INITIAL REVIEW ENGINEERING REPORT

PMN: 06-0263 263/264/266/267 Focus Ready Draft 2/9/2006

ENGINEER: Hall \ AMO PV (kg/yr): 236,000 YX

SUBMITTER: Champion Technologies

USE: Hydrate inhibitor for oil and gas wells, production pipelines and flowlines. C onsolidated set: P-02-0262-267.

OTHER USES:

MSDS: Label: No

Gen Eqpt: Respirator:

Health Effects:

TLV/PEL: none established

CRSS (02/06/2006):

Chemical Name: S-H20: Dispersible g/L @ VP: 1.0E-6 torr @

MW: 440.72 %<500 %<1000 Physical State and Misc CRSS Info:

Chemical Name:

Consumer Use: No

SAT (concerns) (02/07/2006): Migration to groundw ater: Negligible PBT rating: P1B1T2 Health: 2 Dermal, Inhalation, XB Testing (Testing desired) Eco: 3 Water (All releases to water), XB Testing (Testing desired)

OCCUPATIONAL EXPOSURE RATING: 1C

NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER. This IRER is for th e consolidated set of chemicals P06-0263/264/266/267. The production vol ume for each chemical is 236,000 kg/yr and all estimates are for each PMN (not a combination). A separate IRER has been completed for these chemicals. Any changes to this IRER may effect the other IRER.

P06-0263/264/266/267 are used as a hydrate inhibitor in oil and gas well applications. Three same submitter/same use pastcase referenced for consistency are: . Inhalatio n exposure was negligible in all three past cases (consistent with this IRER). All three reference the

Generic Scenario for Oil Well Treatment Chemicals for some end use information (consistent with this IRER). Water release are expect ed from at the use sites in (not consistent with this IRER). to the manufacturing site in (consistent w ith this IRER per submission information).

POLLUTION PREVENTION CONSIDERATIONS:INITIAL REVIEW ENGINEERING REPORT

PMN: 06-0263 263/264/266/267

MFG: Manufacture of P06-0263/264/266/267,

EXPOSURE-BASED REVIEW: Yes (1 criteria met)

1) # of workers exposed: 305 >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: Yes

Number of Sites/ Location: 1 Corsicana Technologies Corsicana TX 75110 Days/yr: 47

Basis:

Process Description:

ENVIRONMENTAL RELEASE S ESTIMATE SUMMARY Air - negligible (VP<0.001 torr)| Land - not required, per SAT.

Water or Incineration Conservative: 5.0E+1 kg/site-day over 4 days/yr from 1 site or 2.0E+2 kg/yr to: Water, Incineration, or

from:

basis:

Water or Incineration High End: 1.5E+2 kg/site-day over 47 days/yr from 1 site or 7.1E+3 kg/yr

to: Water or Incineration

from:

basis:

RELEASE TOTAL 7.3E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers expose d via assessed routes:

Basis:

Inhalation:

Dermal:INITIAL REVIEW ENGINEERING REPORT

PMN: 06-0263 263/264/266/267

USE: Hydrate Inhibitor for Oil and Gas Wells and Pipelines

Number of Sites/ Location: 50 unknown site(s) Days/yr: 350

Basis: Submission states 50 site s and 18 days/yr. Per generic scenario, site operates 350 days /yr. CEB assumes PMN unloaded 18 days/yr.

Process Description:

ENVIRONMENTAL RELEASE S ESTIMATE SUMMARY Air - negligible (VP<0.001 torr) | | Land - not required, per SA T.| | Water - not expected,

Incineration Output 2: 6.8E+2 kg/site-day over 3 days/yr from 50 sites or 1.0E+5 kg/yr

to:
from:

basis:

RELEASE TOTAL 1.0E+5 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers expose d via assessed routes:

Basis:

Inhalation:

Dermal: