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 controlled
file:///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 sites
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: 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 , 0448
file:///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 sites
file:///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 sites
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:

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

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

-