P140501.en3

INITIAL REVIEW ENGINEERING REPORT 

PMN: 14-0501 

Post-Focus Draft Revision 2 6/9/2015

ENGINEER: Austin \ REC 

PV (kg/yr): 120,000 YX

Revision Notes / Assessment Overview: Information used as provided in 

amendment of Januray 30, 2015. Primarily relating to the subsequent 

production of 51 --> 502.

SUBMITTER: Ethox Chemicals, LLC 

USE: Gellant for use in oil fracturing Consolidated set: No 

references found. Analogs have similar uses.

OTHER USES: A Pigment dispersant. Analogs : 

Surfactant for paints and coatings.

MSDS: No Label: No

TLV/PEL:

 

 

 

 

 

 

Consumer Use: No 

SAT (concerns) (04/29/2014):

Related Cases and Misc SAT Info: 

Analogs:

Migration to groundwater: Moderate 

PBT rating: P1B1T2 

Health: 2 Dermal, Drinking Water, Inhalation, XB Testing (No Testing desired) 

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

desired) 

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OCCUPATIONAL EXPOSURE RATING: 1B

NOTES & KEY ASSUMPTIONS: 

Generated by the 09/30/2013 version of ChemSTEER. 

POLLUTION PREVENTION CONSIDERATIONS:

No P2 information has been provided.

EXPOSURE-BASED REVIEW: Yes (0 criteria met) 

1) # of workers exposed: 11 >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

 

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INITIAL REVIEW ENGINEERING REPORT 

PMN: 14-0501 

Manufacturing: Batch

Number of Sites/ Location: 1 

Ethox Chemicals LLC Greenville SC 29605

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Days/yr: 25

Basis: Submitter specifies 1 site, 30,000 kg PMN/st-bt, 72 hr/bt, 25 bt/yr, 

and 100% PMN in product. Due to a mass balance discrepancy, CEB assumes 1 

site, 25 bt/yr, and 100% PMN in product. ChemSTEER calculates a use rate of 4,

800 kg PMN/st-bt.

Process Description: Raw materials --> Reactors (PMN Formed) --> Blending 

Vessel --> send PMN 501 to pMN 502 reactor, destoryed.

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.

Incineration

Central Tendency: 3.4E+0 kg/site-day over 5 days/yr from 1 site

or 1.7E+1 kg/site-yr from 1 site or 1.7E+1 kg/yr-all sites

to: Incineration

from: Equipment Cleaning Losses of Liquids from a Single, Large Vessel

basis: EPA/OPPT Single Vessel Residual Model, CEB standard 1% residual. 

Amendment states equipment cleaned every 5 days. Assumed gravity drained, 

pumped vessel for manufacturing (reactor) (.007 LF) 6/09/15 amendment 

states that facility will collect the 5 days of reactor releasse and send off 

site for incineration.

RELEASE TOTAL

1.7E+1 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 3

Basis: 

Inhalation:

negligible (VP < 0.001 torr)

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Dermal:

Exposure to Liquid at 100.00% concentration

High End:

> Potential Dose Rate: 2.2E+3 mg/day over 25 days/yr

> Lifetime Average Daily Dose: 1.3E+0 mg/day over 25 days/yr

> Average Daily Dose: 2.2E+0 mg/day over 25 days/yr

> Acute Potential Dose: 3.2E+1 mg/day over 25 days/yr

Number of workers (all sites) with dermal exposure: 3

Basis: Loading Liquid Product into Drums; EPA/OPPT 2-Hand Dermal Contact with 

Liquids Model.

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INITIAL REVIEW ENGINEERING REPORT 

PMN: 14-0501 

Use 1: Site-Limited Chemical Intermediate (19% PV)

Number of Sites/ Location: 1 

Ethox Chemicals LLC Greenville SC 29605

Days/yr: 6

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Basis: Submitter specifies 1 site (same as manufacturing site), 2 batches, 15,

485 kg PMN/st-bt and 100% PMN in raw material. Due to a mass balance 

discrepancy, CEB assumes 1 site, 2 batches, and 100% PMN in raw material. 

ChemSTEER calculates a use rate of 11,400 kg PMN/st-bt.

Process Description: PMN (liquid, 100%) sent to reactor for PMN 502r --> 

Addition of KOH --> PMN consumed (per submission, technical contact)

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.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 0

Basis: 

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

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INITIAL REVIEW ENGINEERING REPORT 

PMN: 14-0501 

Use 2: Oil Fracturing (81% PV)

Number of Sites/ Location: 1 

unknown site(s) 

Days/yr: 350

Basis: Submitter does not provide information on the end use. The 2011 ESD on 

Chemicals Used in Oil Well Production estimates 350 operating days/yr and 1,

460 kg oil/st-bt. CEB assumes 100% PMN in raw material. ChemSTEER calculates 

0.19 sites. To correct mass balance discrepancy, CEB assumes 1 site, 350 

day/yr, and 100% PMN in raw material. ChemSTEER calculates a new batch size 

of 278 kg PMN/st-bt.

Process Description: PMN unloaded (liquid, 100%) --> Storage tank --> Oil 

well --> Crude oil/water separator --> PMN in oil layer transported to a 

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refinery and destroyed, PMN in water phase re-used, deepwell injected, or 

land dispersed (per ESD)

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.

Deepwell Injection

High End: 8.3E+0 kg/site-day over 350 days/yr from 1 site

or 2.9E+3 kg/site-yr from 1 site or 2.9E+3 kg/yr-all sites

to: Water, Incineration, or Landfill (per ESD)

from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material

basis: Per submitter amendment on Jan 30, after use of the products the end 

user will rinse drums whcih contained these products and use this wash liquid 

in the fracking site; i.e., the material will go into the fracking well.

RELEASE TOTAL

2.9E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 8

Basis: 

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 100.00% concentration

High End:

> Potential Dose Rate: 2.2E+3 mg/day over 250 days/yr

> Lifetime Average Daily Dose: 1.3E+1 mg/day over 250 days/yr

> Average Daily Dose: 2.2E+1 mg/day over 250 days/yr

> Acute Potential Dose: 3.2E+1 mg/day over 250 days/yr

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

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal 

Contact with Liquids Model.

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MEMORANDUM of CBI TELEPHONE CONVERSATION

CALL BY: 

Organization: 

CALL TO: John McKiernan

Organization: Ethox Chemicals, LLC

Date: 04/30/2014

Time: 12:45 PM

Phone: 

Concerning what TSCA CBI?

PMN: 14-0501 

The following questions are for P14-0501 to 0503:| Q1: Ethox 4576 (P14-0502) 

scheme: Is P14-0501 reacted to P14-0502? Or will P14-0501 remain as part of a 

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mixture? If P14-0501 is not reacted, at what concentration will the PMN be 

present? | A1: Becomes a salt when you at potassium hydroxide. Reacted for 

on-site use. Will be used as is in oil field fracturing for the remaining PV 

that is sold to other companies. 19% used on-site and 81% will be sold and 

used as is in the oil field.| | Q2: Ethox 4576 (P14-0502) and 

 schemes: Within these process diagrams, it appears as though 

 is blended with to from . However, P14-0501 is 

listed as both Ethox 4158 and Ethox 4180. At what concentration is the PMN 

within Ethox 4180 (i.e. 100% as this is the PMN, or <100% because the PMN is 

a blend of Ethox 4158 and Ethox 2989)?| A2: Both qualified as PMN, assume PMN 

is 100% Ethox 4158. Unsure of the concentration of the PMN in Ethox 4180. He 

will look into estimating this.| | Q3: Are only P14-0502 and used as 

gellants in oil well fracturing? Or is P14-0501 used to create both of these 

chemicals as well as on it's own in oil well fracturing?| A3: All three will 

be used as in oil well fracturing. P14-0501 will be sold to other companies 

that use the chemical within oil well fracturing (see answer to Q1).| | Q4: 

Can you provide PMN concentrations for all three chemicals after 

manufacturing?| A4: All three liquids, P14-502 and are used at 100%. 

Looking into the concentration for P14-0501.| | Q5: Do you have an estimate 

of the number of sites at which the PMNs will be used? And at what 

concentration will they be used? Are there intermediate processing sites that 

formulate the gellant prior to use in oil well fracturing?| A5: No idea of 

the number of sites that the PMN will be used. Sent directly to well head 

site; no intermediate processing sites. Do not know the concentration at 

which they will be blended at the well head site.| | Spoke with John 

McKiernan on 5/7/2014 at 9:40 AM.

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