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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 indicate 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 diff cases are referenced 

for consistency: . // For PROC: The 

current IRER asse pment cleaning 

releases to on-site WWTP, per submitter. All past cases only assess 

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 as 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 mineral 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: No

 
INITIAL 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 (liquid, 

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 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.
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.