file:///C|/Documents%20and%20Settings/jquennev/Desktop/p090447c.en2.txt[3/4/2013 12:10:35 PM] INITIAL REVIEW ENGINEERING REPORT PMN: 09-0447 , 0448 Post-Focus Draft Revision 2 12/20/2012

ENGINEER: Macek/Austin \ ERG PV (kg/yr):file:///C|/Documents%20and%20Settings/jquennev/Desktop/p090447c.en2.txt[3/4/2013 12:10:35 PM] SAT (concerns) (07/07/2009): Migration to groundwater: negligible to slow PBT rating: P2B2T1 Health: 1-2 Dermal, Inhalation Eco: 2 Water (All releases to water with a CC = 37 ppb)

OCCUPATIONAL EXPOSURE RATING: 1B

NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER.file:///C|/Documents%20and%20Settings/jquennev/Desktop/p090447c.en2.txt[3/4/2013 12:10:35 PM] INITIAL REVIEW ENGINEERING REPORT PMN: 09-0447 , 0448

Process Description: Charge raw materials to reactor --> Hydrolysis rxn --> transferred to bulk storage tanks and dispensed into trucks and rail cars

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. Per terms of the consent order and assuming compliance, release to water will be controlledfile:///C|/Documents%20and%20Settings/jquennev/Desktop/p090447c.en2.txt[3/4/2013 12:10:35 PM] such that the concentration of the PMN substance in receiving streams will be less than 10 ppb.

Incineration High End: 2.3E+2 kg/site-day over 7 days/yr from 1 site or 1.6E+3 kg/yr to: Incineration from: Equipment Cleaning Losses of Liquids from Multiple Vessels basis: EPA/OPPT Single Vessel Residual Model (for reactor), CEB standard 0.2% residual for gravity drain. In amendment from submitter (11/08/11), the submitter indicated that all vessels are conical bottom with gravity drain. CEB used default of 0.2% (compared to standard default of 1%) for gravity drain. Amendment also provided details on cleaning procedures. Submitter stated that material is campaigned. Cleaning occurs upon completion of the campaign. The wash process is done with a compatible solvent, the wash out material is reused in future batches of intermediate or finished product or is disposed of at an approved waste disposal facility according to local regulatory requirements. In subsequent phone call held on November 10, 2011 with EPA New Chemicals staff, the submitter further specified that any washout material that is not reused would be incinerated (Ref: E-mail from Kristan Markey, EPA/CCD to Greg Macek, EPA/CEB on January 11, 2012). CEB assumes infrequent cleanup (up to 7 times per year - assuming a campaign runs for 5 days), 0.2% loss and disposal by incineration.

RELEASE TOTAL 1.6E+3 kg/yr - all sitesfile:///C|/Documents%20and%20Settings/jquennev/Desktop/p090447c.en2.txt[3/4/2013 12:10:35 PM] INITIAL REVIEW ENGINEERING REPORT PMN: 09-0447 , 0448

Process Description: PMN is unloaded from tank trucks --> dedicated formulation tank to produce

in final blend --> pumping directly into well --> formulation will effectively remain in the wells permanently (per 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. Per terms of the consent order and assuming compliance, releases to water will be controlled such that the concentration of the PMN substance in receiving streams will be less than 10 ppb.

Deepwell Injection Output 2: 8.5E+2 kg/site-day over 350 days/yr from 1 site or 3.0E+5 kg/yr to: deepwell injection (per submission) from: Deep Well Injection basis: User-Defined Loss Rate Model. Submission states the formulation will be deep well injected and left underground; only trace amounts will remain in the oil--consistent with GS: the enhanced oil recovery process will result in the release of injection fluid and the PMN material to underground oil reservoirs. Subtracting upstream losses, LF = 1-(0.002+0.02/250) = 0.file:///C|/Documents%20and%20Settings/jquennev/Desktop/p090447c.en2.txt [3/4/2013 12:10:35 PM] 9972. (0.02 is divided by 250, because equipment cleaning is assumed once per year).

Deepwell Injection Conservative: 1.7E+1 kg/site-day over 1 day/yr from 1 site or 1.7E+1 kg/yr to: Deepwell Injection from: Equipment Cleaning Losses of Liquids from Multiple Vessels basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual. Submitter stated bulk tanks are dedicated throughout theri service life. The equipment and storage vessels will be washed only once at end of service life. This is consistent with CEB's Oil Production chemicals scenario (2011) and CEB assumes 1 cleanup per site-yr. Submitter stated that wash solution is injected into enhanced oil recovery well. Stepan has also indicated that they would provide written communication to their customers that that tank cleanout and final disposal following use would be via deepwell injection. CEB assesses deepwell injection as the most likely media of release. Release may be to other media but that is considered less likely.

Other High End: 3.8E+1 kg/site-day over 18 days/yr from 1 site or 6.8E+2 kg/yr to: Incineration or Deepwell Injection from: Cleaning Liquid Residuals from Tank Trucks Used to Transport the Raw Material basis: User-Defined Loss Rate Model. CEB assumes 1 sites. Submitter estimated 18 tank wagons. Release quantity based on 5,000 gallons per tank truck, density of 3.785 kg/gal, and CEB standard default of 0 .2% residue in a tank truck. 5,000 x 3.785 x 0.2% = 38 kg of P-09-0447/448 per cleaning. CEB assumes deepwell injection or incineration as the most likely media of release for this release source. Media of release is based on information provided by the submitter in an amendment to EPA dated 12/26/11. Submitter provided their SOP for managing transportation container cleaning residues. The submitter stated that they will enter into a contract with the transporation vendor. This contract will stipulate that the containers will be handled by one of three methods:| | 1. Cleaned with solvent with cleaning residue then deep well injected at the customer's site (if permits allow).| 2. Returned to Stepan Company location where the containers will be:| a. reused without cleaning| b. cleaned but the rinsate reused| c. cleaned and the rinsate incinerated.| 3. Shipped to a 3rd party waste handler designated by Stepan Company where the containers will be:| a. reused without cleaning| b. cleaned and the rinsate resued|file:///C|/Documents%20and%20Settings/jquennev/Desktop/p090447c.en2.txt[3/4/2013 12:10:35 PM] c. cleaned and the rinsate disposed of by i ncineration.| Based on these commitments by the submitter, CEB asumes incineration or deepwell injection as the most likely media of release for any cleaning residue.|

RELEASE TOTAL 3.0E+5 kg/yr - all sites

INITIAL REVIEW ENGINEERING REPORT PMN: 09-0447 , 0448file:///C|/Documents%20and%20Settings/jquennev/Desktop/p090447c.en2.txt[3/4/2013 12:10:35 PM] Process Description: PMN is unloaded from rail cars --> dedicated formulation tank to produce in final blend --> pumping directly into well --> formulation will effectively remain in the wells permanently (per 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. Per terms of the consent order and assuming compliance, releases to water will be controlled such that the concentration of the PMN substance in receiving streams will be les than 10 ppb.

Deepwell Injection Output 2: 1.7E+3 kg/site-day over 350 days/yr from 2 sites or 1.2E+6 kg/yr to: deepwell injection (per submission) from: Deep Well Injection basis: User-Defined Loss Rate Model. Submission states the formulation will be deep well injected and left underground; only trace amounts will remain in the oil--consistent with GS: the enhanced oil recovery process will result in the release of injection fluid and the PMN material to underground oil reservoirs. Subtracting upstream losses, LF = 1-(0.02/250) = 0.99992. (0.02 is divided by 250 beacuse equipment cleaning is assumed once per year.)

Deepwell Injection Conservative: 3.4E+1 kg/site-day over 1 day/yr from 2 sites or 6.9E+1 kg/yr to: Deepwell Injection from: Equipment Cleaning Losses of Liquids from Multiple Vessels basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual. Submitter stated bulk tanks are dedicated throughout their service life. The equipment and storage vessels will be washed only once at end of service life. This is consistent with CEB's Oil Production chemicals scenario (2011) and CEB assumes 1 cleanup per site-yr. Submitter stated that wash solution is injected into enhanced oil recovery well. Stepan has also indicated that they would provide written communication to their customers that that tank cleanout and final disposal following use would be via deepwell injection. CEB assesses deepwell injection as the most likely media of release. Release may be to other media but that is considered less likely.

Other Output 2: 1.5E+2 kg/site-day over 7 days/yr from 2 sitesfile:///C|/Documents%20and%20Settings/jquennev/Desktop/p090447c.en2.txt[3/4/2013 12:10:35 PM] or 2.1E+3 kg/yr to: Incineration or Deepwell Injection from: Cleaning Liquid residuals from railcars basis: User-Defined Loss Rate Model. CEB assumes 1 sites. In 11/08/11 amendment, the submitter estimated 14 railcars total (CEB assumes 7 for each of the 2 sites). Release quantity based on 20,000 gallons per railcar, density of 3.785 kg/gal, and CEB standard default of 0.2% residue in a railcar. 20,000 x 3.785 x 0.2% = 151 kg of P-09-0447/448 per cleaning. CEB assumes deepwell injection or incineration as the most likely media of release for this release source. Media of release is based on information provided by the submitter in an amendment to EPA dated 12/26/11. Submitter provided their SOP for managing transportation container cleaning residues. The submitter stated that they will enter into a contract with the transporation vendor. This contract will stipulate that the containers will be handled by one of three methods:| | 1. Cleaned with solvent with cleaning residue then deep well injected at the customer's site (if permits allow).| 2. Returned to Stepan Company location where the containers will be:| a. reused without cleaning| b. cleaned but the rinsate reused| c. cleaned and the rinsate incinerated.| 3. Shipped to a 3rd party waste handler designated by Stepan Company where the containers will be:| a. reused without cleaning| b. cleaned and the rinsate resued| c. cleaned and the rinsate disposed of by i ncineration.| Based on these commitments by the submitter, CEB asumes incineration or deepwell injection as the most likely media of release for any cleaning residue.|

RELEASE TOTAL 1.2E+6 kg/yr - all sitesfile:///C|/Documents%20and%20Settings/jquennev/Desktop/p090447c.en2.txt[3/4/2013 12:10:35 PM] INITIAL REVIEW ENGINEERING REPORT PMN: 09-0447 , 0448

Process Description:

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARYfile:///C|/Documents%20and%20Settings/jquennev/Desktop/p090447c.en2.txt [3/4/2013 12:10:35 PM] -