable cultures. 5. Instrument The organic carbon analyzer used was a Dohrmann DC-52A. Its sensitivity limit is approximately 2 mg of carbon per liter. 6. Sample Handling and Storage The sample preservation method used was that prescribed by the TOC manufacturer. The method involved adding 1 drop of concentrated HC1 per 10 ml of filtered sample. This brought the samples to less than pH 2. The samples were then stored under refrigeration in vials with aluminum foil-lined-caps. Dohrmann literature indicates that the method. can stabilize potassium hydrogen phthalater a readily biodegradable material, for several months. FC-600/FC-203 lllito5o April 18, 1983 Due to problems with the sensitivity of the TOC analyzer, onl.y half of the samples were analyzed within a month after sampli.ng. Following 4-5 months of storage, all of the samples were reanalyzed. Comparison of the TOC analyses done within I inoiii-.1-i with those done after 4-5 months of storage showed that in only one stored sample had the TOC changed significantly. This sample was discardea. Results and.Discussion Table 2 summarizes the resul*tsof this study. Appendices I and 2 contain the actual data sheets and plots of the degradation as a function of time. Table 2 shows that the sodium benzoate reference compound was nearly completely degraded within 14 days. Degradation of both FC-600 and FC-203 continued throughout the course of the 28-day test period without plateauing. At 28 days the average TOC removal for FC-600 was 86% and at 27 days the average TOC removal for FC-203 was 79%. The test procedure recommends that chemicals giving a result greater than 70% loss of DOC (within-28 days) should be regarded as readily biodegradable. These 3M formulated.AFFF products are thus even more completely degraded than is necessary for a chemical to be considered readily biodegradable. TABLE 2 Biodegradation (% DOC removal) of Sodium Benzoate, FC-203 and FC-206 Product % Degradation at Day: 7 14 21 27 28 Sodium Benzoate Sodium Benzoate Duplicate 94.4 92.3 94.7 96.3 93.2 99.6 93.5 97.7 94.5 100.0 FC-203 FC-203 Duplicate -.37.4 43.0 59.2 54.6 68.4 66.0 76.7 81.3 78.0 FC-600 FC-600 Duplicate 46 47.2 63.5 67.1 73.5 80.2 82.1 88.7 79.9 92.1 *Sample discarded due to probable contamination. The sterile control data in Table 3 provide further substantial evidence that soluble TOC loss from the test samples is not due to physical modes such as adsorption, volatilization, or precipitation. These samples were handled identically to the test vessels, except that they contained HgC12 to prevent microbial growth. At the end of 28-day test period, these controls contained all,of the initial DOC. FC-600/FC-203 Page 6 April 18, 1983 Conclusion TABLE 3 Percent InitiaI DOC in Sterile Controls at 28 days Product DOC Remaining FC-2U3 98.1 L-C-600 101.3 The present study demonstrates that Light Water products FC-203 and FC-600 are "readily biodegradable" according to the recommended 70% DOC removal criteria of the Modified OECD Screening Test. FC-203 and FC-206 had average losses of DOC of 79% and 86t, respectively. References 1. Dr. H. Hellmann and D. Muller, "Environmental Impact of Fire Extinguishing Foam Compounds (Umweltgefahrdung durch Feuerlosch-Schaummittell)." The study was carried out by the West German Institute of Hydrology (Bundesanstalt fur Gewasserkunde), April 18, 1979. 2. D. Muller and T. Tittizer, "The TOC Degradation Test - A Process to Test Organic Materials for Complete.Biodegradation (Der TOC Abbautest - ein Verfahren zur Prufung von Oroanbischen Substanzen auf Vollstandiaen gi@'-ologischeAnbbau)." Developed at the Bundesanstalt for Gewasserkunde, Koblenz, Z. F. Waser-und Abwasser-Forschung (1979). 3. Organization for Economic Cooperation and Development, Guidelines For Testing of Chemicals, Section 301 E, Ready Biodegradability: Modified OECD Screening Test, May 12, 1981. 4. Dohrman DC-,52A Operating Manual, 4th Ed., 1978. ..Page,.7, Appendix 1 A N t4 SAWLE FORM SHEET FOlt IHE MODIRIEC) QECD SCREENI-NG TEST 4tISq 13 E:p. no.: 0 to OT St*Tt OT tOSt: 10 - ;@-7 - lr2- 4vm * standermaotorist, Yheorptietl vane.-: 2./7@ /I lnocuium. Clip(.4)tiblh t;arom siteayoor rie %'IW At Cgntrgls; I TOC* I ooc*e I *took solution or the to*t rial /1, dilution - I I Ia al of nutrient solution) I I 83 Carbon taterainations: 3C)p us Irisoul maiyees Culture asol no. I (A M f@,@, ivnear.i pvc - concentrationsorter x aayii leene. I mo/I I loo/i 10 (Co)l 71 141 -211 271 28 1 Mineral nutrient solutioniM III test sato-rT&-T 0" Nith gnocu=us 42 al 021 I lei - ---7-1 (Ct) 2'. 1 1- I I ?I y /,-.-rI I I b2 bl b21 1 102 - ---I- I l(Ct) Irn-s-r-anluttionti solution wittmutigiankl test seterzal 1 out 1uh 02 al + 02 (ebi) Y l,7 12,3 d) 12, o I I j,0 10,*71,:D@-i-l,iD.1 11 -1 osirl 0 note musli@ent -61 im Blank al (Cbl) L 1 10--710@,S@-3@0-71t 0 "SCOGNmt betws*^ON "W TOC valuesPoints towardsInsufficientsolubility *1 tu test uterial. BW vg&Wo det@ifted otter **Mwww filtraties. ,AUEOAC,E OF 13LAtJi,-S* AfTeR X pAys 7 iq 2 /.ot TO-1 03.r o, LP,o a g e /-E fe 12 *Ready Hiodograda6ility: ModL?Iod OECD Scroon*ing Test* C; cya:uatlgo of Lew date; FIO*kl no. DOC - concontrations minus I 101 5 otx removal arter x 71 14 211 27, o2y8' sit O)t ico lyq *3t 1 93 I 03 J 01 02 2 for day x 'i 'I ige "Ready Uiodegradability: modified OECD Screening Test' 301 E I Page 11 S. A N N I X SAWLE roitm SIICET FOil Itif MOOIFICU OECD Exp. no.: -94'93 Date of start of test: 1,-1-817- UP6 * Stendero coromrsais Thoorpli&!!t tI.;*.canc.: . ,l;naoculu:: C@,Elt-14RASX roon iia4yvor: 7 V,.3 L 2!2 A SCREENIW .1f@! /wi TESY As ganlra": I TOCS I DDC*E I latook soluttai;of the Lost material I (1000 a 1, dilution el of nutrient ig"tion) I I Carboi U: Culture Td2r JFA*TEAIAL. i fiesiti I Analyst* I sodium no. Fc-- iTheor.1 ouc - concentrations ertc-r--x--aa-ysl loonc. 1 09/1 1 NVI 10 (Co)l-&71 *vl4lAP2llop271 28 1 IlUneral nutrient,, al solutionXUII I I I material 1 82 lww With -f I I 1.@ I IIq II,, q'i 11 1',gI'',-7 ' 61 + 821 1 1 1 1 1 1 1 I (Ct) 7,i!i 1 2 2 11 / 1I.2 i.o 'I113.9'1 I q. r I'?. 1I4. q41 'II/!Sr..y-l0 1I I (Ct) I bl b21 102 - (fL, autrilenti solutioVnitboutilnkl PIJ ltest material 1 02 lout im I;$ a I linecu-1us I (cbI) mineralokutft"t "lutten ut sionill testwittae"lf butKUK at I (Cbl) I 0 D$oosroononbtetweenM &PATIC v@4v*opointstowardsSawrtiesentsolubility of thetest"terist. P41 ut valvesdotu"ood aftermamwom rsittattea. WtJ ATf..?ACr fO t 13LA (,KJ PA-RA -:>a,ge E /.,a12 *Ready siodograda6ility: j, ModLflod OECD SersonLng Test" C:eva:uatlgofg-rav dots, low - concentrations minus blw*o Ina. 1 I 2 &San mi@ - O)t al - al 21 - 03t 102- D) 01 02 2 for,day x 2-03 Ia U-N removal afte days I 1 71 141 211 r27 11, 28 1 1 I 100 P7.q I I?I I lf%O I lq3. lqo157 1 me A !RF-SUL-TS eelolt -To E)or- A(( -T-0 Stlo") SAPAELE (-a#j-rAvtlljA.T, UALt4r. ONE V gr Sol )Page "Ready Uiodegradability: Modified OECD Screening Testa - --------- 301 E I Page 11 ANNi X SAWLE f(MiN$MEET FOR ItifMQUIFICO9CC SC"EFNIUGTgLy Exp. no.: I-A 4 1?tiq 3 Date of sre-Ttor test: 4ooh- 1 Standard notortal i Thearvil@!!! uonc.- ianoculu:: roan slasy0or;--Dc--;L.,L igrA A Ai Af) As iggtrolg: I TOC* I DOC** I tOOk *Oluttan or the test materls 'low mg/l, dilution ...IIDCIO Al at-p utrient soigtion)-t- I 81 Carbon daterainatilins: MA-rC$2slL Floomi oina&yses cu-iture S*dLum ,no. I Ec- 00 lThear.1 06 - Concentrationsofter-x dayal leonc. 1 9/1 1 40/1 10 (Cc)leaf7t1^^14 o*21W 271 28 1 KtnerGl nutrlsnt ti n wlth ,t,a:Itl"ia*te-rraT end lith I infoulu-N I 42 lI - I I &I l@02 I 2 S,.g:j-qf4 II -"Y,s-iL30.1 II I 11/3. 1 q, cy 0 I i(Ct) 12 b2 bi b2 102 0 NtneraVnuttlent solutionwithoulibinkl test motor-Lfil--i 02 but xm I;# a 2. 3.1 I(Cbl) testastefio4ut4ol@&nkt (chi) 0 O0lff#,r,0t0e"nstt bftvolft DOC S"d TOC VGIUGS P*Lnt& tOW&VdB lftsufficienstolublilty 0* vo4we detw"mw after embeeng riltrotloi%. age '12t. E 12 mo;Roaot siodo radability: Iris OCCO lcre*nlng Test* C: L"tlon IOOC slow$ of rewim": IFI*Skl no. 2 seen Olt - 23t al - 93 821 - 03t 1.2 . m3 L ol 02 for day x 5 oac removal a 71 141 21F r2717 2YO 1 I "f"o iq7.;i 177lrl1?(1* Page 13 1 If i 100% i-44-4 9ax I iT 1! 70% Lli at 60% 50X@ 40% ca 30%- r7 20X Appendix 2 3M Envlromental Laboratory OECD Modified Screening Test with DOC Analysis Analyst: Wade A. Schell. Date of Start of Test: /0-27-t2La Request No.: Test Material: Smj>iupq W-Pleo*rrs 21 27 NUMBER OF DAYS INCUBATED L-@= 7 Page 14 I I 3M Enviromantal Laboratory OECD Modified Screening Test with DOC Analysis Analyst: Wade A. Schell Data of Start of Test: 10-:Z7-12- Lab Request No.: 13qS3 Test Material: FC-- 10 70%- LU 60%--S. 5D%. 40%-Im LU 30%- 20X 10% XV z z 7. : ! I I ---------- 21 2 NUMBER OF DAYS INCUBATED Page 15 I 90% 80%. 70% LLS c3 CF/o 40% 3='7 20X L.0 20 09 3M Envi.a ntal Laboratory OECD Modified Screening Test with DOC Analysis 7- Analyst: Wade A. Schell Date of Start of Test: Lob Request No.: -Sqw*3 Test tbt*rial:-F -(POO -Awr T 21 2@ NUMBER OF DAYS INCUBATED