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INITIAL REVIEW ENGINEERING REPORT 

PMN: 11-0530

Standard Review Draft 4/4/2013

ENGINEER: El-Zoobi \ AH \ JAS \ JD \ AG \ JAS
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INITIAL REVIEW ENGINEERING REPORT 

PMN: 11-0530
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.

INITIAL REVIEW ENGINEERING REPORT 

PMN: 11-0530
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INITIAL REVIEW ENGINEERING REPORT 

PMN: 11-0530
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INITIAL REVIEW ENGINEERING REPORT 

PMN: 11-0530
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INITIAL REVIEW ENGINEERING REPORT 

PMN: 11-0530
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INITIAL REVIEW ENGINEERING REPORT 

PMN: 11-0530
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INITIAL REVIEW ENGINEERING REPORT 

PMN: 11-0530
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C6F13 is 21.8% in PMN.// Perfluoro to WATER or

INCINERATION or LAND from container cleaning to:

uncertain: 2E-3 kg/site-day over 59 days/yr for 1 site or

0.1 kg/yr. // Perfluoro to WATER from Energency Use, to:

POTW with dilution : 0.9 kg/site-day over 59 days/yr for

1 site or 54 kg/yr.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 24

Basis: CEB assesses the std default minimum of 3

workers/site.

Inhalation:

Exposure to Mist (non-volatile) (Class I)

Output 1: 3.3E-2 mg/day over 1 days/yr

Output 2: 1.7E+0 mg/day over 1 days/yr

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

Basis: Emergency Use; User-defined Inhalation Model. Per

P01-0232 (MW = 316, 100% conc), exposure to foam is

expected during training and use on actual fires. During

fire fighting, exposures to the foam, its degradation

products, and toxic fumes from the fire may be expected

to be acute. Portable extinguishers -- 80 ppm outdoors, 1

minute to 900 ppm indoors, >7.5 minutes = 24 to 1,800

mg/episode. Total flooding systems -- 7,000 ppm, > 1

minute or up to 10,000 ppm, < 1 minute (assume| 30

seconds) = <1,900 mg/episode. This IRER assesses a range

of 80 ppm for 1 minute (portable fire| extinguisher) to

10,000 ppm for 30 seconds (flooding system). The PMN

concentration in the final foam is approximately 0.05%

(per 11/4/11 amendment); therefore the exposure is

adjusted according to the concentration.

NOTE: The respirator class is: I. Particulate (including

solid or liquid droplets).

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit

 or data not specific to industry): Yes

2)a) Exposure level > 1 mg/day? Yes

 OR

 b) Hazard Rating for health of 2 or greater? 2 Yes

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Exposure to Liquid at 1.20% concentration

High End: 2.1E+1 mg/day over 1 days/yr

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

Basis: Unloading Liquid Raw Material from Tank Trucks;

EPA/OPPT 2-Hand Dermal Contact with Liquids Model.
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INITIAL REVIEW ENGINEERING REPORT CBI: Yes

PMN: 11-0530

Use 4: Testing of Foam Systems at Industrial and Military

Facilities (38.6% of Total PV)

Number of Sites/ Location: 96

unknown, different sites each yr; release from specific

site once per period of expiration time.

Days/yr: 2

Basis: To estmate the number of sites, CEB assumes PV x

99% x 95% industrial+military use / industrial use rate x

Xnew. The industrial use rate is determined by the AFFF

methodology (El-Zoobi and Avcin) estimates that the

average amount of fluorinated surfactant used in

commercial-industrial facilities = 1,900,000 gallons AFFF

concentrate x density of AFFF concentrate x 1.06 %

average fluorinated surfactant in concentrate / 149

refineries. (1.06% is the average PMN concentration in

AFFF concentration for P11-530, P11-533, P11-534, P11-484,

 and P11-487). Calc:1,900,000 gal/site-yr x 3.78 kg/gal x

1.06% / 149 refineries = 510.93 kg/site-yr. Therefore,

the number of sites = 52,000 x 99% x 95% industrial use /

510.93 kg/site-yr = 96 sites, with 1 day/site. CS

calculates 6.8 kg/site-day.The total PV for this use is

653.2 kg/yr. See Release Section for discussion on

release days.

Process Description: AFFF concentrate (liquid, 1.2 %)

mixed with water to a concentration of around 0.05% and

discharged for testing purposes (per amendments 11/4/11

and 2/28/12)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources

to the same medium.

Water

Output 2: 3.4E+0 kg/site-day over 2 days/yr from 96 sites

to: CEB assumes POTW (with dilution)

from: System Testing

basis: User-Defined Loss Rate Model. CEB assumes

discharge from testing at industrial and military

facilities will sent to POTW with dilution. Release of

PMN is diluted during pre-treatment to not exceed a

maximum concentration of AFFF concentrate in POTW

influent that is indicated in product literature. A POTW

influent flow rate of 1 million liters per day is assumed

as a conservative value for calculation of a maximum

number of release days. The number of days is calculated

as follows: frequency = amount released / (concentration

limit * POTW influent flow rate). Concentration limit =

50 mg/L of AFFF concentrate for 3% AFFF concentrate * 1.
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2% PMN in concentrate = 0.6 mg/L. Frequency = 6.8 kg *

1000000 mg/Kg / (0.6 mg/L * 1000000 L/day) = 12 days.

Water or Incineration or Landfill

High End: 6.8E-3 kg/site-day over 2 days/yr from 96 sites

or 1.3E+0 kg/yr

to: uncertain

from: Cleaning Liquid Residuals from Tank Trucks Used to

Transport the Raw Material

basis: EPA/OPPT Bulk Transport Residual Model, CEB

standard 0.2% residual.

RELEASE TOTAL

6.5E+2 kg/yr - all sites

C6F13 is 21.8% in PMN. // Perfluoro to WATER or

INCINERATION or LAND from container cleaning to:

uncertain : 2.E-3 kg/site-day over 2 days/yr for 96 sites

or 0.3 kg/yr. // Perfluoro to WATER from Industrial and

Military Testing, to: POTW with dilution : 0.9

kg/site-day over 2days/yr for 96 sites or 142 kg/yr.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 2,358

Basis: CEB assesses the std default minimum of 3

workers/site.

Inhalation:

Exposure to Mist (non-volatile) (Class I)

Output 1: 3.3E-2 mg/day over 1 days/yr

Output 2: 1.7E+0 mg/day over 1 days/yr

Number of workers (all sites) with inhalation exposure:

Basis: System Testing; User-defined Inhalation Model. Per

P01-0232 (MW = 316, 100% conc), exposure to foam is

expected during training and use on actual fires. During

fire fighting, exposures to the foam, its degradation

products, and toxic fumes from the fire may be expected

to be acute. Portable extinguishers -- 80 ppm outdoors, 1

minute to 900 ppm indoors, >7.5 minutes = 24 to 1,800

mg/episode. Total flooding systems -- 7,000 ppm, > 1

minute or up to 10,000 ppm, < 1 minute (assume| 30

seconds) = < 1,900 mg/episode. This IRER assesses a range

of 80 ppm for 1 minute (portable fire| extinguisher) to

10,000 ppm for 30 seconds (flooding system). The PMN

concentration in the final foam is approximately 0.05%

(per 11/4/11 amendment); therefore the exposure is

adjusted according to the concentration.

NOTE: The respirator class is: I. Particulate (including

solid or liquid droplets).

INHALATION MONITORING DATA REVIEW

1) Uncertainty (estimate based on model, regulatory limit
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 or data not specific to industry): Yes

2)a) Exposure level > 1 mg/day? Yes

 OR

 b) Hazard Rating for health of 2 or greater? 2 Yes

Inhalation Monitoring Data Desired? Yes (both criteria

met)

Dermal:

Exposure to Liquid at 1.20% concentration

High End: 2.1E+1 mg/day over 1 days/yr

Number of workers (all sites) with dermal exposure: 288

Basis: Unloading Liquid Raw Material from Tank Trucks;

EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT CBI: Yes

PMN: 11-0530

Use 5: End of Life Disposal at Fire Departments (2.99% of

Total PV)

Number of Sites/ Location: 1,484

Unknown sites; emergencies unplanned/random so releases

likely occur at different sites each yr

Days/yr: 3

Basis: The AFFF methodology (El-Zoobi and Avcin)

estimates that the average amount of fluorinated

surfactant used in fire department facilities = 1,360,000

gallons AFFF concentrate x density of AFFF concentrate x

1.06% average fluorinated surfactant in concentrate / 32,

000 fire departments. Calc: 1,360,000 gal/site-yr x 3.78

kg/gal x 1.06% / 32,000 fire departments = 1.7 kg

PMN/site-day over 1 day/site. CEB assumes the PV for this

use is the (Total PV - (PV from uses 1-4)) x 5% = 2,527

kg/yr. The number of sites = 2,527 kg/yr / 1.7 kg

PMN/site-day = 1,484 sites. See Release Section for

discussion of release days.

Process Description: AFFF solution (liquid, 1.2%) charged

to fire fighting system and eventually removed from

system because solution expires (per engineering

judgement)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources

to the same medium.

Water

Output 2: 5.5E-1 kg/site-day over 3 days/yr from 1,484

sites

to: CEB asssumes POTW (with dilution)

from: Disposal of Expired AFFF Concentrate Containing the

PMN
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basis: User-Defined Loss Rate Model. There is a lag time

between commencement of PMN use and commencement of

releases that is equal to the PMN expiration time. The

technical contact indicates that 95% of PMN is disposed

to landill or incineration, and up to 5% to POTW (with

dilution). For this operation CEB assumes that release

from municipal fire departments may be sent to POTW (Use

6c estimates landfill or incineration releases). At an

influent flow rate of 1 million liters per day, a single

release would result in a concentration of 1.7 mg

PMN-day/L [Calc = (1.7 kg) x (1E6 mg/kg) / (1E6 L/day).

To obtain the required treatment rate of 0.60 mg PMN/L

(Calc = 50 mg conc/L-day (for 3% AFFF concentrate) x 1.2%

PMN), 3 days of release per year are required (Calc = 1.7

/ 0.60).

Water or Incineration or Landfill

High End: 1.7E-2 kg/site-day over 3 days/yr from 1,484

sites

or 7.6E+1 kg/yr

to: uncertain

from: Cleaning Liquid Residuals from Drums Used to

Transport the Raw Material

basis: EPA/OPPT Drum Residual Model, CEB standard 3%

residual.

RELEASE TOTAL

2.5E+3 kg/yr - all sites

C6F13 is 21.8% in PMN. // Perfluoro to WATER or AIR or

INCINERATION or LAND from container cleaning to uncertain:

 3.7E-3 kg/site-day over 3 days/yr for 1,484 sites or 17

kg/yr. // Perfluoro to WATER from discharge, to: POTW

with dilution : 0.12 kg/site-day over 3 days/yr for 1,484

sites or 534 kg/yr.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 2,742

Basis: CEB assesses 3 workers/site.

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 1.20% concentration

High End: 2.1E+1 mg/day over 1 days/yr

Number of workers (all sites) with dermal exposure: 4,452

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT

2-Hand Dermal Contact with Liquids Model.
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INITIAL REVIEW ENGINEERING REPORT CBI: Yes

PMN: 11-0530

Use 6a: Fire Fighting Conc for Deployment at Industrial

Facilities (36.9% of Total PV)

Number of Sites/ Location: 62

unknown, different sites each yr; release from specific

site once per period of expiration time.

Days/yr: 1

Basis: The AFFF methodology (El-Zoobi and Avcin)

estimates that the average amount of fluorinated

surfactant used in commercial-industrial facilities = 1,

900,000 gallons AFFF concentrate x density of AFFF

concentrate x 1.06 % average fluorinated surfactant in

concentrate / 149 refineries. (1.06% is the average PMN

concentration in AFFF concentration for P11-530, P11-533,

P11-534, P11-484, and P11-487). Calc:1,900,000

gal/site-yr x 3.78 kg/gal x 1.06% / 149 refineries = 510.

93 kg/site-yr. // Amendment (11/28/2011) provided by

Zofia Kosin estimated up to 65% of PV for industrial

facilities. CEB assumed the PV for this use is (Total PV

- PV from uses 1 through 5) x| 65% = 31,202 kg/yr //

Number of sites = PV / M_avg_refinery. Calc = 31,202 /

510.93 kg/site-yr = 62 sites.

Process Description: AFFF solution (liquid, 1.2%) charged

to fire fighting system and eventually removed from

system because solution expires (per engineering judgement

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources

to the same medium.

Water or Incineration or Landfill

High End: 1.0E+0 kg/site-day over 1 day/yr from 62 sites

or 6.2E+1 kg/yr

to: uncertain

from: Cleaning Liquid Residuals from Tank Trucks Used to

Transport the Raw Material

basis: EPA/OPPT Bulk Transport Residual Model, CEB

standard 0.2% residual. Media of release for container

cleaning is unknown. CEB assesses release to water,

incineration or landfill.

Incineration or Landfill

Output 2: 5.0E+2 kg/site-day over 1 day/yr from 62 sites

or 3.1E+4 kg/yr

to: CEB assume release to incineration or landfill

from: Disposal of Expired AFFF Concentrate Containing the

PMN

basis: User-Defined Loss Rate Model. Accounting for

container cleaning, LF = 1- 0.002 = 0.998. CEB assumes
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release to incineration or landfill from industrial

facilities. There is a lag time between commencement of

PMN use and commencement of releases that is equal to the

PMN expiration time.

RELEASE TOTAL

3.1E+4 kg/yr - all sites

C6F13 is 21.8% in PMN. // Perfluoro to WATER or AIR or

INCINERATION or LAND from container cleaning to uncertain:

 0.22 kg/site-day over 1 day/yr for 62 sites or 14 kg/yr.

// Perfluoro to INCINERATION or LAND from discharge, to:

incineration or land : 111.2 kg/site-day over 1 day/yr

for 62 sites or 6,892 kg/yr.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 114

Basis: CEB assesses the std default minimum of 3

workers/site.

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 1.20% concentration

High End: 2.1E+1 mg/day over 1 days/yr

Number of workers (all sites) with dermal exposure: 186

Basis: Unloading Liquid Raw Material from Tank Trucks;

EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT CBI: Yes

PMN: 11-0530

Use 6b: Fire Fighting Conc for Deployment at Military

Facilities (17.0% of Total PV)

Number of Sites/ Location: 18

unknown, different sites each yr; release from specific

site once per period of expiration time.

Days/yr: 1

Basis: The AFFF methodology (El-Zoobi and Avcin)

estimates that the average amount of fluorinated

surfactant used in military facilities = 2,836,500

gallons AFFF concentrate x density of AFFF concentrate x

1.06% average fluorinated surfactant in concentrate / 142

military facilities. (1.06% is the average PMN

concentration in AFFF concentration for P11-530, P11-533,

P11-534, P11-484, and P11-487). Calc: 2,836,500

gal/site-yr x 3.78 kg/gal x 1.06% / 142 military

facilities = 800.37 kg/site-yr. // Amendment (11/28/2011)
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provided by Zofia Kosin estimated up to 30% of PV for

military facilities. CEB assumes the PV for this

operation is (Total PV - PV for uses 1 through 5) x 30% =

14,401 kg/yr. // Number of sites = PV / M_avg_military.

Calc = (14,401kg/yr / 800.37 kg/site-yr = 18 sites.

Process Description: AFFF solution (liquid, 1.2%) charged

to fire fighting system and eventually removed from

system because solution expires (per engineering judgement

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources

to the same medium.

Water or Incineration or Landfill

High End: 1.6E+0 kg/site-day over 1 day/yr from 18 sites

or 2.9E+1 kg/yr

to: uncertain

from: Cleaning Liquid Residuals from Tank Trucks Used to

Transport the Raw Material

basis: EPA/OPPT Bulk Transport Residual Model, CEB

standard 0.2% residual. Media of release for container

cleaning is unknown. CEB assesses release to water,

incineration or landfill.

Incineration or Landfill

Output 2: 8.0E+2 kg/site-day over 1 day/yr from 18 sites

or 1.4E+4 kg/yr

to: CEB assumes incineration or landfill

from: Disposal of Expired AFFF Concentrate Containing the

PMN

basis: User-Defined Loss Rate Model. Disposal of Expired

AFFF Concentrate Containing the PMN. CEB assesses 99.8%

loss, accounting for container cleaning releases. LF= 1 -

Container Cleaning = 1 -0.002 = 0.998. There is a lag

time between commencement of PMN use and commencement of

releases that is equal to the PMN expiration time. CEB

assumes release to incineration or landfill.

RELEASE TOTAL

1.4E+4 kg/yr - all sites

| C6F13 is 21.8% in PMN. // Perfluoro to WATER or AIR or

INCINERATION or LAND from container cleaning to uncertain:

 0.35 kg/site-day over 1 day/yr for 18 sites or 6.3 kg/yr.

 // Perfluoro to INCINERATION or LAND from discharge, to:

incineration or land : 174 kg/site-day over 1 day/yr for

18 sites or 3,134 kg/yr.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 36

Basis: CEB assesses the std default minimum of 3
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workers/site.

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 1.20% concentration

High End: 2.1E+1 mg/day over 1 days/yr

Number of workers (all sites) with dermal exposure: 54

Basis: Unloading Liquid Raw Material from Tank Trucks;

EPA/OPPT 2-Hand Dermal Contact with Liquids Model.

INITIAL REVIEW ENGINEERING REPORT CBI: Yes

PMN: 11-0530

Use 6c: Fire Fighting Conc for Deployment at Fire

Departments (2.84% of Total PV)

Number of Sites/ Location: 1,410

unknown, different sites each yr; release from specific

site once per period of expiration time.

Days/yr: 1

Basis: The AFFF methodology (El-Zoobi and Avcin)

estimates that the average amount of fluorinated

surfactant used in fire department facilities = 1,360,000

gallons AFFF concentrate x density of AFFF concentrate x

1.06% average fluorinated surfactant in concentrate / 32,

000 fire departments. Calc: 1,360,000 gal/site-yr x 3.78

kg/gal x 1.06% / 32,000 fire departments = 1.75

kg/site-yr. (1.06% is the average PMN concentration in

AFFF concentration for P11-530, P11-533, P11-534, P11-484,

 and P11-487). // Amendment (11/28/2011) provided by

Zofia Kosin estimated up to 5% of PV for fire department

facilities. CEB assumed the PV for this operation (Total

PV - PV from uses 1 through 5) x 5% = 2,400 kg/yr. //

Number of sites = PV / M_avg_fire_dep. Calc = 2,400/ 1.7

kg/site-yr = 1,410 sites.

Process Description: AFFF solution (liquid, 1.2%) charged

to fire fighting system and eventually removed from

system because solution expires (per engineering judgement

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

IRER Note: The daily releases listed for any source below

may coincide with daily releases from the other sources

to the same medium.

Water or Incineration or Landfill

High End: 5.1E-2 kg/site-day over 1 day/yr from 1,410

sites

or 7.2E+1 kg/yr
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to: uncertain

from: Cleaning Liquid Residuals from Drums Used to

Transport the Raw Material

basis: EPA/OPPT Drum Residual Model, CEB standard 3%

residual. Media of release for container cleaning is

unknown. CEB assesses release to water, incineration or

landfill.

Incineration or Landfill

Output 2: 1.7E+0 kg/site-day over 1 day/yr from 1,410

sites

or 2.3E+3 kg/yr

to: CEB assumes landfill or incineration

from: Disposal of Expired AFFF Concentrate Containing the

PMN

basis: Disposal of Expired AFFF Concentrate Containing

the PMN basis: User-Defined Loss Rate Model. Accounting

for container cleaning, LF = 1- 0.03 = 0.97. CEB assumes

release to landfill or incineration.

RELEASE TOTAL

2.4E+3 kg/yr - all sites

C6F13 is 21.8% in PMN. // Perfluoro to WATER or AIR or

INCINERATION or LAND from container cleaning to uncertain:

 0.011 kg/site-day over 1 day/yr for 1,410 sites or 16

kg/yr. // Perfluoro to INCINERATION or LAND from

discharge, to: incineration or land : 0.36 kg/site-day

over 1 day/yr for 1,410 sites or 508 kg/yr.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 2,721

Basis: CEB assesses the std default minimum of 3

workers/site.

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 1.20% concentration

High End: 2.1E+1 mg/day over 1 days/yr

Number of workers (all sites) with dermal exposure: 4,230

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT

2-Hand Dermal Contact with Liquids Model.

CBI: Yes
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MEMORANDUM of CBI TELEPHONE CONVERSATION

CALL BY: Ariel Hou

Organization: ERG for CEB

CALL TO: Thomas J. Martin

Organization: Chemguard, Inc.

Date: 08/03/2011

Time: 12:00pm

Phone: 817-473-1036

Concerning what TSCA CBI?

PMN: 11-0530

The following contact report applies to P11-0527 - 0530

and 0532. Submitter called back at 2:30pm to answer

questions. Q1: Submission lists 10 sites. Does the

operation occur at all sites at once or just one of the

10 sites (similar to previous submission, P11-0483)?| A1:

Most of the processing will be done at Chemdesign. The

others are just possible manufacturing sites, but it's

unlikely that we will manufacture there. | | Q2: What

happens to the storage drums? Is the drum cleaned on a

regular basis? A2: We typically have dedicated drums or

totes and they are re-used each time as needed. At end of

useful life, there is a contractor that conditions and

disposes of the drum.