INITIAL REVIEW ENGINEERING REPORT PMN: 10-0486 0487 Post-Focus Draft Revision 1 2/2/2011

ENGINEER: Macek \ BCS PV (kg/yr): 5,400,000 Import Only YX

Revision Notes / Assessment Overview: This IRER is an update of the FOCUS Ready Draft version dated 8/26/10. The submitter provided additional information to EPA in a letter dated January 14, 2011. The additional information included risk management actions they were proposing to minimize the potential for water release of the PMN chemicals. The purpose of this revision to the IRER is to present an assessment of potential releases if these proposed risk management actions are carried out.

SUBMITTER: Sasol North America

USE: Surfactant for enhanced oil recovery from oil wells Consolidated set: P-10-486-487. P-08-427-428 are for the same use, from same submitter. STN file CA: No references found. PV above is for total import into US. 1,800,000 kg/yr will be sold in US; 3,600,000 kg/yr will be exported.

OTHER USES: All analogs are surfactants.

MSDS: Yes Label: No

Gen Eqpt: Eng Controls: Ensure adequate ventilation, especially in confined areas. // Eye: when contact with liquid is likely, use face shield and chemical resistant goggles. Otherwise use safety glasses or goggles. // Skin: Full protective clothing, chemical boots, and chemical gloves when contact with liquid is possible. Respirator: If exposure limmits are likely to be exceeded, use NIOSH approved respiratory protection. Health Effects: Eyes: Irritating to eyes. May cause corneal inflammation. // Skin: repeated or prolonged contact can cause reddening and scaling of the skin (dermatitis). // Inhalation: negligible hazard due to low volatility. // Ingestion: No hazard due to low order of toxicity. TLV/PEL: none established

CRSS : Chemical Name: Poly[oxy(methyl-1,2-ethanediyl)], .alpha. -sulfo-.omega.-hydroxy-, C12-13-branched and linear alkyl ethers, sodium saltsS-H20: Dispersible g/L @ VP: 1.0E-6 torr @ MW: 646.00 14.80%<500 93.00%<1000 Physical State and Misc CRSS Info: Neat: Solid (est.) Mfg: NK: Imported Proc/Form: Solution/Dispersion: 27-30% in water End Use: Solution, 0. 05-0.5% in aqueous formulation. NAVG = 646 with 14.8% <500 and 93% <1000, by GPC. The targeted number of PO units is 4 or 8 but may range from 1 to 30. From Same as Case P-08-427:The C12-13 alcohol predominantly has one side chain which may be methyl, ethyl or propyl. The carbon distribution is: C11 0-2%, C12 40-60%, C13 40-60%, C14 0-2%, C15 0-1%. The MSDS and physical/chemical properties are provided for a 30% aqueous solution of PMN substance. Submitted data: OECD test data at 50°C that shows the substance is hydrolytically stable. Estimated Data: VP < 0.000001 torr (Salt); WS = dispersible (use as surfactant).

Consumer Use: No

SAT (concerns) (08/17/2010): Related Cases and Related Cases and Misc SAT Info: Ecotox: Same as P-08-427. Analogs: P-08-429, P-08-513, P-04-65, P-03-140, P-03-15, P-00-762. // Health: P-08-0427 (SAME) Migration to groundwater: Moderate PBT rating: P1B1T1 P10-0486 Eco = 2 and P10-0487 Eco = 3. Health: 1-2 Dermal, Drinking Water, Inhalation Eco: 3 Water (All releases to water with a CC = 28 ppb (P10-0486) and 4 ppb (P10-0487))

OCCUPATIONAL EXPOSURE RATING: 1C

NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER. This is a consolidated case for P10-0486 and P10-0487. This PMN is import only, therefore manufacturing was not assessed. // This is an exposure-based case. None of the criteria were met. // There a two handling operations: the first is the importer handling (PROC1) and the second is the handling at the customer site (PROC2) before being shipped of to the oilfield (USE). After PROC1, 66.66% of the total PV will be exported and 33.33% of the PV will be used domestically. // IRER Note: The submitter provided ample information on releases estimates for each operation and therefore the submitter estimates were used to estimate release amounts and media. // The 1991 GS for Oil Well Treatment Chemicals was referenced. // Note SAT concern for dermal, inhalation, drinking water, and all releases to water with CoC = 24 ppb for P10-0486 and 4 ppb for P10-0487. Incineration releases > 28,000 kg/site-day; air releases negligible (VP < 0.001 torr); migration to groundwater = moderate;water releases are expected from equipment and container cleaning operations. // For PROC1 and PROC2: This IRER assesses sampling to incineration, and container and storage tank cleaning to water based on submitter estimates. // For USE: This IRER assesses sampling to incineration, container and storage tank cleaning to water, and oilfield releases to deepwell injection (50%) and incineration (50%) (GS and submission). // 1-hand and 2-hand dermal exposure was assessed for all operations. Inhalation is expected to be negligible (VP < 0.001 torr). // Same-submitter, same-use past cases P08-0427 and P08-0428c were referenced for consistency. Both past cases were manufactured domestically and had a domestic formulations step. Both past cases referenced the 1991 GS for final use (consistent with this IRER). Both past cases assessed dermal exposure but no inhalation due to VP < 0.001 torr. Both past cases conservatively assesses releases based on lack of submitter information during manufacture and formulation. This IRER contained ample information to assesses releases based on submitter information.

POLLUTION PREVENTION CONSIDERATIONS: P2 Claims: In recent years the interest in using surfactants to enhance the recovery of oil has grown significantly. This is due to the improved chemical efficiency and increased oil recovery versus the standard method of using polymer alone. The surfactant works to remove petroleum oil from rock much like detergents work to remove soil from clothing. That is, the surfactant surrounds the soil particle reducing the "interfacial tension" holding the soil to the cloth, and increasing the affinity of the soil to the surrounding water. The soil can then easily be pulled off the cloth and into the flowing water in the washing process. Likewise, in an oil reservoir, surfactant is pumped into a well where it migrates to areas of high oil concentration. The surfactant then surrounds the oil, coming between the oil and the rock to which it is adhered. The interfacial tension holding the oil to the rock is reduced such that the oil can now be swept off the rock. Additionally, the surfactant increases the affinity of the oil to the water allowing the oil to be pushed out of the well by water and polymer. Almost any surfactant on the market today can be considered and would probably work to some degree to enhance the quantity of oil recovered. However, the ALFOTERRA® Surfactants (alcohol propoxy sulfates) have two significant advantages over other commercially available surfactants such as linear alkyl benzene sulfonate (LAS), dialkyl benzene sulfonate (DABS), nonylphenol sulfonate (NPES), and even alcohol ether sulfates. The advantages are 1) the critical micelle concentrations (CMC) - amount of surfactant molecules required to work- of the ALFOTERRA® Surfactants are onaverage 10x lower than that of the other surfactants, and 2) the interfacial tension (IFT) generated between the ALFOTERRA® Surfactant and the oil is also significantly lower than that for other surfactants. These advantages result in a large difference in the amount of surfactant required to remove the oil. For example, a loading of 3 to 5% by weight of DABS or LAS is recommended for improved oil recovery. In contrast, only 0.1 to 0.3% by weight of ALFOTERRA® type surfactants are required for the same target oil recovery. Thus, it takes 10 to 50 times less ALFOTERRA® Surfactant than other standard surfactants to remove a given volume of oil. Sasol's analysis shows that a small-to-medium sized oilfield will require 39 million lbs of ALFOTERRA® Surfactant injected over three-years to recover 80 to 90% of the oil remaining in the field. If any other standard surfactant was used, the amount required would be a 390 million to 1. 8 billion lbs. It is imperative that the chemical industry work to produce more efficient molecules that reduce the carbon footprint, environmental impact, and human exposure.

EXPOSURE-BASED REVIEW: Yes (0 criteria met)

1) # of workers exposed: 88 >1000? No 2) >100 workers with >10 mg/day inhalation exposure: No 3) (a) >100 workers w/1-10 mg/day inh. exp. & >100 days/yr: No (b) Routine Dermal Cont: >250 workers & >100 days/yr: No

INITIAL REVIEW ENGINEERING REPORT PMN: 10-0486 0487

PROC1: Transfer Operations at Import Receiving Site

Number of Sites/ Location: 1 Volpak Galena Park TX 77547 Days/yr: 12 Basis: Per submission, PMN can be imported in either ships or ISO containers to 1 site as a liquid at 30%. The submitter estimates a worst case scenario for 90% of the PMN delivered on ships and 10% delivered in ISO containers. The submitter estimates that this would equal 8 ship deliveries and 90 ISO containers. Each shipment of ISO containers comes in 25-50 containers. As conservative, CEB estimates 25 ISO containers per shipment for a total of 4 ISO shipments. Therefore, the total number of shipments is 8 ships + 4 ISO = 12 shipments per year (12 bt/yr). ChemSTEER calculates 450, 000 kg/bt.

Process Description: PMN (liquid, 30%) is imported in either ships or ISO containers ---> hook up transfer line---> QC sampling ---> transfer of PMN to holding tank ---> hook up transfer line to either rail cars or tank trucks ---> delivered customers (PMN liquid, 30%) (submission)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources to the same medium. Due to the level of detail in the submitters releases estimates during transfers at the customer sites, CEB assesses releases based on the submitter estimates. Note SAT concerns for dermal, inhalation, drinking water, and all releases to water with CoC = 28 ppb for P10-0486 and 4 ppb for P10-0487. Incineration releases < 28,000 kg/site-day; air releases are negligible (VP < 0.001 torr); migration to groundwater = moderate; releases to water are expected from container cleaning processes.

Incineration Output 2: 8.6E+0 kg/site-day over 12 days/yr from 1 site or 1.0E+2 kg/yr to: incineration (submission) from: Sampling Liquid Raw Material basis: User-Defined Loss Rate Model. As a worst case scenario, the submission states that 102 kg PMN/yr will be disposed of by Intertek QC sampling and 1.8 kg PMN/yr will disposed of by Sasol QC sampling for a total of 102 + 1.8 = 103.8 kg PMN/yr. This is equal to 103.8/12 = 8. 65 kg PMN/bt. The sampling waste is sent to incineration.

Incineration Output 2: 1.1E+2 kg/site-day over 1 day/yr from 1 site or 1.1E+2 kg/yr to: Incineration from: Equipment Cleaning Losses of Liquids from Storage Tanks basis: User-Defined Loss Rate Model. Sasol will mandate that the PMN substances will be rinsed form the holding tank using a solvent (i.e. diesel) and that the rinse aid be collected for incineration (Ref. Sasol, 2011, p. 9). The submission states that the storage tanks are cleaned once every 3 to 5 years and estimates that 57 kg PMN per cleaning . As a worst case scenario, the submission assumes a once per year cleaning cycle and 2 storage tanks for a total of 114 kg PMN released.

Incineration Output 2: 1.2E+2 kg/site-day over 12 days/yr from 1 site or 1.5E+3 kg/yr to: Incineration from: Cleaning Liquid Residuals from Ships or ISO Containers Used to Transport the Raw Material basis: User-Defined Loss Rate Model. The submissionestimates that 57 kg PMN per ship cleaning and 6 kg PMN per ISO container cleaning are released from the cleaning processes. As a worst case scenario of 80% PMN delivered by ship and 20% delivered by ISO containers, the submission estimates a total of 1,479 kg PMN/yr (1479/12 = 123.25 kg/bt) released from cleaning operations. Sasol will mandate that the PMN substance be triple-rinsed using a solvent (i.e. diesel) and that the rinse-aid be collected for incineration.

RELEASE TOTAL 1.7E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 31 Basis: There are a total of 31 workers involved in various activities including QC unloading, loading, QC sampling, storage tank cleaning, and container cleaning. As conservative, CEB assesses all 31 workers to both 1-hand (sampling) and 2-hand (unloading and loading) dermal exposure to PMN at 30%.

Inhalation: negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 30.00% concentration High End: 2.6E+2 mg/day over 12 days/yr Number of workers (all sites) with dermal exposure: 31 Basis: Sampling Liquid Raw Material; EPA/OPPT 1-Hand Dermal Contact with Liquids Model.

Exposure to Liquid at 30.00% concentration High End: 5.3E+2 mg/day over 12 days/yr Number of workers (all sites) with dermal exposure: 31 Basis: Unloading Liquid Raw Material from Ships or ISO Containers; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT PMN: 10-0486 0487

PROC2: Transfer Operations a Customer Site

Number of Sites/ Location: 3 unknown site(s) Days/yr: 300 Basis: Per submission, 3 domestic customer site will receive PMN at 30% (1 customer for P10-0486 and 2 customers for P10-0487) As a worst case, the submitterestimates that 95% (84 shipments) of the incoming customer shippments will be via rail car and 5% (15 shipments) will be via tank truck for a total of 99 shipments. The customer will ship the PMN via tank truck and will have a total of 300 shipments per year. CEB assumes the number of batches to be 300 based on the customer shipment frequency.

Process Description: PMN (liquid, 30%) is delivered in either tank trucks or rail cars to customer sites ---> 33. 33% of PV (1,800,000 kg/yr) is shipped to domestic customers and 66.66% of PV (3,600,000 kg/yr) is exported ---> customer holding tank ---> QC sampling ---> loading PMN (30, liquid) onto tank trucks for transfer to the oilfield (submission)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources to the same medium. Due to the level of detail in the submitters releases estimates during transfers at the customer sites, CEB assesses releases based on the submitter estimates. Note SAT concerns for dermal, inhalation, drinking water, and all releases to water with CoC = 28 ppb for P10-0486 and 4 ppb for P10-0487. Incineration releases < 28,000 kg/site-day; air releases are negligible (VP < 0.001 torr); migration to groundwater = moderate; releases to water are expected from container cleaning processes.

Incineration Output 2: 5.6E+0 kg/site-day over 99 days/yr from 3 sites or 1.7E+3 kg/yr to: Incineration from: Cleaning Liquid Residuals from Rail Cars and Trucks Used to Transport the Raw Material basis: User-Defined Loss Rate Model. Submitter indicated that field experience suggests that residuals are <5 gallons and <10 gallons respectively. Submitter estimated a total of 270 kg/yr (truck) and 288 kg railcar per year over 99 shipments per customer. Sasol will mandate that the PMN substances be rinsed from the railcars and trucks using a solvent and that the rinse-aid be collected for incineration.

Incineration Output 2: 4.5E-1 kg/site-day over 99 days/yr from 3 sites or 1.3E+2 kg/yr to: incineration (submission) from: Sampling Liquid Raw Material basis: User-Defined Loss Rate Model. As a worst case scenario, the submission estimates that 14.9 kg/site-yr of P10-0486 (substance A) and 29.7 kg/site-yr of P10-0487 (substance B) will be disposed of to incineration fromsampling for a total of 44.6 kg/site-yr or (44.6/99) = 0. 45 kg/site-bt.

Incineration Output 2: 5.7E+1 kg/site-day over 1 day/yr from 3 sites or 1.7E+2 kg/yr to: Incineration from: Equipment Cleaning Losses of Liquids from Holding Tank basis: User-Defined Loss Rate Model. The customer storage tanks are expected to be cleaning once every 3 to 5 years. As a worst case scenario, the submision estimates cleaning will occur once per year and that 57 kg/site-yr will be disposed. Sasol will mandate that the PMN substances be rinsed from the holding tank using a solvent (i.e. diesel) and that the rinse-aid be collected for incineration.

RELEASE TOTAL 2.0E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 66 Basis:

Inhalation: negligible (VP < 0.001 torr) .

Dermal:

Exposure to Liquid at 30.00% concentration High End: 5.3E+2 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 33 Basis: Unloading Liquid Raw Material from Rail Cars or Tank Trucks; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

Exposure to Liquid at 30.00% concentration High End: 2.6E+2 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 33 Basis: Sampling Liquid Raw Material; EPA/OPPT 1-Hand Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT PMN: 10-0486 0487

USE: Oilfield Application

Number of Sites/ Location: 3 unknown site(s) Days/yr: 365Basis: Per submission, 3 customer sites will ship the PMN at 30% to its oilfield site via tank truck. The oilfield will operate 365 days/yr. PMN will be injected into the well at 0.1%. ChemSTEER calculates a use rate of 1,643. 84 kg/site-day.

Process Description: PMN (liquid, 30%) unloaded from tank trucks into field holding tank ---> QC sampling ---> meter mixing system ---> PMN (liquid, 0.1%) injected into the well ---> 50-100% of the PMN will bind to rock formations or breakdown in the well ---> oil/water separation ---> oil tank or recycle back to the mixing system (submission)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources to the same medium. Due to the level of detail in the submitters releases estimates during oilfield applications at customer sites, CEB assesses releases based on the submitter estimates for cleaning operations. The 2009 GS for Oil Well Production was referenced. Note SAT concerns for dermal, inhalation, drinking water, and all releases to water with CoC = 28 ppb for P10-0486 and 4 ppb for P10-0487. Incineration releases > 28,000 kg/site-day; air releases are negligible (VP < 0.001 torr); migration to groundwater = moderate; releases to water are expected from container cleaning processes.

Water Output 2: 2.9E-5 kg/site-day over 365 days/yr from 3 sites to: POTW (assumption) from: Chemical in produced water (discharged) basis: User-Defined Loss Rate Model. Per 2009 GS eqn 4-7b, 1% of chemical in produced water (after partition) may be discharged to water. Fwater = 3.5E-6 and Fwater_discharged = 0.01

Incineration Output 2: 6.0E+0 kg/site-day over 1 day/yr from 3 sites or 1.8E+1 kg/yr to: Incineration from: Cleaning Liquid Residuals from Tank Trucks Used to Transport the Raw Material basis: User-Defined Loss Rate Model. Submission states that customers have 1 dedicated truck to ship the PMN to their oilfield. As a worst case scenario, the submission assumes 1 cleaning per truck per year. Based on field experience, submitter estimated 6 kg PMN/cleanup will be released from truck cleaning operations. Sasol will mandate that the PMN substances be rinsed from the trucks using a solvent (i.e. diesel) and the rinse-aid be collected for incineration.Incineration Output 2: 1.9E-1 kg/site-day over 365 days/yr from 3 sites or 2.1E+2 kg/yr to: incineration (submission) from: Sampling Liquid Raw Material basis: User-Defined Loss Rate Model. Submission states that 22.7 kg/site-yr for P10-0486 and 45.2 kg/site-day for P10-0487 will be disposed to incineration from sample disposal for a total of 67.9 kg/site-yr or (67.9/365) = 0. 19 kg/site-day.

Incineration Output 2: 8.2E+2 kg/site-day over 365 days/yr from 3 sites or 9.0E+5 kg/yr to: to refinery (incineration) from: Chemical in oil to refinery (incineration) basis: User-Defined Loss Rate Model. Submitter estimates 50% of PMN chemical remaining in well, for the other 50%, CEB estimates partition to oil phase using Method 3 approach in 2009 GS (based on water solubility). Per eqn 4-5, Foil = 0.9999965 and Fwater = 3.5 e-6

Landfill Output 2: 1.7E-4 kg/site-day over 365 days/yr from 3 sites or 1.9E-1 kg/yr to: land from: Chemical in produced water to land basis: User-Defined Loss Rate Model. Per 2009 GS, eqn 4-8, 6% of PMN chemical in produced water (after partition) is discharged to land. Fwater = 3.5e-6 and Fland = 0.06

Deepwell Injection Output 2: 5.7E+1 kg/site-day over 1 day/yr from 3 sites or 1.7E+2 kg/yr to: Injected into the Enhanced Oil Recovery Well or into a designated disposal well on the field. from: Equipment Cleaning Losses of Liquids from Holding Tank basis: User-Defined Loss Rate Model. The customer storage tanks are expected to be cleaned once every 3 to 5 years. As a worst case scenario, the submision estimates cleaning will occur once per year and that 57 kg/site-yr will be disposed. The submitter indicated that the residual PMN substances and the water rinse-aid will be injected into the EOR well at the completion of the project. Any remaining field water which could contain trace amounts of the PMN substance would be injected into the EOR well or into a designated disposal well on the field.

Deepwell Injection Output 2: 1.0E-3 kg/site-day over 365 days/yr from 3 sites or 1.1E+0 kg/yrto: from: Chemical in produced water (deep well injected) basis: User-Defined Loss Rate Model. Per 2009 GS eqn 4-7a, 36% of PMN chemical remaining in water phase (after partition)goes to deepwell. Fwater = 0.0000036 and Fdeepwell = 0.36

Other Output 2: 8.2E+2 kg/site-day over 365 days/yr from 3 sites or 9.0E+5 kg/yr to: remaining in well from: Chemical remaining in oil well basis: User-Defined Loss Rate Model. Submitter estimates that 50 to 100% of the PMN chemical will remain in the well. CEB assumes 50% to maximize quantity for other release sources.

RELEASE TOTAL 1.8E+6 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 24 Basis: The submission estimates that 6 workers/site are involved invarious loading, unloading, sampling, and equipment and container cleaning activities 2009 GS estimates 8 workers per site. 8 workers used as basis for this IRER. (consistent with the GS). CEB conservatively assesses all workers to 1-hand and 2-hand dermal exposure to PMN at 30%.

Inhalation: negligible (VP < 0.001 torr) . Also per 2009 GS

Dermal:

Exposure to Liquid at 30.00% concentration High End: 5.3E+2 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 24 Basis: Unloading Liquid Raw Material from Tank Trucks; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

Exposure to Liquid at 30.00% concentration High End: 2.6E+2 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 24 Basis: Sampling Liquid Raw Material; EPA/OPPT 1-Hand Dermal Contact with Liquids Model.CALL BY: Organization:

CALL TO:

Organization:

Date:

Time:

Phone:

-