### Human Exposure and Environmental Release (Continuation Sheet for page 9 of PMN Form)

Section A - - Industrial Sites Controlled by the Submitter

2. Occupat ional Exposure – during the production of

This attachment is the basis for the information submitted under “Occupational Exposure” of this

PMN for the use New Chemical Su bstance (NCS) at plant.

General Process Information

The production of is carried out in several continuous processing and distillation

units . Due to the potential hazards associated with the use of flammable, corrosive, or toxic substances, guidelines require that all vessels or other units be operated as a “closed” system and inerted with nitrogen during normal charging, reaction, or transfer operations and also be process

- piped wherever possible. It should also be noted that the NCS processing with the most potential for chemical exposure is taking samples. However, to insu re against exposure, all chemical operators are required to use appropriate personal protective equipment for all sampling operations and all plant sampling operations utilize closed sampling
systems

. The trucks used for shipping the for sulfur recovery are s ampled with PPE (gloves and eye protection).

If inspection or repairs are required during production, which is a rare occurrence, these will only be undertaken after a thorough clean out of the involved equipment according to corporat e standard operating procedures including the need for an approved safety work permit. In addition, all maintenance personnel must use all protective equipment as outlined in the associated standard operating procedures. Thus, there is no potential of exposure to the NCS for these workers. There is also no potential of exposure for supervisory personnel as they are only rarely in close proximity to any chemical processing area, and in the rare instances that they are, they are required to wear appropriate protective equipment.

There is a potential for exposure to for the laboratory technicians who assay the process samples some of which contain the NCS. However, to minimize this exposure, all laboratory technicians are required to wear appropriate personal protection equipment and to follow prudent laboratory practices.

Based on the above, worker activities required for the use of the NCS, which result in the potential for occupational exposure, are described in further detail the following

sections of this attachment

.

Occupational Exposure 2(1): Worker Activities (Involving Exposure), 2(3): Protective Equipment/Engineering Controls, & 2(5): Physical Form(s )

Routine Batch Sampling : R outine sampling activities will occur at various times in the continuous processing. During sampling, the material handlers/chemical operators will wear

appropr iate protective equipment (gloves and eye protection ) . A description of each likely sample stream including the number of samples to be taken, the physical form, stream temperature, and percent uracil NCS in the stream are listed below. In addition to the routine number of samples to be taken for each batch, the number of samples that may be taken durin g
the start

- up of a campaign is also shown in the Sampling Table below.Routine Number (Start

- up Number) Physical Temper

- % NCS

Process Step Stream Description of Samples Form ature in Stream

NCS 1/day L iquid Ambie nt 100 %

NCS 1/day Liquid 250 oF 100 %

NCS (1) /day Liquid ~375 - 390 o F 100 %

NCS 1 /day Liquid 375 – 390 oF 100 %

NCS (1 )/day Liquid ? oF 100 %

NCS 3/week Liquid 150 oF 100 %

Note t hat a sample is normally taken from ; however, if is out of service, the sample is taken from . A sample is normally taken from , which is connected to

the bottom of . If is out of service, the sample is taken f rom bottoms. A sample is normally not taken from

.

As indicated in the Sampling Table above, there is a potential for expo sure during routine sampling of the process streams to produce the

Sample Analysis: To minimize exposure to any chemicals, laboratory technicians prepare samples for analysis in a chemical fume hood or with local ventilation. Laboratory technicians are also required to use protective equipment such as safety glasses or splash goggles, gloves, laboratory coats or aprons for any sample analysis. A description of the samples to be assayed at various times during a day including the physical

form is shown in the Sampling Table above. However, for these samples, the temperature at the

time of exposure would be “Ambient ”.

2(8) Occupational Exposures : Maximum Number of Workers in Each Activity

The chemical operators and laboratory technicians work 12 hour shifts on a 4 shift schedule which runs seven days/week. This rotation results in th at a given chemical operator/laboratory

technician is working 10.5 days every two weeks. This is approximately 75% of the

manufact uring days. For the production of it is assumed that five chemical
operators

, but only two take samples and 3 laboratory technicians, will be required for each 12

- hour shift. Thus, potentially 2 chemical operators and 3 laboratory technician may be exposed

to the NCS during each 12 hour shift.

Based on the above analysis, activities for which occupational exposures can occur and the number of employees that could potentially be exposed are summarized below:

1. Ro utine batch sampling involves 8 chem ical operators (2 chemical operators for each of the 4 shifts)

2. Sample analysis involves 12 laboratory technicians (3 for each of the 4 shifts)

Thus, the maximum number of different workers who could potentially be exposed during the

use of the NCS would be 20 (8 chemical operators/material handlers and 12 laboratory technicians).

2(10) Occupational Exposure: M aximum Duration of Exposure in Hours/Day

The maximum duration of exposures during the use of the PCM NCS is estimated based on the operation description. It should be noted that any actual exposure is not the duration of the activity itself, since the la tter information is of limited value in evaluating the extent of the

exposure.Routine Process Sampling: As indicated previously , the present samp ling scenario for the

process shows that the expected number of samples/day involving the significant potential for
exposure to is 4 /day. Thus, normally the 2 chemical operators working over the

c ourse of a 12

- hour shift or 0.5 day will conduct 2 sampling operations. The maximum exposure for chemical operators during a batch sampling operation is expected to be approximately 15 minutes per sample. Assuming that each chemical operator performs a similar number of sampling opera tions, this translates to 1 sampling opera tions/day/chem ical operator (2/2). Thus, the duration of exposure for e ach of the 8 chemical operators is estimated

to be 0.25 ho urs/day/chemical operator (1 x0.25).

Sample Analysis: Maximum exposure for the laboratory technicians during any single sample analysis activity is expected to be approximately 20 minutes per sample. As indicated above, the

exp ected number of samples/year involving the potential for exposure to is 3x330 days = 990 routine samples

. Thus, the three laboratory technicians working over the course of a

12

- hour shift will assay 1.5 samples (3 x 0.5 day). Assuming each laboratory technician performs a similar number of analyses, th is translates to 0.17 analyses/day/laboratory technician (0.5 /3 ). Thus, the maximum daily exposure for each of the laboratory technicians is estima ted to b e 0.06 hours/day/laboratory technician ( 0.17x0.333 = 0.06 ).

2(11) Occupational Exposure: Maximum Duration of Activity in Days/Year

It is estimated that the use of the N C S on this scale could require up to 330 days at the one year maximum volume anticipated. Using this number of manufacturing days and assuming each chemical operator and laboratory technician works on approximately 75% of the manufacturing days (see the previous page for how this % was arrived at), these workers can be exposed to

the PCM NCS on approximately 251 days each year.

### Part II - - Human Exposure and Environmental Release (Continuation Sheet **for page 9 of PMN Form)**

Section A - - Industrial Sites Controlled by the Submitter

3. Environmental Release and Disposal – For the production of

The following discussion addresses t he waste streams from production of the NCS and how these waste streams are handled and disposed.

3(1) Identity of the Release Numbers (Release Points)

During normal production, there a re no releases of the NCS to the environment . Since all the organic streams that comprise the come from phase splits from an aqueous phase, it is possible that a small amount of remain in the aqueous layer. All the

aqueous waste is disposed of on

- site via the deep well. Before the aqueous is sent to the deep well, there is a final split of residual organic material that is added to the rest of the

Vessels that contain are only cleaned at the end of a campaign or before maintenance. When they are cleaned, they are cleaned with caustic and steam

, and the clean

out solution is transferred to the aqueous waste system for eventual on site deep well injection.



### Industrial H ygiene Plan

The Industrial Hygiene Program at all plants is comprehensive and covers all the requirements outlined by the corporation as well as OSHA regulations. Written standards, tailored to the specific needs of each plant, have also been docume nted.

Specific aspects of the program include:

1. Appropriate personnel monitoring of employees for airborne contaminants (dusts and vapors) and physical hazards (noise). Exposure results are posted in the operating areas monitored, and reports are issued directly to the employees being monitored.

2. A record system, including an employee file to maintain documentation of all industrial hygiene related training and respirator fit testing.

3. Control over all chemical substances introduced into the plant, including approval prior to

such use.

4. Listings of chemical exposure by job description (as outlined in Industrial Hygiene Exposure Assessment Program) for the chemicals that are handled.

5. Respirator training and fitting program.

6. Basic design criteria such that all processes are carried out as closed vessel operation to as great an extent as possible.

7. Use of local exhaust ventilation and personal protective equipment where opening of otherwise closed system is required, e.g. for sampling, charging, transfe r operations, equipment inspections/flushing etc.

8. Approved areas for eating and smoking.9. A personal hygiene and clothing program under which employees are given freshly laundered clothing to start each shift and encouraged or required to shower and chang e clothing at the end of the shift.

10. Written operating instructions used by production employees which outline the hazards of each chemical substance used in the process and the special precautions which must be followed in handling it.

11. A system of safety work permits used by maintenance employees, which outline special precautions, required for each job.

12. Monthly plant keeping inspections, which are performed in each operating department.

13. Disciplinary actions for failure to follow established rules. Thi s policy applies to both hourly and supervisory personnel.

14. Routine annual or biennial physical examination for all employees by an in

- plant Medical Department (for small plants the examination is performed by a pre

- selected outside physician and the resul ts and records sent to the company).

15. Firefighting training is given to all employees based on the level of protection a facility has chosen to comply with under OSHA Subpart ”L” Standard first aid training is also highly

recommended.



### Emergency Related Pr ocedures

Emergency related procedures include:

1. Fire brigade and/or emergency response teams trained and equipped to comply with OSHA Subpart “L” 1910.130.

2. Written instructions used by production operators, which outline the hazards associated with

any job, they are expected to perform and including routine precautions for handling all chemical substances involved in their work. Clean up procedures for minor and major spills

are included.

3. When a spill extends beyond the capabilities of the local person nel, the emergency response team will be called. Emergency evaluation procedures exist for each building.

4. Any new process or modification of an existing process must undergo a Hazards and Operability Review (HAZ

- OP). Before the process is actually started up or modification implemented, a Pre Startup Safety Review (PSSR) must also be completed to insure that the items raised during the HAZ

- OP have been adequately addressed. Any additional action items raised during the PSSR must be addressed befor e start

- up.

### Engineering Safeguards

Safeguards to Prevent Worker Exposure

1. This section describes the general Industrial Hygiene Program maintained by the Company. The proper breathing, eye protection, and protective clothing (chemical resistant suits) have been designated for each process after careful study to insure compatibility with th e chemicals in use. This insures that the protective devices will provide the workers with the best possible protection.

2. Eyewash and shower stations are located in close proximity to the reactors and sampling points. All of the samples with the exceptio n of sampling the truck are also taken using an enclosed sampling device, which is designed to minimize the exposure of the operator to the
process stream.

3. At the use site for the NCS, the equipment has been designed to be operated as a closed

process sys tem whenever possible. Solid handling is minimized by the use of automated centrifuges and drum emptying equipment that will limit the operator’s exposure to the NCS and other chemicals. This along with protective equipment should eliminate worker

exposur e to the NCS.

4. Reactors normal vents are ven ted to incinerators . Local building specific ventilation consists of two separate systems using two exhaust fans located on the roof.



### Safeguards to Prevent Fire

During the use of the NCS the reactors will alwa ys be inerted to a thermal oxidizer and a set nitrogen purge. To prevent static build up, equipment will also be properly bonded and grounded. Liquid free falls will also be avoided.