Analogs: Related Ca Migration PBT rating: P2B1T1 Health: 1 Eco: 3 Water (All releases to water with a CC = 7 ppb), XB Testing (Testing desired)OCCUPATIONAL EXPOSURE RATING: NR
NOTES & KEY ASSUMPTIONS: Generated by the 09/30/2013 version of ChemSTEER. This IRER presents an exposure based assessment; only eco testing desired. SAT concerns for water releases, migration to groundwater is slow; no exposures listed. Exposure estimates are not provided in this IRER as health testing is not desired and SAT does not indi cate any exposure concerns. PMN is import

- only; therefore manufacturing is not assesed. MSDS is not provided. The 2004 interim draft GS on Use of Additives in Papermaking is referenced for environmental releases during the USE operation. // The following d iff cases are referenced for consistency: . // For PROC: The current IRER asse pment cleaning releases to on

- site WWTP, per submitter. All past cases only asses s manufacturing and use operations. // For USE: The current IRER estimates releases based on submitter provided data and the 2004 interm draft GS on Use of Additives in Papermaking and submitter provided information. Container cleaning residuals and white

- water disposal are released to on - site waste water treatment; this IRER presents a 100% release scenario. Past cases were paper additives that were not 100% released (not defoamers). // For all operations: Dermal and inhalation exposures are not assessed a s they are not required, per SAT, and health testing is not desired.

POLLUTION PREVENTION CONSIDERATIONS: P2 Claim: Water

- based defoamers are typically used in the manufacturing of paper products. Excess foam in the process inhibits proper sheet formation, causing pinholes and loss of strength in finished product. Excess foam also inhibits drainage through the formation fabric, causing slower speeds leading to less production. Typical water

- based defoamers are not effective in temperatures over 55 ° C, so mi neral oil/silicone oil type defoamers are employed. Because of its higher melting point, water

- based defoamers made as described in this PMN should be able to handle higher temperature environments, displacing some mineral oil based defoamers. P2REC: CRSS: Forward.

EXPOSURE

- BASED REVIEW: Yes (0 criteria met) 1) # of workers exposed: 0 >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: NoINITIAL REVIEW ENGINEERING REPORT PMN: 14

- 0448 Processing: Defoamer Preparation
BASF Appleton WI Nalco Texarlana AR Nalco Vancouver WA Number of Sites/ Location: 3

Days/yr: 133 Basis: Submitter indicates 3 sites, 150 days/yr, max batch size of 300 kg PMN/day, 10% PMN in raw material and 2% PMN in product. Due to a mass balance discrepancy, CEB assumes 3 sites, 300 kg PMN/day, and 10% PMN in raw material; ChemSTEER calculates 133 bt/st

- yr. This method provides conervative environmental release estimates.

Process Description: PMN (liquid, 10%) imported in isotanks

-- > Storage Tank

-- > Mixing Tank

-- > Sampling

-- > Defoamer Formulation (li quid, 2%)

-- > Storage Tank

-- > Bulk Car to Paper Mill (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.Water Output 2: 4.0E+0 kg/site

- day over 133 days/yr from 3 sites or 5.3E+2 kg/site

- yr from 3 sites or 1.6E+3 kg/yr

- all sites to: On

- site WWTP (per submission) from: Cleaning Liquid Residuals from Isotanks Used to Transport the Raw Material basis: User

- Defined Loss Rate Model. Submitter estimates 4 kg/bt (LF~0.0133) released to on

- site WWTP from cleaning of shipping vessels. This is more conservative than the standard loss fraciton of 0.002 for bulk residuals.

Water Conservative: 6.0E+0 kg/site

- day over 133 days/yr from 3 sites or 8.0E+2 kg/site

- yr from 3 sites or 2.4E+3 kg/yr

- all sites to: On

- site WWTP (per submission) from: Equipment Cleaning Losses of Liquids from Multiple Vessels basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% residual. Submitter estimates 4.8 kg PMN/bt released from storage tank cleaning released to waste water treatment plant. CEB conservatively assesses release using the standard loss fraciton for multiple process vessels.

RELEASE TOTAL 4.0E+3 kg/yr

- all sit es

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 0 Basis:Inhalation: Inhalation not required per SAT; health testing not desired; negligible (VP < 0.001 torr).

Dermal: Dermal not required, per SAT; health testing not desired.INITIAL REVIEW ENGINEERING REPORT PMN: 14

- 0448 Use: Defoamer for Pulp Washing
unknown site(s) Number of Sites/ Location: 40

Days/yr: 350 Basis: Submitter indicates 40 sites, 30 exposure day/yr and 2% PMN in raw material. The 2004 draft i ives i aking GS and similar use past cases , and ) estimate 350 day/yr operation. es, 35 , and 2% PMN In raw material; ChemSTEER calculates a PMN use rate of 8.57 kg/site

- day.
Process Description: PMN (liquid, 2%)

-- > Storage tank

-- > White

- water system in Paper Mills

-- > Recirculated or disposed of (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.Water High End: 7.6E

- 1 kg/site

- day over 8 days/yr from 40 sites or 6.1E+0 kg/site

- yr from 40 sites or 2.4E+2 kg/yr

- all sites to: On

- site WWTP (per submission) 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. Submitter estimates 4 kg/day released to on

- site waste water treatment from cleaning of tank car. CEB assesses release using the standard model for tank truck residuals as the typical batch size associated with such a release is unknown.

Water Output 2: 8.6E+0 kg/site

- day over 350 days/yr from 40 sites or 3.0E+3 kg/site

- yr from 40 sites or 1.2E+5 kg/yr

- all sites to: On

- site WWTP (per submission; GS) from: White

- water disposal basis: User

- Defined Loss Rate Model. Submitter indicates storage tank cleaning and effluent are released for on

- site waste water treatement. Per GS, chemicals that are not incorporated into the final paper product will enter a wastewater stream; a 100% release scenario is assessed for defoamers. LF = 1

- 0.002 = 0.998

RELEASE TOTAL 1.2E+5 kg/yr

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 0 Basis:Inhalation: Inhalation not required per SAT; health testing not desired; negligible (VP < 0.001 torr).

Dermal: Dermal not required, per SAT; health testing not desired.