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 salts

EPA SANITIZED Page 1 of 12
S-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;

EPA SANITIZED Page 2 of 12
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 on

EPA SANITIZED Page 3 of 12
average 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

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---> 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 submission

EPA SANITIZED Page 5 of 12
estimates 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 submitter

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estimates 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 from

EPA SANITIZED Page 7 of 12
sampling 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: 365

EPA SANITIZED Page 8 of 12
Basis: 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.

EPA SANITIZED Page 9 of 12
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/yr

EPA SANITIZED Page 10 of 12
to:

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.

EPA SANITIZED Page 11 of 12
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