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. Page 1p130237.eng 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 Page 3p130237.eng 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 Page 4p130237.eng 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 Page 5p130237.eng 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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