## 1

**I. IMPORTA** **TION, STORA GE, A**  **ND TRA NSFER TO SHIPPING VESSELS IN US**  The PMN S ubstances 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. Wh en the ship carrying the PMN Substance s (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, Gal ena 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/ PM N Substance s 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). Vop ak tanks are designed with the required bermming and spill - catch containment. PM N 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 . W hen 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 b y 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 unl oading 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 hazardou s 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 atta chment/detachment will be conducted by Vopak workers trained to handle hazardous and non hazardous 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 th e 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 P MN Substances A or B during the activity and the duration of the exposure. **Activit y**  **Description People Exposed**  **Time Exposed Unloading of a Ship**  A Inspection of PMN Substances on ship 3x 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 W orker 5 minutes C After PMN Substance transferred through hose/pipeline to dock a 0.5 kg spl collected for visual inspection 1 Intertek In spector 1 Vopak W orker 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 W orker 5 minutes E Hose attached to tank 1 Vopak W orker 5 minutes F Aft er 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 We stlake QC lab 1 Intertek Inspector 10 minutes H Analysis of QC samples 5 spls of PMN Substance tested 1 Intertek QC Technician 60 minutes cumulative I Analysis of Sasol QC sample 1 spl of PMN Substance tested 1 Sasol QC Technician 15 minutes cumulative **Unloadin g 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 W orker 5 minutes L Hose from ISO container connected to holding tank. 1 Vopak W orker 5 minutes
M All ISO containers within shipment emptied. Tank filled. Tank weight/volume re corded. 0.5kg spl collected and taken to QC lab, 0.5kg spl collected and shipped to Sasol We stlake QC lab 1 Intertek Inspector 10 minutes
N Analysis of QC samples 2 spls of PMN Substance tested 1 Intertek QC Technician 30 minutes cumulative O Analysis of Sasol QC sample 1 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 W orker 10 minutes Q Ho se connected to truck or railcar. 1 Vopak W orker 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 samples 1 spl of PMN Substance tested 1 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, calculation s 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%** **A ctive)**  **Max 12 Month Vol.**  **as Received (30%** **A ctive)**  **Max 12 Month**

**Vol. Shipped per Method**  **Shipment Siz e**  **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 9 5 % 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%** **A ctive)**  **Max 12 Month Vol.**  **as Received (30%** **A ctive)**  **Max 12 Month**

**Vol. Shipped per Method**  **Shipment Size Max Shipme**  **nts 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 9 00,000 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 3 rd party certified chemical waste handler who has it incinerated. **Release 1 occurs at Intertek Testing Lab**  **- maximum of**  **102 kg per y** **ear, 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%** **A ctive)**  **Max Shipments**

**(Preferred Methods)**  **Max Shipments**

**(Worst Case Scenario)**  **Release Volume**

**100% A** **ctive (Preferred**  **Metho ds)**  **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 con tainers 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 poure d 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 ye**  **ar, 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%** **A ctive)**  **Max Shipments**

**(Preferred Methods)**  **Max Shipments**

**(Worst Case Scenario)**  **Release Volume**

**100% A** **ctive (Preferred**  **Methods) Release Volume** 

**100% A** **ctive (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 

## IMPORTA**TION, STORA GE, A**  **ND TRA NSFER TO SHIPPING VESSELS IN US**  **will not**  **result in a direct, uncontrolled release to the environment.** 

## II. **CLEA NING 1 & 2**  **- CLEA**  **NING OF SHIP -**  **BOA RD TA**  **NKS AND I**  **SO CONTA** **INERS THA T CONTA** **INED PMN SUBSTA NCES**  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 sh ows 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 Substance s A and B. According to Paul Dunn of Stolt- Nielsen, www.stolt- nielsen.com/Stolt- Tankers - Terminals.aspx , the process for ship tank 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 con tact 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 proce ss 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**  **1 00%** **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. Cleani ng 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 - Terminal s.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 ship tank cleaning in that a “spinner” is attached to the top hatch of the ISO container. W ater, 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 compl etely “empty”. There will be at most 19 kg of residual PM N 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. **Ul timately** **, 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 3 rd party certified chemical waste handler who has it incinerated, land -fille d, 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 W aste Treatment facility (CWT ) as defined by the US EPA. A CW T treats wastewater prior to discharge to a Public Operated Treatment W orks (POT W) . The POTW Bealine discharges to is operated by The Gulf Coast W aste 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 W aste Disposal Authority operates a state - of - the art process unlike anything else in the world. Bealine is conn ected 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 Wa shburn Tunnel Facility located on the Houston Ship C hannel, the Bayport Industrial W astewater Treatment Facility located in the Bayport Industrial District in Pasadena, Texas, the 40

–Acre Facility in Texas City and the Odessa Regional W astewater Treatment Facility in Odessa, Texas.” Bealine transfers th eir rinse water to the GCA Pasadena facility exclusively. The GCA Pasadena facility discharges the treated wastewater into Galveston Bay under permit TPD S 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 : TXD 980809859 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 t he 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 **Activit y**  **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 W orker 5 minutes U Hook up spinner to ISO container and remove when cleaning complete. Inspect and certify cl ean container 1 Stolt W orker 20 minutes V Hook up truck carrying ship slop tank water to accumulation tank 1 Stolt W orker 5 minutes W Hook up hose to truck to transfer rinse water to Bealine for waste water treatment 1 Stolt W orker 5 minutes cumulative X Hook up truck carrying ship slop tank water to waste water treatment tank 1 Wa ste -Wa ter Facility Wo rker 5 minutes Y Hook up truck carrying ISO rinse water to waste water treatment tank 1 Wa ste -Wa ter Facility Wo rker 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 - case scenario, 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 y ear, of PMN**  **Substance A and B to a controlled release technology .**  **Table 5**  **. Release 3 -**  **Annual Di sposal of Cleaned Ship**  **- Tank & ISO Container Waste**  **PMN Substance**  **Max 12 Month**

**Vol. Shipped per Method**  **(30% A** **ctive) Shipment** 

**Size Max Boat/ ISO** 

**Container Shipments**  **per Year Residual Volume** 

**of 100% A** **ctive PMN Substance in**  **Empti ed**  **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 (Wors**  **t 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 

## CLEA **NING 1 & 2 -**  **CLEA NING OF SHIP**  **- BOA**  **RD TA NKS**  **AND I SO CONTA**  **INERS THA** **T CONTA INED PMN SUBSTA**  **NCES will**  **not result in a direct, uncontrolled release to**  **the environment.** 996 kg

## 9

**III. CLEA**  **NING 3 -**  **CLE ANING OF VOPA**  **K TANKS** Cleaning 3 - PMN Substances A an d 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 s cenario 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 send s 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 IS O containers) to th e “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 rinse water would be contained. The rinse water is then transported by truck to Vopak’s wastewater treatment plant at their Deer P ark 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 **Activit y**  **Description People Exposed**  **Ti me Exposed**  Z Hooking up and disassembling portable tank wash system 1 Tank W ash W orker 20 minutes AA Attaching hose from truck to water treatment plant. Detaching hose from truck to water treatment plant. 1 Tank W ash W orker 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 eve ry 5 years . For each tan k, 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 pla ce at Vopak Deer Park Site**  **- maximum of 114 kg**  **per y ear**  **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% A** **ctive 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 

## CLEA **NING 3 -**  **CLE ANING OF VOPA**  **K TANKS will**  **not result in a direct, uncontrolled**  **release to the environment.** 

## IV. **SHIPMENT OF MA TERIA**  **L TO CU STOMER STORA** **GE** 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 y**  **ears 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**  **wi ll 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 holdin g 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 t ank quickly. S hipping 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. O ur customers indicate tha t 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 assure d that they have the truck and driver available “ on demand ”. This i s 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 fro m the rail - site storage tank to the oil field. Secondly, the customers do not want to be concerned about cross contaminatio n. 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 ove rall 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

. **Activit y**  **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 transfe rred to tank. Hose disconnected. 1 Customer Inspector 1 Customer Wo rker 15 minutes cumulative

AC Analysis of QC sample 1 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 Wo rker 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 pe r 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% A** **ctive) 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 tota l 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% A** **ctive) 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 i s collected from the bulk product for QC testing at the customer’s QC lab . After testing is complete, the remaining PM N 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 3 rd 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 y ear of PMN Substance A and**  **29.7 kg per y**  **ear of PMN Substance B to a controlled release**  **technology .**  **Table 9**  **. Release 5**  **- Annual Dispos**  **al of QC Samples from Customer Tank Site PMN**  **Substance Sample**  **Volume per Shipment**  **(30% A** **ctive) Max** 

**Shipments (Preferred**  **Methods) Max** 

**Shipments (Worst Case**  **Scenario) Release** 

**Volume 100% Active**  **(Preferred Methods)**  **Releas e** 

**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 MA** **TERI AL** **TO CU STOMER STORAGE**  **will not result in a direct, uncontrolled release to the environment.**  

## V. **CLEA NING 4**  **, 5**  **, & 7 -**  **CLEA NING OF TRUCKS & RA**  **ILCA RS**  After the PMN Substance has been unloaded from a truck or railcar the container must be cleaned. T he 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 , own s and operate s trucks for chemical transport

. . They also have a new facility for truck wash ing 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 POT W , meaning they remove all sludges , oil, and solids. They also adjust the pH before sending the wastewater on to Gulf Coast W aste Wa ter Treatment Authority. Superior is connected to Gulf Coast Wa ste W ater Treatment Authority (TPDS 0 10 54 ) 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 the ir trucks to one of several commercial fleet washing facilities around the country th at QD ha s 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.c om , 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 a n 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 describe d 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. Wh en railcars are cleaned at VLS Recovery Services in Houston, TX, the wastewater is sent to either Bealine Environmental Services or Liquid Environmental Servic es for initial treatment and then to Gulf Coast W aste Wa ter Authority for discharge. VLS have contracted 3 rd party companies licensed in handing and disposing of hazardous and non - hazardous waste to take any resulting sludge/solids for incineration or lan d -fill. Wh en 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 BWServices facility. The rinse water is then sent by pipeline to the City of Angleton W aste W ater Treatment according to permit 96001 for biological treatment . City of Angleton W aste W ater discharges into Brushy Bayou according to permit TX 0057827

. BWhas contracted 3 rd party companies licensed in handing an d 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. W aste W ater Specialties cleans the tank trucks and railcars used by the multiple chemical manufacturing companies, (Citco, Sasol, Conoco, PPG, etc.) located in W estlake, LA. The process used at their facility is representative of the reputable truck and tank cleaning facilities located through th e 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 almo st identical to W aste W ater Specialties.  **Bill Kitto of BW Services**

. BWServices 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 c onsulted 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 th rough 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, the y 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 3 rd party certified chemical waste handler for incineration or land -fill . The result ing 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 , s uch 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 10 0% 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 va cuumed into a drum . The drum would be sent back to Sasol to be sold as “good product” or turned over to a 3 rd party compan y licensed in handing and disposing of hazardous and non - hazardous waste who would incinerate or land -fill the residuals within the d rum. 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 **Activit y**  **Description People Exposed**  **Time Exposed** AE Hook up spinner to truck and

remove when cleaning complete. Inspect and certify clean container 1 Truck-Wa sh Facility Wo rker 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-Wa sh Facility Wo rker 5 minutes
AG Hook up truck carrying rinse water

to off - site pre -wastewater treatment tank 1 Wa ste -Wa ter Fac ility Wo rker 5 minutes
AH Hook up truck to on - site pre wastewater treatment tank for transport of rinse water to POTW 1 Wa ste -Wa ter Facility Wo rker 5 minutes AI Hook up truck carrying rinse water

to POT W 1 POTW Facility W orker 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 9 5% 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 s ame 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 p er**  **Customer per Site**  **Customer to Oilfield**  **(Domestic) Customers** 

**Sites per PMN**  **Substance (USA and**  **Export) Customers** 

**Sites per PMN**  **Substance (USA Onl**  **y) 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 accumu lated 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 wa ste 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 us ed 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, 6 kg 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 custo mer 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 wash ing 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% Act**  **ive 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 ye**  **ar)** 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 ded icated 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 wa shing per- railcar will be used in this example. **Release 6 is to POTW from rail and truck cleaning**  **- maximum of 5**  **64 kg per y**  **ear of PMN Substance A and 570 kg per y**  **ear 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**

**Substa nce 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. CLEA**  **NING 4 ,**  **5 , & 7**  **- CLEA**  **NING OF TRUCKS will not result in a direct,**  **uncontrolled release to the environment.** 

## VI. **RECEIPT A ND USE OF PMN SUBSTA**  **NCES A T 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 an alysis by Customer Technicians before the PMN Substances are injected into t he 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 wa ste 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 be low along with the number of people exposed to PMN Substances A or B during the activity and the duration of the exposure **Activit y**  **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 Wo rker 15 minutes cumulative AK 0.25kg Sample of the well formulation including PMN Substance taken 2x da ily 1 Customer QC Technician 10 minutes cumulative/day AL Analysis of QC samples 1 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, PM N Substance B will be used by two US customers simu ltaneously 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**  **Substa nce**  **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 metho ds , 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 po rtion of the PMN Substance either binds to the subsurfa ce 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 th e 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 test ing 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 3 rd party certified chemical waste handler who has it incinerated. **Release 7**  **wi ll take place at Customer Site**  **s -**  **maximum of 22.**  **7 kg per y**  **ear of PMN Substance A and 4**  **5.2 kg per y** **ear of PMN Substance B to a controlled release technology**  **.** The maximum release in the US is detailed in the table below. **T able**  **14 . Release**  **7 -**  **Annual Disposal of QC Samples from Oilfield Site PMN**  **Substance Sample Volume**  **(30% A** **ctive) 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 A**  **ND USE OF PMN SUBSTA NCES A** **T THE OILFIELD will not**  **result in a direct, uncontrolled environmental release.** 

## VII. **CLEA NING 6 &**  **8 -**  **CLEA NING OF CUSTOMER TA**  **NKS** Finally, it is also necessary to account for cleaning of the storage tanks t hat 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 worse case 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 washe d a s described in the Vopak tank washing section above. The customer would contract a tank cleaning company who would s end 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 rinse water 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**

**Activit y**  **Description People Exposed**  **Time Exposed** AM Hooking up and disassembling portable tank wash system 1 Tank W ash W orker 20 minutes AN Attaching hose from truck to water treatment plant. Detaching hose from t ruck to water treatment plant. 1 Tank W ash W orker 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 y ear of PMN Substance A and**  **114 kg per y** **ear of PMN Substance B**  **to a**  **controlled release technolog**  **y .**  **Table 15**  **. Annual Disposal of Cleaned Customer Rail -** **Site Holding Tank Waste PMN**  **Substance Residual PMN** 

**Substance 100% Active in Rail**  **** **Site Tank Number of Tanks** 

**per Substance per Site**  **Customers Sites**

**in USA per PMN Substance**  **Release Volume**

**100% A** **ctive per Site**  **Release Volume**

**100% A** **ctive Total**  A 57 kg 1 1 57 kg 57 B 57 kg 1 2 57 kg 114 Cleaning 8 - Wh en 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 < 1 ppb PMN Substance in water produced from well

Release 9 Release 9 - **Rele ase 9 will be in the**  **C ustomer’s**  **D isposal**  **W ell**  **- 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%**  **A ctive 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 T ank, T**  **ruck and Rail Cleaning. Rinse**  **Water Origin**  **Party**

**Responsible for**  **Cleaning Location**  **Where C leaning**  **Will T ake**  **P lace**  **Facility Where**  **Rinse W**  **ater P**  **retreated Permit**  **Further Facility**  **W her** **e W**  **astewater B**  **iologically T**  **reated Permit**  Vopak Holding Tank Vopak Vopak - Galena Park, TX http://www.v

opak.com Vopak - Deer

Park, TX http://www.vopa

k.com TPDS:

WQ 0001731000 Ship Tank Stolt Port of Houston or Vopak Dock Bealine Env. Serv. - Pasadena, TX http://bealine env.com EPA ID:

TXD980809859 Stat e ID: 40421 Gulf Coast Wa ste W ater Authority - Pasadena, TX http://www.gcw

da.com/index.ht ml TPDS: 01054

NPDS: TX0005380 ISO Containers Stolt Stolt- Nielsen Houston facility www.stolt nielsen.com

Railcars Sasol VLS Recovery Service, Hockley, TX http://www.vl

srs.com Bealine Env.

Serv. - Pasadena, TX http://bealine env .com EPA ID:

TXD980809859 State ID: 40421 Gulf Coast Wa ste W ater 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 BWServices, Angelton, TX http://www.b

wservices.bi z BWServices -

Angelton, TX http://www.bws

ervices.biz/2.ht ml Permit to discharge to

City of Angleton 96001 City of Angelton Wa ste W ater Treatment http://www.angl

eton.tx.us/publi cworks.cfm NPDS: 10548 -

004 TX0057827

Trucks Sasol (Quality

Distribution) QualaW ash 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 W aste Water Authority Gulf Coast Wa ste W ater Authority - Pasadena, TX http://www.gcw

da.com/index.ht ml TPDS: 01054

N PDS: TX0005380 Customer Storage Tank Customer

(Contract cleaning service) Customer

Site All rinse water to disposal well or ASU water treatment POTW or Disposal W ell Customer Oil Field Holding T ank Customer Customer Oil Field All rinse water to EOR well or customer disposal well Disposal W ell or EOR W ell

## 23 **Table 18**  **. Contacts Company**  **Contact Contact Ti**  **t le**  **Contact Email Ad**  **dress Phone**  Gulf Coast W aste Disposal Authority Scott Harris Compliance Coordinator sharris@gcwda.com 910 Bay Area Blvd, Pasadena, TX 281 -474 -4111 Kathy Richolson Compliance

Coordin ator KRichols@gcwda.com 281 -488 -4115 Bealine Env ironmental Services Blake Erwin Blake.erwin@bealine - env.com 9717 Chemical Rd, Pasadena, TX 77507 281 -474 -4200 BWServices Bill Kitto Environmental and P ermitting 512 - 680 - 5311 VLS Recovery Servi ces We sley Arthur E H&S Manager We sley.Arthur@vlsrs.com 17020 Premium Drive, Hockley, TX 77447 281 - 881 - 3656 936 - 372 - 0464 ext. 132 Cell: 281 - 881 - 3656 Vopa k T iffany Hill Environmental tiffany.hill@vopak.com 281 - 604 - 6083 Tony Kinner Customer Service

Manager tony.kinner@vopak.com Galena Park, Texas 77547 Stolt - Nielsen Du stin Callaway Technical Director D.Callaway@stolt.com United States 281 - 860 - 6427 Liquid Environmental Services Bob Kappling er 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 W elsh 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

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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 dis solved 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 n o longer exhibit the aquatic toxicity of the parent compound.