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) Page 1P140501.en3

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 Page 3P140501.en3

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

Page 6P140501.en3 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 Page 9P140501.en3 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 Page 11P140501.en3 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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