REVISED INITIAL REVIEW ENGINEERING REPORT 

PMN: 04-0319 

This is a revised engineering report based on the additional 

information from the company on 5/19/2004. Revisions are in bold. 

ENGINEER: Jon \ DGR 

PV (kg/yr): 15,000,000 (Import only) 

SUBMITTER: Transmare Houston Inc. 

USE: paint and ink (60%) formulations; indoor heating oil (20%); 

solvent blend for cleaning (20%).

OTHER USES: 

MSDS: Yes Label: No 

Gen Eqpt: impervious gloves/chemical safety goggles & face 

shield/local exhaust ventilation 

Respirator: respiratory protection 

Health Effects: flammable 

TLV/PEL: PMN (Mosspar M) 100 mg/m; (MSDS) 

CRSS (2/19/2004): 

Chemical Name: Distillates (Fischer-Tropsch), hydroisomerized 

middle, C10-13-branched alkane fraction 

S-H20: 0.001 g/L 

VP: 0.48 torr 

MW: 142.29 

Phys State: NEAT: Liquid; MFG: NK, Import; PROC/FORM: NA; END 

USE: Destroyed as heating oil; Solution: added to 

pesticides, paint and ink formulations, and 

cleaning solvents 

Consumer Use: No 

SAT (2/20/2004): 

Related cases: IDENTICAL TO (INCOMPLETE) 

Migration to groundwater: Moderate 

PBT rating: P1B2T2 

Health: 1-2 Dermal, Drinking Water, Inhalation, 

Other(Ingestion); XB: No testing desired 

Eco: 3 Water; XB: No testing desired 

OCCUPATIONAL EXPOSURE RATING: 2-3 
REVISED INITIAL REVIEW ENGINEERING REPORT 

PMN: 04-0319 

NOTES & KEY ASSUMPTIONS: 

This substance will be imported; therefore manufacturing 

assessments have not been made in this IRER. The submitter was 

contacted to answer questions, see contact report for details. 

The generic scenario for use of printing inks was used to make 

assessments for USE 1. 

The generic scenario for wet cleaning process in IC fabrication 

was used to make assessments for USE 2. Different submitter, 

similar use past cases were referenced for consistency. Past case 

 also referenced the generic scenario for web cleaning process 

and all assessments were consistent with this IRER. 

No past cases were found for USE 4, heating oils; standard CEB 

estimates were used to make assessments. Generic scenarios for UV 

curable roll coating and automotive spraying were used to make 

end use assessments for USE 5. 

POLLUTION PREVENTION CONSIDERATIONS: 

The PMN material is a non-odorous substitute for kerosene. Its 

use will result in a significantly reduced exposure to aromatics, 

because this material does not contain the aromatics that 

kerosene does. Therefore, the overall risk to human health and 

the environment will be reduced. 

EXPOSURE-BASED REVIEW: No 
REVISED INITIAL REVIEW ENGINEERING REPORT 

PMN: 04-0319 

PROC 1: receive imported PMN from ships to storage tanks 

Number of Sites: 1 Submitter site (Deer Park, TX 77536) 

Days/yr: 15 (past case ) Note: unloading from ship to storage 

tank expected to occur on less than 200 dpy 

Basis: Submission estimates 200 days/yr for both unloading from 

ship to storage, and loading from storage to trucks or ships. 

Previously, in , 5 days/yr were estimated for the unloading from 

import ship. The PV for this PMN is 3 times greater than in , 

therefore 15 days/yr was assumed. 

Process Description: 1,000 to 10,000 metric tons of PMN are 

imported by ship => PMN is pumped to storage tank facility (Max 

3,500 metric tons/tank). (Submission) 

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY 

WATER 

Not expected 

Underground injection 

1 kg/site-day over 12 days/yr 

(This is changed from the initial review) 

Air 

27 kg/site-day over 15 days/yr 

from: Unloading Liquid Raw Material from Storage/Transport 

Vessels; Loading Liquid into Storage/Transport Vessels 

basis: EPA/OAQPS AP-42 Loading Model. Submission estimates 1 

kg/day fugitive air releases. 

Incineration 

4,000 kg/site-day over 11 days/yr using CEB worst case estimates 

from: Cleaning Liquid Residuals from Storage/Transport Vessels 

basis: EPA/OPPT Bulk Transport Residual Model; Submission 

estimates 50% of non-fugitive emissions are to waste water 

treatment plant (surface water), 50% to off-site energy recovery 

(incineration). Submission estimates 1 kg/month released to 

incineration. 

Landfill: not expected (submission) 
REVISED INITIAL REVIEW ENGINEERING REPORT 

PMN: 04-0319 

PROC 1 (continued): 

OCCUPATIONAL EXPOSURES SUMMARY 

Tot. # of workers: <3 (CEB standard default, Submission 

estimates 1 worker) 

Days/yr: 15 

INHALATION: 

Exposure to Vapor (Class II) 

PEL: 1000 mg/day over 15 days/yr (based on PEL) 

Model:< 110,266.7 mg/day over 15 days/yr (based on container 

volume) 

Number of workers (all sites) with inhalation exposure: <3 

basis: Unloading Liquid from Storage/ Transport Containers; 

EPA/OPPT Mass Balance Model: large container size (1.4 million 

gal) makes model output very large. 

Note: The respirator class is: II. Gas/vapor (all substances in 

the gas form) 

Inhalation Monitoring Data Review 

1) Uncertainty (estimate based on model, regulatory limit, or 

data not specific to industry): YES 

2)a) Exposure level > 1 mg/day? YES 

OR 

 b)Hazard rating for health of 2 or greater? NO 

Inhalation Monitoring data desired? YES (both 

criteria met) 

DERMAL: 

Exposure to Liquid at 100.00% concentration 

1,764.00 mg/day over 15 days/yr 

Number of workers (all sites) with dermal exposure: <3 

basis: Cleaning Liquid Residuals from Storage/ Transport Vessels; 

EPA/OPPT 2-Hand Dermal Contact with Liquids Model. 
REVISED INITIAL REVIEW ENGINEERING REPORT 

PMN: 04-0319 

PROC 2: Transfer to Tank Trucks or Ships 

Number of Sites: 1 Submitter site (Deer Park, TX 77536) 

Days/yr: 200 (Submission) 

Basis: Submission estimates continuous process, 200 days/yr and 

75,000 kg/day. 

Process Description: PMN (100%) is pumped from storage tank 

facility to trucks or ships (est. 1,200 gal). (Submission) 

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY 

WATER 

Not expected 

Underground injection 

1 kg/site-day over 12 days/yr 

(This is changed from the initial review)

Air 

1.0 kg/site-day over 200 days/yr 

from: Loading Liquid Product into Tank Trucks 

basis: EPA/OAQPS AP-42 Loading Model estimates 0.358 kg/site-day 

typical and worst case. Submission estimates 1 kg/day fugitive 

air releases. 

Incineration 

14,000 kg/year 

3500 kg/site-day over 4 days/yr using CEB worst case estimates 

from: Cleaning Liquid Residuals from Storage/Transport Vessels 

basis: EPA/OPPT Bulk Transport Residual Model; Submission 

estimates 50% of non-fugitive emissions are to waste water 

treatment plant (surface water), 50% to off-site energy recovery 

(incineration). Submission estimates 1 kg/month released to 

incineration. 

Landfill: not expected (submission) 
REVISED INITIAL REVIEW ENGINEERING REPORT 

PMN: 04-0319 

PROC 2 (continued): 

OCCUPATIONAL EXPOSURES SUMMARY 

Tot. # of workers: <3 (CEB standard default, Submission 

estimates 1 worker) 

Days/yr: 200 

INHALATION: 

Exposure to Vapor (Class II) 

worst case: 57.4943 mg/day over 4 days/yr

typical: 0.024 mg/day over 4 days/yr 

Number of workers (all sites) with inhalation exposure: <3 

basis: Cleaning Liquid Residuals from Storage/Transport Vessels; 

EPA/OPPT Mass Balance Model 

Note: The respirator class is: II. Gas/vapor (all substances in 

the gas form) 

Exposure to Vapor (Class II) 

worst case: 19.5318 mg/day over 200 days/yr

typical: 2.17 mg/day over 200 days/yr

Number of workers (all sites) with inhalation exposure: <3 

basis: Loading Liquid Product into Tank Trucks; EPA/OPPT Mass 

Balance Model 

Note: The respirator class is: II. Gas/vapor (all substances in 

the gas form) 

Inhalation Monitoring Data Review 

2) Uncertainty (estimate based on model, regulatory limit, or 

data not specific to industry): YES 

2)a) Exposure level > 1 mg/day? YES 

OR 

 b)Hazard rating for health of 2 or greater? NO 

Inhalation Monitoring data desired? YES (both criteria met) 

DERMAL: 

Exposure to Liquid at 100.00% concentration 

1,764.00 mg/day over 15 days/yr 

Number of workers (all sites) with dermal exposure: <3 

basis: Cleaning Liquid Residuals from Storage/ Transport Vessels 

(User-Defined); EPA/OPPT 2-Hand Dermal Contact with Liquids 

Model. 
REVISED INITIAL REVIEW ENGINEERING REPORT 

PMN: 04-0319 

PROC 3: Formulation of Paints, Inks, and Cleaning Solvent (80% 

of PV) 

Number of Sites: 8 unknown formulating sites 

Days/yr: 235 

Basis: Submission estimates 8 sites at 200 days/yr for 

formulation of paints, inks, insecticide carrier and solvent 

uses. 

Process Description: PMN is transported by trucks or ships => 

PMN unloaded to storage tanks (est. 5,000 gal) => PMN is 

transferred to mixing tanks (est. 500 gal) => PMN is mixed with 

other feedstocks to make formulation (30-50% PMN) => Formulation 

loaded into 5 gal cans or 55 gal drums. (Submission) 

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY 

Incineration 

180,000 kg/site-yr 

from: Cleaning Liquid Residuals from Tank Trucks Used to 

Transport the Raw Material (16 kg/site-day); Equipment Cleaning 

Losses of Liquids (80 kg/site-day) 

from a Single, Large Vessel 

basis: EPA/OPPT Bulk Transport Residual Model, CEB standard 0.2% 

residual.; EPA/OPPT Single Vessel Residual Model, CEB standard 

1% residual. 

Because PMN is a PMN is mixture of C10-C13 parafins, did not use 

worst case water estimate for container cleaning - per 

(US EPA/CEB), water releases from oils/gases to water is not 

expected. Submission states steam cleaning of storage tanks 

approximately every 6 months. Once PMN is combined with other 

materials, resumed worst case water assessments. 

Air 

0.13 kg/site-day over 235 days/yr 

from: Cleaning Liquid Residuals from Tank Trucks Used to 

Transport the Raw Material; Equipment Cleaning Losses of Liquids 

from a Single, Large Vessel; Loading Liquid Product into Drums; 

Unloading Liquid Raw Material from Tank Trucks 

basis: EPA/OPPT Mass Transfer Coefficient Model.; EPA/OPPT Mass 

Transfer Coefficient Model.; EPA/OAQPS AP-42 Loading Model.; 

EPA/OAQPS AP-42 Loading Model. 
REVISED INITIAL REVIEW ENGINEERING REPORT 

PMN: 04-0319 

PROC 3 (continued): 

OCCUPATIONAL EXPOSURES SUMMARY 

Tot. # of workers: <3 (CEB standard default, Submission 

estimates 1 worker) 

Days/yr: 235 

INHALATION: 

Exposure to Vapor (Class II) 

worst case: 548 mg/day over 235 days/yr 

typical: 18.3 mg/day over 235 days/yr 

Number of workers (all sites) with inhalation exposure: <3 

basis: unloading Liquid Product from tank trucks; EPA/OPPT Mass 

Balance Model 

Note: The respirator class is: II. Gas/vapor (all substances in 

the gas form) 

Inhalation Monitoring Data Review 

3) Uncertainty (estimate based on model, regulatory limit, or 

data not specific to industry): YES 

2)a) Exposure level > 1 mg/day? YES 

OR 

 b)Hazard rating for health of 2 or greater? NO 

Inhalation Monitoring data desired? YES (both 

criteria met) 

DERMAL: 

Exposure to Liquid at 100.00% concentration 

1,764.06 mg/day over 235 days/yr 

Number of workers (all sites) with dermal exposure: 3 

basis: Cleaning Liquid Residuals from Tank Trucks Used to 

Transport the Raw Material; EPA/OPPT 2-Hand Dermal Contact with 

Liquids Model. 
REVISED INITIAL REVIEW ENGINEERING REPORT 

PMN: 04-0319 

USE 1: Component of Printing Inks at 30-40% formulation, 

assume 30% PV (4.5 MM kg/yr) 

Number of Sites: < 6,458 

Days/yr: 250 (CEB standard default) 

Basis: Number of unknown user sites from Generic Scenario for Use 

of Printing Inks (1994): 3,000,000 kg/yr x 59,505 (sites in 

industry) / 30 to 40% PMN / 138E6 (PV of industry) = 4851 to 6458 

sites) 

Process Description: unload PMN (30-40% in ink formulation) from 

containers -> transfer to printing press -> rollers -> paper -> 

all volatile components evaporate from paper into the atmosphere 

(per generic scenario) 

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY 

WATER 

Not expected per generic scenario. 

AIR 

2.6 kg/site-day over 250 Days/yr 

from: evaporation 

basis: Per generic scenario, assume all solvent portion of the 

ink is released to the atmosphere. (4,500,000 kg/yr - cleaning 

and container residue losses 225,000 kg/yr) / 250 days/yr / 1,437 

sites = 2.6 kg/site-day 

INCINERATION OR LANDFILL: 

225,000 kg/yr 

from: equipment cleaning and container residue 

basis: CEB std. est for entire process equipment cleaning is 2% 

and liquid container residue is 3% -> 4,500,000 kg/yr x 5% = 

225,000 kg/yr 
REVISED INITIAL REVIEW ENGINEERING REPORT 

PMN: 04-0319 

USE 1 (continued): 

OCCUPATIONAL EXPOSURES Summary 

Tot. # of workers: <38,700 (generic scenario: 5-6 per site) 

Days/yr: 250 (CEB standard default) 

INHALATION 

Exposures to vapor (Class II) 

Worst: <4,200 mg/day over 250 Days/yr 

Typical: 140 mg/day over 250 Days/yr 

basis: Generic scenario and open surface and transfer models 

vapor generation spreadsheet: 3 ft diameter open surface over 8 

hours 

Number of workers with inhalation exposure: <25,900 

Note: The respirator class is: II. Gas/vapor (all substances in 

the gas form) 

Inhalation Monitoring Data Review 

4) Uncertainty (estimate based on model, regulatory limit, or 

data not specific to industry): YES 

2)a) Exposure level > 1 mg/day? YES 

OR 

 b)Hazard rating for health of 2 or greater? NO 

Inhalation Monitoring data desired? YES (both 

criteria met) 

DERMAL: 

Exposure to Liquid at 30-40% concentration 

720 mg/day over 15 days/yr 

Number of workers (all sites) with dermal exposure: <25,900 

basis: Incidental contact, 2 hands (transferring liquids, per 

generic scenario) 
REVISED INITIAL REVIEW ENGINEERING REPORT 

PMN: 04-0319 

USE 2: Cleaning solvent at 50% PMN, 20% of PV (3,000,000 kg/yr) 

Number of Sites: <200 unknown user sites (generic scenario) 

Days/yr: 345 (generic scenario for wet cleaning process in IC 

fabrication) 

Process Description: (CEB assumption) unload PMN directly to 

treatment tank or in the case of use in aqueous process, transfer 

to dilution tank for dilution with water where it is diluted to 

5% PMN (as in generic scenario for wet cleaning process in IC 

fabrication) => clean parts in bath => rinse parts (from Past 

case: ) 

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY 

WATER:

Not expected, waste incinerated 

INCINERATION OR LANDFILL: 

2,900,000 kg/yr 

from: spent bath, container residue 

basis: Assume all of spent solvent is disposed. 

AIR: 

0.88 kg/site-day over 345 Days/year 

from: evaporation, open surface 

basis: Open surface model vapor generation spreadsheet. 3 feet 

open surface over 24 hours - 0.8832 kg/day 
REVISED INITIAL REVIEW ENGINEERING REPORT 

PMN: 04-0319 

USE 2 (continued) 

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY 

Tot. # of workers: 600 (1 worker per shift, 3 shifts per generic 

scenario) 

Days/yr: 345 (generic scenario for wet cleaning process in IC 

fabrication) 

INHALATION: 

Not expected, cleaning is all done in closed systems. 

DERMAL: 

Exposure to Liquid at 50% concentration 

882 mg/day over 345 days/yr 

Number of workers (all sites) with dermal exposure: 600 

basis: EPA/OPPT 2-Hand Dermal Contact with Liquids Model. 
REVISED INITIAL REVIEW ENGINEERING REPORT 

PMN: 04-0319 

USE 3: Indoor heating oil at 100% PMN for 20% of PV (3,000,000 

kg/yr) 

Number of Sites: 100's unknown user sites (CEB assumption) 

Days/yr: 250 (CEB std est.) 

Process Description: Unload PMN from tank truck (100% PMN) => 

transferred to storage tank => PMN sent to furnace/burner => PMN 

combusted (CEB assumption). 

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY 

INCINERATION: 3,000,000 kg/yr over 250 days/yr 

from: Burner and container residue 

basis: PMN is used as heating oil. All PMN is burned. 

Water / Landfill: not expected 

Air: negligible kg/site-yr 
REVISED INITIAL REVIEW ENGINEERING REPORT 

PMN: 04-0319 

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY 

Tot. # of workers: 100's (CEB std. est. <3/site) 

Days/yr: 250 (CEB std est.) 

INHALATION: 

Exposure to vapors (Class II) 

Worst: 6.9 mg/day over 250 Days/yr 

Typical: 0.23 mg/day over 250 Days/yr 

Number of workers with inhalation exposure: 100's 

basis: Generic scenario and open surface and transfer models 

vapor generation spreadsheet: 2 inch diameter open surface over 1 

hours for transferring liquid 

Note: The respirator class is: II. Gas/vapor (all substances in 

the gas form) 

Inhalation Monitoring Data Review 

5) Uncertainty (estimate based on model, regulatory limit, or 

data not specific to industry): YES 

2)a) Exposure level > 1 mg/day? YES 

OR 

 b) Hazard rating for health of 2 or greater? NO 

Inhalation Monitoring data desired? YES 

DERMAL: 

Exposure to liquid at 100% concentration: 

1764.00 mg/day over 250 days/yr 

basis: EPA/OPPT 2-Hand Dermal Contact with Liquids Model. 
REVISED INITIAL REVIEW ENGINEERING REPORT 

PMN: 04-0319 

USE 4: Paints used at 30% PMN for 30% PV (4,500,000 kg/yr) 

Site/Location: 8 companies purchasing formulated paint

(per submitter) 

Days/yr: 200 (CEB assumption) 

Basis: submitter claimed that there will be 8 end users using the 

architectural coating containing PMN substance 

Since it is most likely be outside, assume 200 days/year. 

Process Description: Paint formulation is unloaded from 

containers (30% PMN) => transferred to application equipment 

(rollers or spraying) => rolling or spraying application => cured 

onto substrate (CEB assumption) 

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY 

WATER: 

Not expected 

basis: submitter claimed there will not be any water releases 

during this use. 

INCINERATION -OR- LANDFILL: 

225,000 kg/yr 

from: equipment cleaning and container residue 

basis: CEB std. est. for entire process equipment cleaning is 2% 

and liquid container residue is 3% -> 4,500,000 kg/yr x 5% = 

225,000 kg/yr 

AIR: 

2670 kg/site-day over 2 Days/year over 100 sites 

from: evaporation during curing or drying of paint 

basis: All PMN is evaporated since the PMN chemical is volatile. 

(4,500,000 kg/yr - 225,000) / 8 / 200 = 2,670 kg/site-day 

assume 2 days/site => 100 sites 
REVISED INITIAL REVIEW ENGINEERING REPORT 

PMN: 04-0319 

USE 4: continued 

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY 

Tot. # of workers: 160 (assume 20 workers per crew) 

Days/yr: 250 (CEB std. est.) 

INHALATION: 

Exposure to mist (Class III) 

Roll coating

0.14-0.91 mg/day over 250 Days/yr 

Spraying

53 mg/day over 250 Days/yr 

Number of workers with inhalation exposure: 540 

basis: Generic scenarios for UV curable roll coating and 

Automotive spraying. Roll coating: 0.04 to 0.26 mg/m3 x 1.25 

m3/hr x 8 hrs/day x 0.35 PMN = 0.14 to 0.91 mg/day. Spraying: 15 

mg/m3 x 1.25 m3/hr x 8hr x 0.35 PMN = 52.5 mg/day 

Note: The respirator class is: III. Combination Gas/Vapor and 

Particulate (gas and liquid/solid physical forms are both 

present: a good example is paint spray mist, which contains both 

liquid droplets and vapor). 

Inhalation Monitoring Data Review 

1) Uncertainty (estimate based on model, regulatory limit, or 

data not specific to industry): YES 

2)a) Exposure level > 1 mg/day? YES 

OR 

 b) Hazard rating for health of 2 or greater? NO 

Inhalation Monitoring data desired? YES 

DERMAL: 

Exposure to Liquid at 30% concentration: 

up to 3,000 mg/day over 250 days/yr 

Basis: EPA/OPPT 2-Hand Dermal Immersion in Liquids Model. 
REVISED INITIAL REVIEW ENGINEERING REPORT 

PMN: 04-0319 

CBI CONTACT REPORT 

(Telephone Log) 

PMN: 04-0319 

Call By: Dan Roper(ERG) for EPA/OPPT/CEB 

Call To: Cynthia Bishop (Gardere) 214.99.4506 

Submitter: Transmare Houston Inc. 

Date: February 23, 2004 

Time: 9:45 am 

Submitter was contacted to confirm that P-04-319 is the same 

substance with the same uses as . Previous contact report 

follows with notes in bold.