p130237.eng

INITIAL REVIEW ENGINEERING REPORT 

PMN: 13-0237

Focus Ready Draft 3/21/2013

ENGINEER: Jon \ JAS

PV (kg/yr): 5,079,900 YX

SUBMITTER: Tire Recycling & Processing LLC

USE: Raw feedstock for refineries.

OTHER USES: Analog is used as a cutter stock for

Fuel Oil No. 6 to power industrial boilers, or for Marine

Diesel Oil to power marine engines. Analog is

used as a fuel for industrial boilers, a marine fuel, a

solvent for industrial degreasers of dissolving agent,

and an oil extender in oil blends. Analogs and

 are used as naphtha in high octane gas and

cleaning fluids, kerosene for jet fuels, fuel oil for

diesel engines and power generation, and vacuum gas oil

for gasoline. Analog is used as a gasification

feedstock for producing CO and H2.

MSDS: Yes Label: No

Gen Eqpt: protective gloves: nitrile, viton / Goggles,

safety glasses, face shield. Full face respirator if eye

irritation occurs. / Apron or overalls to prevent

staining and exposure to skin / Use process enclosures,

explosion proof local exhaust and general ventilation to

maintain airborne concentrations below the applicable

exposure limits. Store away from heat and flame.

Respirator: Maintain atmospheric levels below exposure

limits. SCBA or respirator when liquid is warm.

Health Effects: Flammable. // Eyes (acute): Mild to

severe irritation, redness, burning, blurred vision //

Skin (acute): Mild irritation, burning, drying, flaking,

staining // Inhalation (acute): Over exposure can cause

dizziness, disorientation, headache, nausea, fatigue and

lung congestion. // Ingestion (acute): Over exposure can

cause irritation to mouth, throat, stomach, headache,

gastrointestinal irritation, narcosis, vomiting, diarrhea,

 jaundice, coma and hemolytic anemia.

TLV/PEL:

Benzene 5 % 1 ppm OSHA PEL

Xylene 13 % 200 ppm OSHA PEL

Naphthalene 2 % 10 ppm OSHA PEL

Toluene 6 % 200 ppm OSHA PEL

CRSS :

Chemical Name: Tires, wastes, pyrolyzed, C5-15 condensate

oil fraction Definition: A complex combination of

hydrocarbons obtained from the substance produced by the

pyrolysis of rubber-based tires after removal of the

carbon black fraction. It consists predominantly of

S-H20: 0.00757 g/L @

VP: 1.6E+0 torr @

MW: 136.00 %<500 %<1000

Physical State and Misc CRSS Info:

Neat: Liquid Mfg: Liquid Proc/Form: NA End Use: Destroyed.

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 The PMN material is a complex mixture. The composition

of the mixture is described on page 6 of this report.

Submitted Properties: Pour Point = -43.6 °F (-42 °C); BP

= 102-829 °F (38.9-442.8 °C) (Simulated Distillation), -6

to 160 °C (Definition); Flash Point = -20 °F (-29 °C), 2

°F (-17 °C) (Pensky-Martens Closed Cup); Autoignition

Temperture = 800 °F (427 °C); Specific Gravity = 0.866;

Kinematic Viscosity = 1.48 cSt at 40 °F, 1.76 cSt at 100

°F; Sulfur = 0.70%, 0.75% (XRF); Ash Content < 0.05%;

Cetane Index = 22.2; Water Content = 0.1%, 0.132%;

Sediment = 0.34%; Aromatic Hydrogen Types = 52% (HPLC);

Carbon Residue, Ramsbottom = 0.13%. Measured Properties

for Limonene (Typical Component): MP = -95 °C; BP = 176

°C; VP = 1.55 torr; WS = 0.00757 g/L; logP = 4.57

(PhysProp).

Consumer Use: No

SAT (concerns) (03/15/2013):

Related Cases and Related Cases and Misc SAT Info:

Ecotox Related Cases: Analogs: .

Migration to groundwater: Moderate

PBT rating: P1B2T2 .

Health: 2 Dermal, Drinking Water, Inhalation

Eco: 3 Water (All releases to water with a CC = 4 ppb. ),

XB Testing (Testing desired)

OCCUPATIONAL EXPOSURE RATING: 2-3B

NOTES & KEY ASSUMPTIONS:

Generated by the 06/07/2005 version of ChemSTEER. 

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POLLUTION PREVENTION CONSIDERATIONS:

P2 Claim: 1. Reduction in waste tire sites in south

Texas and the environmental impact from such sites. 2.

Scrap tires must be managed to control fires and human

disease vectors (mosquitoes, rats, snakes). 3. Recycling

of a waste stream (tires) into oil to reduce dependence

on foriegn oil.

EXPOSURE-BASED REVIEW: Yes (0 criteria met)

1) # of workers exposed: 17 >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: 13-0237

Manufacturing: Batch

Number of Sites/ Location: 1

Tire Recycling and Processing LLC Harlingen TX 78550

Days/yr: 350

Basis: Submission: 1 site, 14,514 kg/batch, 24 hr/batch.

350 batches/yr.

Process Description: Raw materials (tire waste) added to

pyrolysis reactors --> Heated to 450 degrees C -->

Oil/gas separator and condensers --> Oil pumped to oil

storage tanks (2-10,000 gal) --> Product loaded on tanker

trucks (liquid mixture, 100%) (per submission and CRSS).

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.

Water or Incineration or Landfill

Conservative: 2.9E+2 kg/site-day over 26 days/yr from 1

site

or 7.5E+3 kg/yr

to: uncertain

from: Equipment Cleaning Losses of Liquids from Multiple

Vessels

basis: EPA/OPPT Multiple Process Vessel Residual Model,

CEB standard 2% residual. The submission states that line

purging and cleaning occurs 2 times per month, but does

not describe the media of release. CEB assumes release

occurs over 26 days.

Air

Output 2: 6.6E-1 kg/site-day over 350 days/yr from 1 site

to: fugitive air

from: Equipment Cleaning Losses of Liquids from Multiple

Vessels

basis: EPA/OPPT Mass Transfer Coefficient Model.

Air

Typical: 1.6E-1 kg/site-day over 350 days/yr from 1 site

Worst Case: 1.6E-1 kg/site-day over 350 days/yr from 1

site

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to: fugitive air (submission)

from: Loading Liquid Product into Tank Trucks

basis: EPA/OAQPS AP-42 Loading Model. The submission

estimates a total of 0.0022 kg/day release to fugitive

air from loading operations: (1) 0.0022 kg/day from

emission point FUGL-01 and 0.00498 g/day from emission

point MSS-03. The CEB model is presented as more

conservative.

Air

Output 2: 8.8E-2 kg/site-day over 350 days/yr from 1 site

to: fugitive air (submission)

from: Fugitive Air Releases from Process Operations

basis: User-Defined Loss Rate Model. The submission

estimates the following fugitive air releases: (1) 0.

0049895 kg/day from emission point T-001; (2) 0.0802

kg/day from emission point FUGE-01; (3) 0.0022 kg/day

from emission point SSM-01; and (4) 0.1944 g/day from

emission point MSS-02 for a total of 0.088 kg/day.

RELEASE TOTAL

7.9E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 8

Basis: The submission estimates up to 8 workers. CEB

assumes exposure may occur to all workers during loading.

Inhalation:

Exposure to Vapor (Class II)

Typical: 7.9E+1 mg/day over 250 days/yr

Worst Case: 2.4E+3 mg/day over 250 days/yr

Number of workers (all sites) with inhalation exposure: 8

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

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? 2 Yes

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Exposure to Liquid at 100.00% concentration

High End: 1.8E+3 mg/day over 250 days/yr

Number of workers (all sites) with dermal exposure: 8

Basis: Loading Liquid Product into Tank Trucks; EPA/OPPT

2-Hand Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 13-0237

Use: Refinery Feedstock

Number of Sites/ Location: 3

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unknown site(s)

Days/yr: 250

Basis: The submission does not provide information on end

use. Past cases report a large variation in the use rate:

 estimates 9,100 kg/site-day (PV = 9,100,000

kg/yr, 4 sites, 250 dpy), while 

estimate 60,000 kg/site-day (PV = 15,000,000, 1 site, 250

dpy). CEB assumes the lower use rate (9,1000 kg/site-day)

to estimate the number of sites, to generate more

conservative exposure estimates (this is an

exposure-based case). CEB calculates (5,079,900 kg/yr)/(9,

100 kg/site-day)/(250 days/yr) = 2.23 sites = ~3 sites.

CEB assumes 3 sites, 250 days/yr. CS calculates 6,773.2

kg/site-day.

Process Description: PMN (liquid, 100%) delivered in tank

trucks --> unloaded to feed tanks --> PMN charged to a

series of fractionation columns --> PMN destroyed (per

past cases and CRSS).

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.

Water or Incineration or Landfill

High End: 3.8E+1 kg/site-day over 89 days/yr from 3 sites

or 1.0E+4 kg/yr

to: uncertain

from: Cleaning Liquid Residuals from Tank Trucks Used to

Transport the Raw Material

basis: EPA/OPPT Bulk Transport Residual Model, CEB

standard 0.2% residual. The submission does not discuss

releases. CEB assumes release to uncertain media.

Air

Typical: 7.7E-2 kg/site-day over 250 days/yr from 3 sites

Worst Case: 7.7E-2 kg/site-day over 250 days/yr from 3

sites

to: air

from: Unloading Liquid Raw Material from Tank Trucks

basis: EPA/OAQPS AP-42 Loading Model.

Air

Output 2: 2.6E-4 kg/site-day over 250 days/yr from 3 sites

to: air

from: Cleaning Liquid Residuals from Tank Trucks Used to

Transport the Raw Material

basis: EPA/OPPT Mass Transfer Coefficient Model.

RELEASE TOTAL

1.0E+4 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 9

Basis: The submission does not provide number of worker

estimates. CEB assumes a minimum of 3 workers/site.

Inhalation:

Exposure to Vapor (Class II)

Typical: 3.7E+1 mg/day over 250 days/yr

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Worst Case: 1.1E+3 mg/day over 250 days/yr

Number of workers (all sites) with inhalation exposure: 9

Basis: Unloading Liquid Raw Material 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

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? 2 Yes

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Exposure to Vapor (Class II)

Typical: 1.6E-3 mg/day over 250 days/yr

Worst Case: 1.4E-2 mg/day over 250 days/yr

Number of workers (all sites) with inhalation exposure: 9

Basis: Cleaning Liquid Residuals from Tank Trucks Used to

Transport the Raw Material; EPA/OPPT Mass Balance Model.

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? No

 OR

 b) Hazard Rating for health of 2 or greater? 2 Yes

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Exposure to Liquid at 100.00% concentration

High End: 1.8E+3 mg/day over 250 days/yr

Number of workers (all sites) with dermal exposure: 9

Basis: Unloading Liquid Raw Material from Tank Trucks;

EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

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