1

I. IMPORTATION, STORAGE, AND TRANSFER TO SHIPPING VESSELS IN US

The PMN Substances A and B will be directly imported into the United States as 30% active matter (70% water). 

The most preferred and economical method for transporting the PMN Substances from Europe, where the PMN 

Substances are manufactured, to the US will be by ship (up to 2,000,000 kg/product/ship). However, though 

uneconomical and not preferred, the PMN Substances A and B can also be imported in ISO containers (20,000 

kg/container). All products will be imported to Houston, TX where they will be stored for further distribution to 

customers.

When the ship carrying the PMN Substances (either in ISO containers or in bulk) arrives in Houston, it will proceed 

to the Vopak Galena Park Terminal to be off-loaded. Vopak (1500 Clinton Dr, Galena Park, TX, 77547) is a global 

leader in chemical storage. They own facilities at major ports around the world including two in Houston (Galena 

Park and Deer Park). For photographs of the Galena Park site and detailed information on Vopak’s holdings, 

operations, and safety/environmental policy see http://www.vopakamericas.com/ 

PMN Substances shipped in bulk will be transferred from the ship by pipeline and hoses to holding tanks as shown 

in Figure 1. Each PMN Substance will require its own dedicated holding tank. The tanks will be appropriately sized 

such that they accommodate at least 1.25 x the maximum quantity imported at any one time ( ~ 2,2500,000 kg). 

Vopak tanks are designed with the required bermming and spill-catch containment.

PMN Substances A and B can also be imported in ISO containers (20,000 kg/container). Sasol obtains ISO 

containers from Stolt-Nielsen http://www.stolt-nielsen.com/Stolt-Tank-Containers.aspx. When imported in ISO 

containers, the PMN Substances will be handled in a similar manner to that for bulk shipment. The ISO container 

will be transported by boat from Europe. ISO containers will be sent in up to 4 shipments of 25 to 50 containers at 

one time. The ISO containers will be offloaded at the Vopak dock and transported by truck to the PMN Substance 

holding tank. The first human contact with the PMN Substance contained within the ISO containers will occur when 

the Vopak worker attaches the hose to the ISO container for unloading into the tank. Since all of the PMN 

Substance delivered at one time will be from a single production batch, only the first ISO container of a shipment will 

be tested for Quality Control. All other ISO containers will be assumed to have the same product quality. 

To assess the quality of the PMN Substances, eight samples will be taken during the unloading of the ship to the 

tank; three samples will be taken during the unloading of the ISO containers to the tank. 

Intertek has been contracted to supply the manpower to conduct all inspections and sample testing associated with 

the PMN Substances. As stated in their website; “Intertek offers clients professional inspection and testing services 

for bulk cargo chemical commodity shipments on a global basis”. Thus, all contact with the PMN Substances will be 

by professionals trained in handling hazardous and non-hazardous chemicals. For more detailed information on the 

services, and qualifications of Intertek see http://www.intertek-cb.com/chemicals/inspections.shtml.

All hose attachment/detachment will be conducted by Vopak workers trained to handle hazardous and nonhazardous chemicals. Similarly, QC samples sent to the Sasol Quality Control Lab will be handled by technicians 

trained in the handling of chemicals. All people handling the PMN Substances will wear the following PPE: safety 

glasses, chemical resistant gloves, protective clothing, and safety shoes.

Finally, the PMN Substances will be loaded from the Vopak holding tanks into railcars and trucks for shipment to the 

customer sites. Two QC samples will be taken during the loading of PMN Substance from the holding tank to each 

railcar or truck. Rail shipment will be the most economical and preferred method. 

The specific details of all unloading/loading and QC processes are given in the diagram and tables below. 
2

Figure 1. Importation, Storage, & Loading - One Site Only

Dock

Hose

Pipeline

Hose

Sample to lab 

for testing and 

disposal

C

D,E,F,

G,L,M

P

Sample to lab 

for testing and 

disposal

Hose

Hose

Sasol QC 

Laboratory

Release 

2

I,O

Intertek QC 

Laboratory

H,N,S Release 

1

Q,R

Cleaning

4

Cleaning

5

Vopak Holding 

Tank

Cleaning

3

J,K

Cleaning

2

A,B

Cleaning

1

Each of the activities is explained below along with the number of people exposed to PMN Substances A or B during 

the activity and the duration of the exposure.

Activity Description People Exposed Time Exposed

Unloading of a Ship

A 

Inspection of PMN Substances on ship3x 1kg spls collected and taken to QC lab for 

testing

1 Intertek Inspector 15 minutes

B

Hooking hose from ship to pipeline to offload material 1 Vopak Worker 5 minutes

C

After PMN Substance transferred through 

hose/pipeline to dock a 0.5 kg spl collected 

for visual inspection

1 Intertek Inspector

1 Vopak Worker 5 minutes

D

After PMN Substance transferred from dock 

through hose/pipeline to tank a 0.5 kg spl 

collected for visual inspection 

1 Intertek Inspector

1 Vopak Worker 5 minutes

E Hose attached to tank 1 Vopak Worker 5 minutes

F After PMN Substance filled in tank to 1ft a 1 Intertek Inspector 10 minutes
3

0.5 kg spl collected and taken to QC lab

G

Tank filled. Tank weight/volume recorded. 

0.5 kg spl collected and taken to QC lab, 

0.5kg spl collected and shipped to Sasol 

Westlake QC lab

1 Intertek Inspector 10 minutes

H

Analysis of QC samples5 spls of PMN Substance tested1 Intertek QC 

Technician 60 minutes cumulative

I

Analysis of Sasol QC sample1 spl of PMN Substance tested 1 Sasol QC Technician 15 minutes cumulative

Unloading of ISO Containers

J

ISO container of PMN Substance arrives at 

holding tank. Hose connected to ISO 

container.

1 Intertek Inspector 5 minutes

K

0.5kg spl collected from the hose for visual 

inspection and sent to QC lab for testing. 

(only the first ISO container per shipment of 

containers is tested)

1 Intertek Inspector

1 Vopak Worker 5 minutes

L

Hose from ISO container connected to 

holding tank. 1 Vopak Worker 5 minutes

M

All ISO containers within shipment emptied. 

Tank filled. Tank weight/volume recorded. 

0.5kg spl collected and taken to QC lab, 

0.5kg spl collected and shipped to Sasol 

Westlake QC lab

1 Intertek Inspector 10 minutes

N

Analysis of QC samples2 spls of PMN Substance tested1 Intertek QC 

Technician 30 minutes cumulative

O

Analysis of Sasol QC sample1 spl of PMN Substance tested 1 Sasol QC Technician 15 minutes cumulative

Loading of Railcars/Trucks

P

Hose is connected to holding tank. 0.5kg spl 

collected for visual inspection.

1 Intertek Inspector

1 Vopak Worker 10 minutes

Q Hose connected to truck or railcar. 1 Vopak Worker 5 minutes

R

Truck/Rail filled with PMN Substance. 

0.5kg spl collected for QC lab 1 Intertek Inspector 5 minutes

S

Analysis of QC samples1 spl of PMN Substance tested1 Intertek QC 

Technician 15 minutes cumulative

Total annual worker exposure of the PMN Substances in the US will depend on the number of shipments received in 

Houston and shipped to customers per year. Due to the excessive cost of shipping material in ISO containers, the 

preferred method of importation will be bulk shipment. However, as a worse-case-scenario, calculations will assume

10% of the total annual volume of PMN Substances A and B are shipped in ISO containers and 90% of the total 

volume is shipped by boat resulting in the number of shipments given below. ISO containers will be received 25 to 

50 containers in one shipment. 

Table 1. Annual Shipments - Europe to US

PMN 

Substance

Max 12 Month 

Vol.

(100% Active)

Max 12 Month 

Vol.

as Received

(30% Active)

Max 12 Month 

Vol. Shipped per 

Method 

Shipment Size

Max 

Boat/ ISO 

Containers 

Shipments per 

Year

Boat Shipments - 100% Total Volume

(Preferred Method)

A 5,400,000 kg 18,000,000 kg 18,000,000 kg 2,000,000 kg 9

B 5,400,000 kg 18,000,000 kg 18,000,000 kg 2,000,000 kg 9

Boat Shipments - 90% Total Volume

(Worst Case Scenario)

A 5,400,000 kg 18,000,000 kg 16,200,000 kg 2,000,000 kg 8

B 5,400,000 kg 18,000,000 kg 16,200,000 kg 2,000,000 kg 8
4

ISO Container Shipments - 10% Total Volume

(Worst Case Scenario)

A 5,400,000 kg 18,000,000 kg 1,800,000 kg 20,000 kg 90

B 5,400,000 kg 18,000,000 kg 1,800,000 kg 20,000 kg 90

Due to the excessive cost of shipping material in trucks compared to rail, the preferred shipment method to the 

customer will be by rail. However, as a worse-case-scenario, calculations will assume 5% of the total annual volume 

of PMN Substances A and B is shipped in trucks and 95% of the annual volume is shipped in railcars resulting in the 

number of shipments given below.

Table 2. Annual Shipments - Vopak Tank to Customer Tank

PMN 

Substance

Max 12 Month 

Vol.

(100% Active)

Max 12 Month 

Vol.

as Received

(30% Active)

Max 12 Month 

Vol. Shipped per 

Method 

Shipment Size

Max Shipments 

per Year from 

Vopak Tank

Rail Shipments - 100% Total Volume (Preferred Method)

A 5,400,000 kg 18,000,000 kg 18,000,000 kg 68,182 kg 264

B 5,400,000 kg 18,000,000 kg 18,000,000 kg 68,182 kg 264

Rail Shipment - 95% Total Volume (Worst Case Scenario)

A 5,400,000 kg 18,000,000 kg 17,100,000 kg 68,182 kg 251

B 5,400,000 kg 18,000,000 kg 17,100,000 kg 68,182 kg 251

Truck Shipment - 5%Total Volume (Worst Case Scenario)

A 5,400,000 kg 18,000,000 kg 900,000 kg 20,000 kg 45

B 5,400,000 kg 18,000,000 kg 900,000 kg 20,000 kg 45

Release 1 - During the above activities, 30% active PMN Substance samples are collected from the bulk product for 

visual inspection or QC testing by Intertek or Sasol. Josh Burkhalter, Laboratory Supervisor, Intertek Testing Lab,

Deerpark, TX provided the following process for handling QC samples. After testing is complete, the remaining PMN 

Substance is held in retain for up to 180 days, after which the samples are poured into an accumulation drum. Once 

the drum is full it is taken by a 3rd party certified chemical waste handler who has it incinerated. Release 1 occurs 

at Intertek Testing Lab - maximum of 102 kg per year, of 100% active PMN Substance A and B to a 

controlled release technology. 

Table 3. Release 1 - Annual Disposal of Intertek QC Samples

Sample 

Volume per 

Shipment 

(30% Active)

Max Shipments 

(Preferred 

Methods)

Max Shipments 

(Worst Case 

Scenario)

Release Volume 

100% Active 

(Preferred 

Methods)

Release 

Volume 100%

Active (Worst 

Case Scenario)

Ships 5 kg 9 8 13.5 kg 12. kg

ISO Containers 1 kg 0 4* 0 kg 1.2 kg

Railcars 1 kg 264 251 79.2 kg 75.3 kg

Trucks 1 kg 0 45 0 kg 13.5 kg

Total: 92.7 kg Total: 102 kg

*90 ISO containers ÷ 25 containers per shipment

Release 2 - Every time product is offloaded into the tank at Vopak, one sample is also taken and sent to Sasol North 

America’s QC laboratory in Westlake, LA. After testing is complete, the remaining PMN Substance is held in retain 

for 365 days, after which the samples are poured into an accumulation drum. Once the drum is full it is taken by a 

3

rd party certified chemical waste handler who has it incinerated. Release 2 occurs at Sasol North America -

maximum of 1.8 kg each, per year, of 100% active PMN Substance A and B to a controlled release 

technology.
5

Table 4. Release 2 - Annual Disposal of Sasol QC Samples

Sample 

Volume per 

Shipment 

(30% Active)

Max Shipments 

(Preferred 

Methods)

Max Shipments 

(Worst Case

Scenario)

Release Volume 

100% Active 

(Preferred 

Methods)

Release Volume 

100% Active 

(Worst Case 

Scenario)

Ships 0.5 kg 9 8 1.4 kg 1.2 kg

ISO Containers 0.5 kg 0 4* 0 kg 0.6 kg

Total: 1.4 kg Total: 1.8 kg

*90 ISO containers ÷ 25 containers per shipment

IMPORTATION, STORAGE, AND TRANSFER TO SHIPPING VESSELS IN US will not 

result in a direct, uncontrolled release to the environment.

II. CLEANING 1 & 2 - CLEANING OF SHIP-BOARD TANKS AND ISO 

CONTAINERS THAT CONTAINED PMN SUBSTANCES 

After PMN Substances A and B are transferred from the ship-board tank or the ISO containers to the Vopak holding 

tank, the ship-tank and ISO containers have to be cleaned. Figure 2 shows the flow diagram for the cleaning 

process.

Cleaning 1 - Stolt-Nielsen is Sasol’s preferred ship carrier. Sasol currently uses Stolt ships to transport solvent and 

alcohols in bulk from our manufacturing sites in Europe to the US. Stolt will also be contracted to carry the PMN 

Substances A and B.

According to Paul Dunn of Stolt-Nielsen, www.stolt-nielsen.com/Stolt-Tankers-Terminals.aspx, the process for shiptank cleaning is automated. Each tank is equipped with a “spinner” through which sea water, hot water, or steam is 

sprayed to the inside of the tank. The rinse water is then pumped into a “slop” tank on the ship where it is 

accumulated. There is no human contact with the PMN Substances during the ship tank cleaning process. The only 

human activities are activating and deactivating the automated system, which actually takes place in a control room 

above deck, and inspection of the cleaned tank. According to Mr. Dunn there will be at most 190 kg of residual PMN 

Substance (30% active) in the ship-tank before cleaning. At minimum, tanks are triple rinsed with 189 kg of water 

per rinse and then steam dried. There are documented procedures for the cleaning process that specify detergent, 

solvent or other cleaning aid requirements based on the chemical being removed from the tank. However, the PMN 

Substances are detergents themselves, so no additional cleaning aid will be required. Ultimately, at most 57 kg of 

100% active PMN Substance A or B will end up in the slop tank for each shipment.

The contents of the slop tank of Stolt ships are either transported by truck to the Stolt-Nielsen facility in Houston 

where this ship rinse water is combined with rinse water from ISO container cleaning, or the ship slop tank contents 

are transported directly to the Bealine Environmental Services facility in Pasadena, TX www.bealine-env.com, for 

preliminary water treatment. 

Cleaning 2 - Stolt-Nielsen is Sasol’s preferred provider of ISO containers. According to Duncan Callaway, Technical 

Director of Stolt-Nielsen, www.stolt-nielsen.com/Stolt-Tankers-Terminals.aspx, all Stolt-owned ISO containers are 

returned to the Stolt facility in Houston for cleaning once they are emptied. ISO container cleaning is similar to shiptank cleaning in that a “spinner” is attached to the top hatch of the ISO container. Water, solvent and/or steam is 

pumped through the spinner and spays the walls of the ISO container. All rinse water is collected and pumped into a 

holding tank where it is accumulated. 

 

According to Mr. Callaway, the ISO container will be completely “empty”. There will be at most 19 kg of residual 

PMN Substance (~30% active) on the walls of the ISO container before cleaning. At minimum, tanks are triple 

rinsed with 76 kg of water per rinse and then steam dried. There are documented procedures for the cleaning 

process that specify detergent, solvent or other cleaning aid requirements based on the chemical being removed 

from the container. However, the PMN Substances are detergents themselves, so no additional cleaning aid will be 

required. Ultimately, at most 6 kg of 100% active PMN Substance A or B will end up in the rinse-water 

holding tank per ISO container. 
6

The Houston Stolt facility does not have on-site water treatment. All rinse water from the Houston Stolt facility is 

sent by truck to the Bealine Environmental Services facility in Pasadena, TX, www.bealine-env.com, (EPA ID: 

TXD980809859, State ID: 40421) for preliminary water treatment. 

Bealine Environmental Services uses chemical, filtration and gravimetric methods to separate sludges, greases, and 

oils from the rinse water. The solids, once separated from the water, are collected and disposed of through a 3rd

party certified chemical waste handler who has it incinerated, land-filled, or deep well injected depending on the 

material composition. It is expected that the PMN Substances will remain in the water fraction. According to Blake 

Erwin of Bealine, “Bealine operates a Centralized Waste Treatment facility (CWT) as defined by the US EPA. A 

CWT treats wastewater prior to discharge to a Public Operated Treatment Works (POTW). The POTW Bealine 

discharges to is operated by The Gulf Coast Waste Disposal Authority (GCA), www.gcwda.com/index.html, which is 

a Texas authority funded for industrial waste treatment.” Mr. Erwin continues that Bealine/Gulf Coast Waste 

Disposal Authority operates a state-of-the art process unlike anything else in the world. Bealine is connected and 

moves the rinse water to Gulf Coast by pipeline.

As described on their website, GCA uses “unique configurations of the Activated Sludge process to optimize the 

treatment of the specific waste streams received at that facility. GCA owns and operates four regional industrial 

wastewater treatment facilities that process liquid wastes from more than 80 industrial plants (largely petrochemical 

in nature). These GCA facilities are the Washburn Tunnel Facility located on the Houston Ship Channel, the Bayport 

Industrial Wastewater Treatment Facility located in the Bayport Industrial District in Pasadena, Texas, the 40–Acre 

Facility in Texas City and the Odessa Regional Wastewater Treatment Facility in Odessa, Texas.” 

Bealine transfers their rinse water to the GCA Pasadena facility exclusively. The GCA Pasadena facility discharges 

the treated wastewater into Galveston Bay under permit TPDS 01054.
7

Figure 2. Cleaning 1 & 2

Hose

Ship Slop Tank

Hose 57 kg of 100% active 

PMN substance

T

Stolt Rinse Water 

Holding Tank

Storage Tank With 

Spinner

All rinse water from the ISO 

container is transferred to the 

rinse water holding tank.

U

Hose

6 kg of 100% active 

PMN substance

W

All rinse water is 

sent to Bealine for 

water treatment

Bealine 

Wastewater 

Treatment

EPA ID: 

TXD980809859 

State ID: 40421

Hose Hose

Gulf Coast Waste 

Disposal Authority

TPDS # 01054

Pipeline

Cleaning

1

Cleaning

2

Stolt Accumulation 

Tank

Hose

or

POTW

Release 

3

Any overflow rinse water is 

caught in the containment 

berm where it is drained and 

dumped to the rinse water 

holding tank.

Containment Berm

X,Y

V

19 kg of 30% active PMN substance

6 kg of 100% active per shipment

190 kg of 30% active PMN substance

57 kg of 100% active per shipment

Each of the activities in the figure above are explained in the table below, along with the number of people exposed 

to PMN Substances A or B during the activity and the duration of the exposure.
8

Activity Description People Exposed Time Exposed

T

Hooking hose to truck to empty slop tank 

for transfer to water treatment facility or 

Stolt-Nielsen facility in Houston

1 Vopak Worker 5 minutes

U

Hook up spinner to ISO container and 

remove when cleaning complete. 

Inspect and certify clean container 

1 Stolt Worker 20 minutes

V

Hook up truck carrying ship slop tank 

water to accumulation tank 1 Stolt Worker 5 minutes

W

Hook up hose to truck to transfer rinse 

water to Bealine for waste water 

treatment

1 Stolt Worker 5 minutes 

cumulative

X

Hook up truck carrying ship slop tank 

water to waste water treatment tank

1 Waste-Water Facility 

Worker 5 minutes

Y

Hook up truck carrying ISO rinse water to 

waste water treatment tank

1 Waste-Water Facility 

Worker 5 minutes

Release 3 - Total annual worker exposure and total PMN Substance going to waste water treatment will depend on 

the number of shipments received per year. For each ship-tank, 57 kg of 100% active PMN Substance will be 

transferred to the water treatment facility. For each ISO container, 6 kg of 100% active PMN Substance will be 

transferred to the water treatment facility. Based on projected total volume for PMN Substances A and B, the 

number of shipments expected is given below. Bulk shipments by boat are preferred. However, as a worse-casescenario, calculations will assume 10% of the total annual volume of PMN Substances A and B is shipped in by ISO 

container and 90% of the annual volume is shipped in bulk by boat resulting in the number of shipments given 

below. Release 3 occurs at the Gulf Coast Waste Disposal Authority - maximum of 996 kg per year, of PMN 

Substance A and B to a controlled release technology.

Table 5. Release 3 - Annual Disposal of Cleaned Ship-Tank & ISO Container Waste

PMN 

Substance

Max 12 Month 

Vol. Shipped 

per Method 

(30% Active)

Shipment 

Size

Max Boat/ ISO 

Container 

Shipments 

per Year

Residual Volume 

of 100% Active 

PMN Substance in 

Emptied 

Container

Total Vol 100%

Active Going 

to Water 

Treatment per 

Method

Boat Shipments - 100% Total Volume (Preferred Method)

A 18,000,000 kg 2,000,000 kg 9 57 kg 513 kg

B 18,000,000 kg 2,000,000 kg 9 57 kg 513 kg

Boat Shipments - 90% Total Volume (Worst Case Scenario)

A 16,200,000 kg 2,000,000 kg 8 57 kg 456 kg

B 16,200,000 kg 2,000,000 kg 8 57 kg 456 kg

ISO Container Shipments - 10% Total Volume (Worst Case Scenario)

A 1,800,000 kg 20,000 kg 90 6 kg 540 kg

B 1,800,000 kg 20,000 kg 90 6 kg 540 kg

CLEANING 1 & 2 - CLEANING OF SHIP-BOARD TANKS AND ISO CONTAINERS 

THAT CONTAINED PMN SUBSTANCES will not result in a direct, uncontrolled release to 

the environment. 

996 kg
9

III. CLEANING 3 - CLEANING OF VOPAK TANKS

Cleaning 3 - PMN Substances A and B will be imported into the Vopak facility at Galena Park, TX and placed in 

10,000-barrell storage tanks. Tanks are emptied and cleaned for inspection once every 3 to 5 years. For the 

purpose of a worse-case scenario however, a 1-time washing per tank will be used in this example. According to 

members of Sasol’s operations team, an “emptied” product storage tank will have less than 50 gallons of residual

product. In this case, 50 gallons of the PMN Substances is 190 kg of 30% active material or 57kg of 100% active 

product. 

Tony Kinner, Vopak Customer Service Supervisor, described the process Vopak uses for tank cleaning as follows: 

Vopak hires a contract company specializing in tank-cleaning. The company sends a portable cleaning unit to the 

tank site. The driver of the unit would hook up the cleaning system (similar to the spinner system used on ISO

containers) to the “man way” or other port-hole to the tank. The cleaning system would spray water, solvent, 

detergent, and/or steam, as required in the cleaning procedure for the original product. All rinse water would be 

collected by vacuum into the portable cleaning truck such that the tank was left cleaned and dried, and the rinsewater would be contained. The rinse water is then transported by truck to Vopak’s wastewater treatment plant at 

their Deer Park site (TPDS WQ0001731000). The Vopak Deer Park site biologically treats the rinse water through an 

ASU-type system and ultimately discharges the cleaned water to the Houston Ship Channel. Further information on 

Vopak’s water treatment facility can be obtained from Ms. Tiffany Hill, Vopak Environmental Department, (281)-604-

6083.

A block diagram of the tank cleaning process is given below:

Figure 3. Cleaning 3 - Cleaning of Vopak Holding Tanks

The tank-cleaning activity is explained below along with the number of people exposed to PMN Substances A or B 

during the activity and the duration of the exposure

Activity Description People Exposed Time Exposed

Z

Hooking up and disassembling portable 

tank wash system 1 Tank Wash Worker 20 minutes

AA

Attaching hose from truck to water 

treatment plant. Detaching hose from 

truck to water treatment plant.

1 Tank Wash Worker 10 minutes

Release 4 - Total annual worker exposure and total PMN Substance going to waste water treatment will depend on 

the number of tanks used to hold the PMN Substances. Sasol is planning for only one tank for each PMN Substance 

at the Vopak Galena Park location. However, as a worse-case scenario, two tanks per PMN substance will be used 

in the example below. Each tank would at most be cleaned one time per year and most preferably 1 time every 5 

years. For each tank, 57 kg of 100% active PMN Substance will be transferred to the water treatment facility in the 

tank rinse water. Based on the number of storage tanks for PMN Substances A and B, the amount released is given 

in the table below. Release 4 will take place at Vopak Deer Park Site - maximum of 114 kg per year of PMN 

Substance A and B to a controlled release technology.
10

Table 6. Release 4 - Annual Disposal of Residuals from Cleaned Vopak Tank Waste

PMN 

Substance

Residual PMN Substance 

100% Active in Vopak Tank

Release Volume 

(Preferred Method -

1 Storage Tank)

Release Volume 

(Worst Case Scenario -

2 Storage Tanks)

A 57 kg 57 kg 114 kg

B 57 kg 57 kg 114 kg

CLEANING 3 - CLEANING OF VOPAK TANKS will not result in a direct, uncontrolled 

release to the environment.

IV. SHIPMENT OF MATERIAL TO CUSTOMER STORAGE

Once PMN Substances A and B are loaded from the Vopak holding tank into railcars and trucks, they will be shipped 

to the customer storage sites and unloaded into customer-owned storage tanks. The maximum volumes given in 

this document, see Table 7, for the first three years of sales will accommodate three simultaneous 

customers with medium-sized oilfields each for PMN Substances A and B. For PMN Substance A, two of the 

three customers will be outside of the US. For PMN Substance B, one of the three customers will be outside 

of the US. For the customers outside of the US, the PMN Substances will be exported either by railcar or 

truck, from the Vopak storage tank to the customer holding tank in a foreign country. Customer-owned 

storage tanks will be located at a rail site which is close to, but not necessarily on, the oil field. Hence, this interim 

storage location is needed so that railcars can be unloaded and sent back to the Vopak tank quickly. Shipping by 

rail instead of truck is preferred due to the significant cost difference. Railcars will be used almost exclusively to ship 

product from Vopak to the customer. The railcars will be owned by Sasol and dedicated to transport only the PMN 

Substances to and from their identified customers. 

Customers will be responsible for transporting PMN substances A and B from their storage tanks at the rail site to 

the oil field. Our customers indicate that a dedicated truck/driver be used for this final transportation step. Our 

customers have conveyed multiple reasons to justify a dedicated truck/driver. First of all, they will be assured that 

they have the truck and driver available “on demand”. This is important as the average oilfield project will employ 

133,000 kg of PMN Substances A or B per week which is 7 truck load trips from the rail-site storage tank to the oil 

field. Secondly, the customers do not want to be concerned about cross contamination. Having a truck dedicated to 

haul only the PMN substances will eliminate any opportunity for cross contamination with other chemicals. Finally, 

having a dedication truck will eliminate the need to wash the truck in between loads thus reducing their overall 

transportation cost. 

It is expected that the customer will collect a sample for QC with each batch of PMN substance received from Sasol. 

A customer technician trained in the handing of hazardous and non-hazardous chemicals will be responsible for 

handling and testing QC samples.

A block diagram of the process to ship the PMN substances to the customer is given below.
11

Figure 4. Shipment of Material to Customer Storage

Each of the three activities is explained below along with the number of people exposed to PMN Substances A or B 

during the activity and the duration of the exposure.

Activity Description People Exposed Time Exposed

AB

Truck/Rail arrives at customer storage 

facility. Hose hooked in truck/rail . 0.5kg 

spl collected for QC lab. PMN 

Substances transferred to tank. Hose 

disconnected.

1 Customer Inspector

1 Customer Worker

15 minutes 

cumulative

AC Analysis of QC sample1 spl of PMN Substance tested 1 Customer QC Technician 15 minutes 

cumulative

AD

Hose connected to truck taking PMN 

Substance to oilfield. Truck filled. Hose 

disconnected. 

1 Customer Worker 15 minutes 

cumulative

Total annual worker exposure for Activities AB and AC will depend on the number of trucks and railcars received 

from the Vopak holding tank per year at each site. Due to the excessive cost of shipping material in trucks 

compared to rail, the preferred shipment method will be by rail. However, as a worse-case-scenario, calculations will 

assume 5% of the total annual volume of PMN Substances A and B is shipped in trucks and 95% of the annual 

volume is shipped in railcars. As stated above, PMN Substances A will be shipped to only one customer or site in 

the US and PMN Substance B will be shipped to two customers or sites in the US. 

Table 7. Annual Domestic Shipments - Vopak Tank to Customer Tank

PMN 

Substance

Max 12 

Month Vol. 

(100%

Active)

Use in USA

Max 12 

Month Vol. 

as Received 

(30% Active)

Use in USA

Max 12 

Month Vol. 

Shipped per 

Method (30%

Active)

Shipment 

Size

Max 

Shipments 

per Year 

Vopak to 

Customer

US 

Customers 

Sites per 

PMN 

Substance

Shipments 

per 

Customer 

per Year

Rail Shipments - 100% Total Volume (Preferred Method)

A 1,800,000 kg 6,000,000 kg 6,000,000 kg 68,182 kg 88 1 88
12

B 3,600,000 kg 12,000,000 kg 12,000,000 kg 68,182 kg 176 2 88

Rail Shipment - 95% Total Volume (Worst Case Scenario)

A 1,800,000 kg 6,000,000 kg 5,700,000 kg 68,182 kg 84 1 84

B 3,600,000 kg 12,000,000 kg 11,400,000 kg 68,182 kg 167 2 84

Truck Shipment - 5% Total Volume (Worst Case Scenario)

A 1,800,000 kg 6,000,000 kg 300,000 kg 20,000 kg 15 1 15

B 3,600,000 kg 12,000,000 kg 600,000 kg 20,000 kg 30 2 15

Total annual worker exposure for Activity AD will depend on the number of trucks sent from the customer holding 

tank to the oilfield per year. Customer holding tanks will be located at the rail terminal. Based on projected total 

volume per customer or site for PMN Substances A and B, the number of expected shipments from customer 

storage to the oil field is given below. A dedicated truck for each PMN Substance for each customer will transport 

the product from the customer-owned storage tank to the oilfield.

Table 8. Annual Domestic Shipments - Customer Tank to Oilfield

PMN 

Substance

Max 12 Month 

Vol. (100%

Active)

Use in USA

Max 12 

Month Vol. 

as Received 

(30% Active)

Use in USA

Customers 

Sites per 

PMN 

Substance

Max 12 

Month Vol. 

per 

Customer

Shipment 

Size

Max Truck 

Shipments 

per Year

Max Truck 

Shipments 

per Year 

per 

Customer

A 1,800,000 kg 6,000,000 kg 1 6,000,000 kg 20,000 kg 300 300

B 3,600,000 kg 12,000,000 kg 2 6,000,000 kg 20,000 kg 600 300

Release 5 - During the above three activities, 0.5 kg of PMN Substance (30% active) per incoming shipment is 

collected from the bulk product for QC testing at the customer’s QC lab. After testing is complete, the remaining 

PMN Substance is held in retain for 120 days, after which the samples are poured into an accumulation drum. Once 

the drum is full, it is taken by a 3rd party certified chemical waste handler who has it incinerated. The maximum 

release in the US is detailed in the table below. Release 5 will take place at Customer Site - maximum of 14.9

kg per year of PMN Substance A and 29.7 kg per year of PMN Substance B to a controlled release 

technology.

Table 9. Release 5 - Annual Disposal of QC Samples from Customer Tank Site

PMN 

Substance

Sample 

Volume per 

Shipment 

(30% Active)

Max 

Shipments 

(Preferred 

Methods)

Max 

Shipments 

(Worst Case 

Scenario)

Release 

Volume 100%

Active 

(Preferred 

Methods)

Release 

Volume 100%

Active (Worst 

Case 

Scenario)

A

Rail Shipments 0.5 kg 88 84 13.2 kg 12.6 kg

Truck Shipments 0.5 kg 0 15 0 kg 2.3 kg

Total: 13.2 kg Total: 14.9 kg

B

Rail Shipments 0.5 kg 176 168 26.4 kg 25.2 kg

Truck Shipments 0.5 kg 0 30 0 kg 4.5 kg

Total: 26.4 kg Total: 29.7 kg

Process III. SHIPMENT OF MATERIAL TO CUSTOMER STORAGE will not result in a 

direct, uncontrolled release to the environment.

V. CLEANING 4, 5, & 7 - CLEANING OF TRUCKS & RAILCARS

After the PMN Substance has been unloaded from a truck or railcar the container must be cleaned. The cleaning 

process for truck and railcars hired by Sasol is given in detail below. See table 16 for a summary of the companies 

responsible for every step of the cleaning process.
13

Truck Cleaning - Trucks arranged by Sasol will be hired through one of two places: Superior Carriers http://superiorcarriers.com or Quality Distribution www.qualitydistribution.com. Sasol has spoken with both companies and their 

methods for handling truck-cleaning are similar. A detailed overview is given in Figure 5. 

Sasol’s preferred shipping company, Superior Carriers, owns and operates trucks for chemical transport.. They also 

have a new facility for truck washing in Pasadena, TX. Any truck that would transport Sasol’s PMN Substances 

would return to the Pasadena facility for washing. Superior Carriers has the capability to pre-treat the rinse water

before sending it to the POTW, meaning they remove all sludges, oil, and solids. They also adjust the pH before 

sending the wastewater on to Gulf Coast Waste Water Treatment Authority. Superior is connected to Gulf Coast 

Waste Water Treatment Authority (TPDS 01054) by pipeline.

 

As a secondary option, Sasol would use Quality Distribution (QD). They own and operate trucks for chemical 

transport similar to Superior Carriers. However, QD does not have truck-washing capability. Instead, they send 

their trucks to one of several commercial fleet washing facilities around the country that QD has audited and 

approved for use. 70% of QD trucks are washed at any of the various locations of three national wash companies: 

Qualawash www.qualawash.com, Phillips Services www.pscnow.com, or Dana Trucking www.danacompanies.com. 

Each of these wash facilities appear to be reputable and have a defined plan for handling treatment of rinse water

that ultimately include biological treatment at an ASU. The specific outlet for the rinse water will depend on the 

location of the wash. In no case is rinse water released to a water body before biological treatment is done, at 

minimum.

Trucks carrying product from the customer holding tank to the oil well will be under the control of the customer. Our

customers indicate that this truck will be dedicated to carrying the PMN Substances only. Thus, washing of the truck 

will occur only 1 or 2 times per year if at all. The customers will use reputable truck-wash facilities which 

appropriately treat all rinse water.

Railcar Cleaning - Railcars will be used to transport product from the Vopak storage tank to the customer storage 

site. All railcars will be owned by Sasol and cleaned at only two places: VLS Recovery Services in Houston, TX 

www.vlsrs.com, or BW Services, Angelton, TX www.bwservices.biz. Both sites use the process described in Figure 

5. Railcars will be dedicated to transport only the PMN Substances. As a result, they will not be cleaned between 

transport. As a worst case scenario, a one time cleaning per year is used in the calculations given below.

When railcars are cleaned at VLS Recovery Services in Houston, TX, the wastewater is sent to either Bealine 

Environmental Services or Liquid Environmental Services for initial treatment and then to Gulf Coast Waste Water 

Authority for discharge. VLS have contracted 3rd party companies licensed in handing and disposing of hazardous 

and non-hazardous waste to take any resulting sludge/solids for incineration or land-fill.

When railcars are cleaned at BW Services in Angelton, TX, the initial rinse water treatment (solids/sludge/oil 

removal, chemical treatment/pH adjustment) is done at the BW Services facility. The rinse water is then sent by 

pipeline to the City of Angleton Waste Water Treatment according to permit 96001 for biological treatment. City of 

Angleton Waste Water discharges into Brushy Bayou according to permit TX 0057827. BW has contracted 3rd party 

companies licensed in handing and disposing of hazardous and non-hazardous waste to take any resulting

sludge/solids for incineration or land-fill.

The information given to describe the process for truck, and rail cleaning was obtained from multiple sources

including;

 Pat Farno and Trent Mere of Waste Water Specialties, a tank and truck wash and waste water treatment 

facility in Sulphur, LA. Waste Water Specialties cleans the tank trucks and railcars used by the multiple 

chemical manufacturing companies, (Citco, Sasol, Conoco, PPG, etc.) located in Westlake, LA. The 

process used at their facility is representative of the reputable truck and tank cleaning facilities located 

through the US. 

 Duncan Callaway, Technical Director of Stolt-Nielsen. As discussed in earlier sections, the StoltNielsen facility in Houston cleans all of the ISO containers. They clean trucks and railcars as well and 

employ a process almost identical to Waste Water Specialties.

 Bill Kitto of BW Services. BW Services is located in Angelton, TX and cleans up to 1000 rail cars per 

year.

 Wesley Arthur of VLS Services. VLS Services is located in Hockley, TX and is one of the leading railcar 

wash centers in Houston.

 Dirk Kercher and Greg Lockner of Superior Carriers. Superior Carriers has a new 4-bay truck wash 

facility at their Pasadena, TX site where trucks carrying PMN Substances would be washed. 

Detailed contact information for people consulted for this PMN is given in Table 18.
14

Cleaning 4, 5, & 7 - Trucks or railcars are moved into a bermed area for cleaning. A “spinner” is attached to the top 

hatch of the truck or rail through which water, solvent and/or steam is pumped and spays the walls of the container. 

All rinse water is captured and accumulated in a rinse water holding tank. Most industrial fleet washing facilities 

have on-site water pre-treatment. At minimum, they are able to separate the oils, sludges, and solids from the rinse 

water. The separated oils and solids are placed into a roll-off container where they are taken by a 3rd party certified 

chemical waste handler for incineration or land-fill. The resulting rinse water is then further treated either on site or 

at an off-site facility (such as Bealine) through chemical methods. Finally the water is sent to a municipal or industrial 

facility for biological water treatment, such as an activated-sludge unit, for breakdown of any dissolved organics. 

Both the off-site and on-site water pre-treatment facilities will not allow the processed water to be released to the 

municipal water treatment facility until the <200 mg BOD EPA guideline is reached. PMN Substances A & B are 

water soluble so they will remain in the rinse water and not in the sludges or oils throughout the cleaning process.

The sources above report that a truck must have <20 gallons and railcars must have <50 gallons of residual PMN 

Substance A or B in order to be considered “empty” and ready for washing. They report that most often trucks will 

have only 5 gallons of residual product (19 kg of 30% active or 6 kg of 100% active) and railcars will have <10

gallons (38 kg of 30% active or 12 kg of 100% active). If there is greater than 20 gallons there is a RECRA rule that 

dictates the residuals must be removed before washing can begin. Removed residuals would be vacuumed into a 

drum. The drum would be sent back to Sasol to be sold as “good product” or turned over to a 3rd party company

licensed in handing and disposing of hazardous and non-hazardous waste who would incinerate or land-fill the 

residuals within the drum.

A block diagram of a typical truck cleaning process in given below:
15

Figure 5. Cleaning of Trucks and Railcars

Each of the three activities is explained below along with the number of people exposed to PMN Substances A or B 

during the activity and the duration of the exposure

Activity Description People Exposed Time Exposed

AE

Hook up spinner to truck and 

remove when cleaning complete. 

Inspect and certify clean container 

1 Truck-Wash Facility 

Worker 20 minutes

AF

Hook up truck to rinse-water 

accumulation tank for transport of 

truck/railcar rinse water to off-site 

pre-wastewater treatment

1 Truck-Wash Facility 

Worker 5 minutes

AG

Hook up truck carrying rinse water 

to off-site pre-wastewater 

treatment tank

1 Waste-Water Facility 

Worker 5 minutes

AH

Hook up truck to on-site prewastewater treatment tank for 

transport of rinse water to POTW

1 Waste-Water Facility 

Worker 5 minutes

AI Hook up truck carrying rinse water 

to POTW

1 POTW Facility Worker 5 minutes
16

Total annual US worker exposure of AE to the PMN Substances will depend on the number of trucks and railcars 

washed each year. As stated earlier, the preferred method of shipping product from the Vopak tank to the customerowned tank will be by railcar, but a worst case scenario would be to send 95% by railcar and 5% by truck. All 

railcars used for this leg of transportation would be in dedicated service to the PMN Substance and will only be 

washed one time per year. Even if only 95% of the shipments are by railcar, there would still be the same number of 

railcars in use as if 100% of the shipments are by railcar. The shipping of product from the customer-owned tank to 

the oilfield will be 100% by truck, but it will be in dedicated trucks which are also washed only one time per year.

Table 10. Annual Number of Shipping Vehicles Washed

PMN 

Substance

Dedicated 

Railcars 

per 

Customer 

per Site 

Vopak to 

Customer

Truck 

Shipments 

per 

Customer 

per Site 

Vopak to 

Customer 

Dedicated 

Trucks per 

Customer 

per Site 

Customer 

to Oilfield 

(Domestic)

Customers 

Sites per 

PMN 

Substance 

(USA and 

Export)

Customers 

Sites per 

PMN 

Substance 

(USA Only)

Total 

Railcars 

Washed 

Within USA

Total 

Trucks 

Washed 

Within USA

Preferred Method (100% railcars - Vopak to customer)

A 8 0 1 3 1 24 1

B 8 0 1 3 2 24 2

Worst Case Scenario (95% railcars, 5% trucks - Vopak to customer)

A 8 15 1 3 1 24 46

B 8 15 1 3 2 24 47

It is difficult to determine the exact amount of exposure for the workers AF and AG above, as the exposure duration 

will be dependent on the number of trucks they hook up to the waste water treatment facility tank. Since the rinse 

water containing the PMN Substances will be accumulated with rinse water from other cleaning activities not 

involving the PMN Substances, an accurate number of shipments is difficult to calculate. Additionally, most 

industrial fleet cleaning facilities have their own water treatment or a direct pipeline to the waste water treatment 

facility and will not require the rinse water to be shipped off site making Activities AF and AG irrelevant. However, as 

a worse-case scenario, the same exposure as for AE could be used for AF and AG.

Release 6 - According to our sources there will be 19 kg of residual PMN Substance (~30% active) in the trucks 

before cleaning and 38 kg in railcars. Ultimately, 6kg of 100% active PMN Substance A or B per truck and 12 kg per 

railcar will end up in the rinse-water holding tank. 

The table below summarizes the mass of residual 100% active PMN Substance transferred to waste water treatment

in the rinse aid from the cleaning of trucks that transport the PMN Substances from Vopak to the customer site (5%

of total import volume) and from the customer site to the oil well. Each domestic customer/site will use a dedicated 

truck to transport the material from the customer-owned tank to the oilfield. As a result, the trucks will not require 

washing after each transport. Typically, dedicated trucks are only washed when they change service. However, for 

the purpose of a worse-case-scenario, a 1-time-per-year washing per truck will be used in this example. 

Table 11. Release 6 - Annual Disposal of Truck Wash Waste

PMN 

Substance

Number of Truck 

Shipments per 

Customer

Number of 

Customers/Sites 

Within USA

Number of 

Dedicated 

Trucks per 

Customer per 

Site

Residual PMN 

Substance 100%

Active 

Release Volume 

Worst Case Scenario (95% railcars, 5% trucks - Vopak to Customer)

A 15 3 0 6 kg 270 kg

B 15 3 0 6 kg 270 kg

Customer to Oilfield - Domestic (1 cleaning per truck per year)

A 300 1 1 6 kg 6 kg

B 300 2 1 6 kg 12 kg

Railcars used to transport the PMN Substances from the Vopak holding tank to the customer storage tank will be in 

dedicated service to the PMN Substance. As a result, the railcars will not require washing after each transport. 

Typically, dedicated railcars are only washed when they change service. However, for the purpose of a worse-case-
17

scenario, a 1-time-per-year washing per-railcar will be used in this example. Release 6 is to POTW from rail and 

truck cleaning - maximum of 564 kg per year of PMN Substance A and 570 kg per year of PMN Substance B 

to a controlled release technology.

Table 12. Release 6 - Annual Disposal of Railcar Wash Waste

PMN 

Substance

Number of 

Railcar 

Shipments per 

Customer

Number of 

Customers/Sites 

Within USA

Number of 

Dedicated 

Railcars per 

Customer per 

Site

Residual PMN 

Substance 100%

Active 

Release Volume 

Preferred Method (100% railcars - Vopak to customer)

A 88 3 8 12 kg 288 kg

B 88 3 8 12 kg 288 kg

Worst Case Scenario (95% railcars, 5% trucks - Vopak to Customer)

A 84 3 8 12 kg 288 kg

B 84 3 8 12 kg 288 kg

Process V. CLEANING 4, 5, & 7 - CLEANING OF TRUCKS will not result in a direct, 

uncontrolled release to the environment.

VI. RECEIPT AND USE OF PMN SUBSTANCES AT THE OILFIELD

A dedicated truck for each PMN Substance for each customer will transport the product from the customer-owned 

storage tank to a holding tank at the oilfield. The PMN Substances will be received as 30% active. The PMN 

Substances then will be metered from the holding tank through an automated system where it will be mixed with 

other components such as water, additives, solvents, polymers, and other surfactants and finally injected into the 

well at 0.05 to 0.50% active, with most preferred being 0.1%.

3 samples will be taken for QC analysis by Customer Technicians before the PMN Substances are injected into the 

well. 1 sample of each shipment will be evaluated to assure the PMN Substances’ quality. 2 samples will be taken 

per day of the blended formula being injected into the well.

All water at the well site will be recycled throughout the injection process. After the injection project is completed, 

any residual water will be re-injected into the now oil-empty well or into another well on the same field set-aside for 

injection of waste materials. 

A block diagram of the process is given below.
18

Figure 6. Receipt and Use of PMN Substance at the Oilfield

Each of the three activities is explained below along with the number of people exposed to PMN Substances A or B 

during the activity and the duration of the exposure

Activity Description People Exposed Time Exposed

AJ

Truck arrives at field chemical facility. 

Hose hooked from truck to tank 0.25kg 

spl collected for QC lab. PMN 

Substances transferred to tank. Hose 

disconnected.

1 Customer Inspector

1 Customer Worker

15 minutes 

cumulative

AK 0.25kg Sample of the well formulation 

including PMN Substance taken 2x daily 1 Customer QC Technician 10 minutes cumulative/day

AL

Analysis of QC samples1 spl of PMN Substance upon arrival

2 spls of well formula / day 

1 Customer QC Technician 30 minutes 

cumulative

Total worker exposure for Activities AI and AJ will result from twice daily QC samples of the final chemical formula 

being injected into the well, 730 samples per year. Total annual worker exposure for Activities AH and AJ will 

depend on the number of trucks containing the PMN Substances received at the field. The table below gives the 

expected number of deliveries of each PMN Substance to the field each year per customer site. As stated earlier, 

PMN Substance B will be used by two US customers simultaneously while PMN Substance A will only be used by 

one customer based on the volumes expected to be manufactured.

Table 13. Annual Domestic Shipments - Customer Tank to Oilfield 

PMN 

Substance

Max 12 Month Vol. 

per Customer (30%

Active)

Customers Sites 

per PMN Substance Shipment Size

Max Truck Shipments per 

Year per Customer 

(Customer Tank to Oilfield)

A 6,000,000 kg 1 20,000 kg 300

B 6,000,000 kg 2 20,000 kg 300

The PMN Substance is added to the well to release the interfacial tension between the residual oil and rock to which 

the oil is bound. Once released, the oil can then be swept through and out of the well by the polymer (Non-PMN 

Component 1) and water. Ultimately, both the oil and the water-based fluids are pumped from the reservoir as a 

mixture. It is then necessary to separate the water from the other organic materials (oil and other organics from 

original carrier fluid formulation). The water is normally separated using either chemical or physical methods, treated 
19

to restore salinity levels, and then recycled to be injected again. Core-flood studies (laboratory simulations 

conducted on a core drilled from the oilfield) confirm that a significant portion of the PMN Substance either binds to 

the subsurface formation, breaks down in the formation, or patricians into the oil. On a study employing a 1 ft core, 

0.1% active PMN Substance was injected into the core and at most only 0.02% PMN Substance was produced and 

isolated from the flood water out the other side of the core. That is, for every 1 ft of reservoir traveled, 80% of the 

surfactant is either bound, destroyed, or partitioned such that it is not present in the water exiting the well. In true 

field applications, the distance between injection and production is >100 ft. Thus, only trace levels (<1 ppb), if any of 

the PMN Substances, are expected to be present in the produced water in the actual oil field. The separated water 

is then reused to make additional carrier fluid. 

Release 7 - During the above activities, 0.25 kg of PMN Substance (30% active) per incoming shipment is collected 

from the bulk product for QC testing. Two 0.25 kg samples of the formulated PMN Substance (0.1% active) per day 

are also collected for QC testing. After testing is complete, the remaining sample is held in retain for 5 days, after 

which the samples are poured into an accumulation drum. Once the drum is full, it is taken by a 3rd party certified 

chemical waste handler who has it incinerated. Release 7 will take place at Customer Sites - maximum of 22.7

kg per year of PMN Substance A and 45.2 kg per year of PMN Substance B to a controlled release 

technology. The maximum release in the US is detailed in the table below.

Table 14. Release 7 - Annual Disposal of QC Samples from Oilfield Site

PMN 

Substance

Sample Volume 

(30% Active)

Max Shipments / 

Max Samples 

per Year

Sample Percent 

Active Release Volume 

A

Truck Shipments 0.25 kg 300 30% 22.5 kg

Formulation 0.25 kg 730 0.1% 0.2 kg

Total: 22.7 kg

B

Truck Shipments 0.25 kg 600 30% 45 kg

Formulation 0.25 kg 730 0.1% 0.2 kg

Total: 45.2 kg

Process V. RECEIPT AND USE OF PMN SUBSTANCES AT THE OILFIELD will not 

result in a direct, uncontrolled environmental release.

VII. CLEANING 6 & 8 - CLEANING OF CUSTOMER TANKS

Finally, it is also necessary to account for cleaning of the storage tanks that house the PMN Substances at the 

customer sites. Tanks are emptied and cleaned for inspection once every 3 to 5 years. For the purpose of a worsecase scenario, a 1-time per year washing per tank will be used in this example. As stated earlier, “emptied” tanks 

can contain up to 50 gallons of the original product. In this case, 50 gallons of the PMN Substances is 190 kg of 

30% active material or 57kg of 100% active product. 

Cleaning 6 - Customer storage tanks at the rail-site will be washed as described in the Vopak tank washing section 

above. The customer would contract a tank cleaning company who would send a portable cleaning unit to the tank 

site. The driver of the unit would hook up the cleaning system (similar to the spinner system used on ISO 

containers) to the “man way” or other port-hole to the tank. The cleaning system would spray water, solvent, 

detergent, and/or steam, as required in the cleaning procedure for the original product. All rinse water would be 

collected by vacuum into the portable cleaning truck such that the tank was left cleaned and dried, and the rinsewater would be contained. The rinse water is then either injected into the customer’s waste water disposal well or it 

is taken to an industrial waste water treatment facility for biological treatment. 
20

Figure 7. Cleaning of Customer Rail-Site Holding Tank

Activity Description People Exposed Time Exposed

AM Hooking up and disassembling portable 

tank wash system 1 Tank Wash Worker 20 minutes

AN

Attaching hose from truck to water 

treatment plant. Detaching hose from 

truck to water treatment plant.

1 Tank Wash Worker 10 minutes

Using the same assumptions as before, a 1-time per year washing per tank will be used, along with 57kg of 100% 

active PMN Substance residue in each tank. Release 8 will take place at either a Disposal Well or to 

Wastewater Treatment - maximum of 57 kg per year of PMN Substance A and 114 kg per year of PMN 

Substance B to a controlled release technology. 

Table 15. Annual Disposal of Cleaned Customer Rail-Site Holding Tank Waste

PMN 

Substance

Residual PMN 

Substance 100%

Active in RailSite Tank

Number of Tanks 

per Substance 

per Site

Customers Sites 

in USA per PMN 

Substance

Release Volume 

100% Active per 

Site

Release Volume 

100% Active 

Total

A 57 kg 1 1 57 kg 57

B 57 kg 1 2 57 kg 114

Cleaning 8 - When PMN Substance A or B will no longer be injected into the EOR well at a particular site, the field 

holding tank will also need to be cleaned. The tank will be cleaned by rinsing it with water. This rinse water will then 

be injected into and left in the EOR well. 

Any remaining water at the end of the project will be injected into the disposal well.
21

Figure 8. Cleaning of Customer Field Holding Tank

Field Holding Tank

Water

Meter Mix System

EOR Well

Oil/Water 

Separation

Oil Tank

Oil 

Water 

Treatment

Water

Cleaning

8

50-100% of PMN Substance 

will bind to rock formation

Disposal Well

<1ppb PMN 

Substance in water 

produced from well

Release 

9

Release 9 - Release 9 will be in the Customer’s Disposal Well - maximum release is difficult to accurately

determine but is expected to be <1ppb.

Table 16. Release 9 - Maximum Annual Disposal to the EOR Well or an On-site Waste Disposal Well 

PMN Substance

US Oilfield 

Sites/Tanks per 

PMN Substance

Residual PMN 

Substance 100%

Active in Tank

Residual PMN 

Substance in Water 

After Pumping and 

Separation from Oil

PMN Substance 

Injected into 

Disposal Well

A 1 57 kg 1 ppb <1 ppb

B 2 57 kg 1 ppb <1 ppb
22

Table 17. Summary of Parties Involved in Tank, Truck and Rail Cleaning.

Rinse 

Water 

Origin

Party

Responsible 

for Cleaning

Location Where Cleaning 

Will Take Place

Facility Where Rinse Water 

Pretreated Permit Further Facility Where Wastewater Biologically Treated Permit

Vopak 

Holding 

Tank 

Vopak

Vopak -

Galena Park, 

TX

http://www.v

opak.com Vopak - Deer 

Park, TX

http://www.vopa

k.com TPDS: 

WQ0001731000

Ship Tank Stolt

Port of 

Houston or 

Vopak Dock Bealine Env. 

Serv. -

Pasadena, TX

http://bealineenv.com

EPA ID: 

TXD980809859

State ID: 40421

Gulf Coast 

Waste Water 

Authority -

Pasadena, TX

http://www.gcw

da.com/index.ht

ml

TPDS: 01054

NPDS: 

ISO TX0005380

Containers Stolt

Stolt-Nielsen 

Houston

facility

www.stoltnielsen.com

Railcars Sasol

VLS 

Recovery 

Service, 

Hockley, TX

http://www.vl

srs.com

Bealine Env. 

Serv. -

Pasadena, TX

http://bealineenv.com

EPA ID: 

TXD980809859

State ID: 40421

Gulf Coast 

Waste Water 

Authority -

Pasadena, TX

http://www.gcw

da.com/index.ht

ml

TPDS: 01054

NPDS: 

TX0005380

Liquid Env Serv -

Houston, TX

http://www.liqui

denviro.com

EPA ID: 

TXD000057000

State ID: H2234

BW Services, 

Angelton, TX

http://www.b

wservices.bi

z

BW Services -

Angelton, TX

http://www.bws

ervices.biz/2.ht

ml

Permit to discharge to 

City of Angleton 96001

City of Angelton 

Waste Water 

Treatment

http://www.angl

eton.tx.us/publi

cworks.cfm

NPDS: 10548-

004

TX0057827

Trucks

Sasol (Quality 

Distribution)

QualaWash www.qualaw

ash.com

Phillips 

Services

www.pscnow

.com

Dana 

Trucking

www.danatru

cking.com

Sasol 

(Superior

Carriers)

Superior 

Carriers, 

Pasadena, 

TX

http://www.s

uperiorcarriers.com/

Superior

Carriers

http://www.supe

riorcarriers.com/

Permit to discharge to 

Gulf Coast Waste 

Water Authority

Gulf Coast 

Waste Water 

Authority -

Pasadena, TX

http://www.gcw

da.com/index.ht

ml

TPDS: 01054

NPDS: 

TX0005380

Customer 

Storage 

Tank

Customer

(Contract 

cleaning 

service)

Customer 

Site

All rinse water to 

disposal well or 

ASU water 

treatment

POTW or 

Disposal Well

Customer 

Oil Field 

Holding 

Tank

Customer Customer Oil 

Field

All rinse water to 

EOR well or 

customer 

disposal well

Disposal Well 

or EOR Well
23

Table 18. Contacts

Company Contact Contact Title Contact Email Address Phone

Gulf Coast Waste Disposal 

Authority

Scott Harris Compliance 

Coordinator sharris@gcwda.com 910 Bay Area Blvd, 

Pasadena, TX

281-474-4111

Kathy Richolson Compliance 

Coordinator KRichols@gcwda.com 281-488-4115

Bealine Environmental Services Blake Erwin Blake.erwin@bealine-env.com

9717 Chemical Rd, 

Pasadena, TX 77507 281-474-4200

BW Services Bill Kitto Environmental and 

Permitting 512-680-5311

VLS Recovery Services Wesley Arthur EH&S Manager Wesley.Arthur@vlsrs.com 17020 Premium Drive, 

Hockley, TX 77447 

281-881-3656

936-372-0464 ext. 

132

Cell: 281-881-3656

Vopak

Tiffany Hill Environmental tiffany.hill@vopak.com 281-604-6083

Tony Kinner Customer Service 

Manager tony.kinner@vopak.com Galena Park, Texas 77547 

Stolt-Nielsen Dustin Callaway Technical Director D.Callaway@stolt.com United States 281-860-6427

Liquid Environmental Services Bob Kapplinger Irving TX 75063 281-753-9382

Quality Distribution

Kevin Gautreau kgautrea@qualitydistribution.c

om

Cell: 225-385-1919

Robert E. 

Smale 

Director, Chemical 

and Environmental 

Services

211 Welsh Pool Rd. Suite 

100, Exton, PA 19341

Office: 813-569-7280

Cell: 610-764-7898

Fax: 813-628-6854 

Superior Carriers Dick Kircher DKircher@superiorcarriers.com Cell: 713-899-4406

City of Angleton Waste Water Olga Flores Plant Manager oflores@angleton.tx.us 979-849-3514
24

All containers that housed the PMN Substances for storage or transport will be cleaned by a reputable and EPA 

compliant facility that specializes in washing truck and rail fleet. All resulting rinse aid will be processed through an 

industrial water treatment facility before being released to municipal water treatment. Laboratory studies contained 

in this application show that 20-40% of the total dissolved organic carbon of the PMN Substances is biodegraded 

during porous pot waste water treatment simulation tests with 6hr HRT. This 20-40% degradation represents the 

primary degradation of the molecule into metabolites that do not degrade rapidly but no longer exhibit the aquatic 

toxicity of the parent compound.