## Cover Letter

We are submitting this Premanufacture Notice (PMN) for a new source of a coal tar-based petroleum-like stream with many environmental benefits, on behalf of our client, Dakota Gasification Company (DGC). The substance consists of a complex mixture of aromatic hydrocarbons, many of which are known to reflect toxic properties. In addition, the estimated production volume for the substance is substantial, estimated at about 82 million kg/year. Potential risk to humans and the environment is negligible, however, due to minimal exposure to humans and releases to the environment based on DGC’s process. The process entirely avoids releases to water, land, and landfill in combination with DGC’s application of petroleum industry standards and compliance with U.S. Environmental Protection Agency (EPA) and Occupational Safety and Health Administration (OSHA) regulations covering similar substances and/or specific chemical components present in the PMN substance. DGC handles similar products with comparably high volumes on a routine basis following the same guidelines and regulatory requirements as described above. DGC’s corporate decision to operate the coal tar production process without releases to water, land, or landfill, however, goes beyond regulatory compliance and is a reflection of DGC’s commitment to the environment and public health. In addition, while risks are substantially, or in some areas entirely mitigated due to implementing standards and compliance with applicable regulations combined with DGC’s corporate and environmental commitment as noted above, there are substantial environmental benefits to be gained through this product. The substance at issue inthis PMN is normally sent for disposal, while the proposed use of the PMN substance is to produce a “petroleumlike” substance that to blend with normal petroleum to produce a commercial-scale petrochemical feedstock, thus reducing the need for imported oil and contributing to U.S. domestic oil sourcing and security. DGC believes that this ability to use brown coal, a domestically available resource, to produce a commercially valuable feedstock without special governmental incentives or subsidies and under conditions that avoid or mitigate environmental and health risks, provides strong environmental, economic, and oil security benefits that should be fully considered and valued as part of EPA’s evaluation of this PMN application. While conducting a “due diligence” on the adoption of the process to convert brown coal tar oil to a reusable substance, and as a further indication of its environmental commitment, DGC has enlisted the services of the Consortium of Environmental Risk Management (CERM) to carry-out a thorough hazard and risk assessment using the methods described by EPA in its Sustainable Futures (SF) program. We note that, considering the available information and understanding, CERM reached a conclusion that risks to humans and the environment are minimal based on lack of exposure to humans and releases to the environment resulting from the mitigating factors described above (full CERM SF report attached).

Page 1 SANITIZED SUBMISSION

### 0000288886 XPMN120124391362500 1PY84T

X
X X

X

X
Page 2 SANITIZED SUBMISSION

### X

Page 3 SANITIZED SUBMISSIONA.T. Funkhouser HSE Manager Dakota Gasification Company 420 County Road 26 Beulah ND 58523

Joseph E. Plamondon TSCA Contractor Bergeson & Campbell, P.C. 2200 Pennsylvania Avenue, N.W., Suite 100W Washington DC 20037 jplamondon@lawbc.com 520-572-3948



## X X X X

Page 4 SANITIZED SUBMISSION

## X

Tar, brown coal

101316-83-0 

## X 157882 00087729.PDF 

### Cx Hy Nz Ow Sv
See Attachment 013 (PMN Structure.pdf)

PMN Structure.pdf
Page 5 SANITIZED SUBMISSIONbrown coal

XXX

See attachment 

## X

00088913.PDF

00088086.PDF
Page 6 SANITIZED SUBMISSIONPage 7 SANITIZED SUBMISSIONPage 8 SANITIZED SUBMISSIONPage 9 SANITIZED SUBMISSION

### 82000000 82000000



## X

N/A Sold to off-site vendors for blending the existing tar oil with petroleum oil for feed to refineries 80 100 0 0 100 0
Sold to off-site vendors for feedstock to a hydrocracker process to make different cut of fuels to blend with other fuels 20 100 0 0 100 0

Page 10 SANITIZED SUBMISSION

## X

84200 2 974 

## 1

XXX 

## X Dakota Gasification Company 420 County Road 26 Beulah ND 58523

Page 11 SANITIZED SUBMISSIONPage 12 SANITIZED SUBMISSIONRailcar loading chemical gloves, safety glasses, face shield, chemical resistant jacket and pants liquid 100% 2 6 365
Tar oil sampling Chemical gloves, safety glasses, face shield. liquid 100% 1 0.5 365

Page 13 SANITIZED SUBMISSION1 88.5 Fugitive Air Tar oil storage with floating roofs. 95% control efficiency 4.4 kg/day
2 940.5 Stack Air See continuation page. id: <P9ASA3(5a)C1R2> 19 kg/day

Page 14 SANITIZED SUBMISSIONP9ASA3(5a)C1R2 Part II, Section A, B.(5a) Control Technology & Efficiency, Row 2

The tar oil vapors will be routed to the plant flare for combustion from the railcar loading system. 98% control efficiency. No releases to land, water, or landfill.

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### 4

See Attachment 004 (00088914.PDF)

00088914.PDF No releases to the land, water, or landfill. Minor air emissions detailed below. Please see 2 attachments for diagrams of downstream industrial users, operation steps, and release points.

Page 16 SANITIZED SUBMISSIONA 2 6 365 liquid and vapors; chemical gloves, safety glasses, face shield, chemical resistant jacket and pants 100 0.008

1 15 kg/day Stack air; vapor recovery or flare B 2 0.25 365 Vapors 100 0.002

2 3.5 kg/day Fugitive air; floating roofs C 2 4 183 Liquid and vapors; chemical gloves, safety glasses, face shield, chemical resistant jacket and pants 100 0.008

1 3.9 kg/day Stack air; vapor recovery or flare D 2 0.25 Vapors 100 0.002

2 0.9 kg/day Fugitive air; floating roofs

Page 17 SANITIZED SUBMISSIONAny risks involved with manufacture and use of the PMN substance are substantially or entirely mitigated due to the implementation of standards

and compliance with applicable regulations in combination with Dakota Gasification Company's (DGC) corporate and environmental commitment as noted above. Additionally, there are substantial environmental benefits to be gained through this product. Normally, the substance at issue in this PMN would be sent for disposal, while the proposed use of the PMN substance would be to produce a "petroleum-like" substance which could be blended with normal petroleum to produce a commercial-scale petrochemical feedstock, thus reducing the need for imported oil and thus contributing to U.S. domestic oil sourcing and security. DGC believes that this ability to use brown coal, a domestically available resource, to produce a commercially valuable feedstock without special governmental incentives or subsidies and under conditions which avoid or mitigate environmental and health risks provides strong environmental, economic, and oil security benefits which should be fully considered and valued as part of EPA's evaluation of this PMN application. The new recycling application for the PMN substance replaces burning it as a fuel.

Page 18 SANITIZED SUBMISSION001 CAS IES Report 00087729.PDF Pt.I, Sec.B, 1c. 1 002 Nature of Reaction 00088913.PDF Pt.I, Sec.B, 1e(2). 1 003 Range of Composition 00088086.PDF Pt.I, Sec.B, 1e(3). 4 004 Operation Description 00088914.PDF Pt.2, Sec.B, 1a. 1 005 Operation Description 00088915.PDF 1 006 Assessment Report 00088860.pdf 18 007 MSDS 00088142.PDF 10 008 Additional Information Regarding Human Expposure and Environmental Release 00088867.pdf 2 009 Interim Report on PMN Substance Analog in CHO HGPRT Forward Mutation Suspension 00088091.PDF 28 010 Interim Report on PMN Substance Analog in Ames Salmonella Reverse Mutation Assay 00088090.PDF 28 011 Interim Report on PMN Substance Analog in CHO Clonal Cytotoxicity Assay 00082828.PDF 22 012 Payment check 00089085.PDF 1 013 Structure PMN Structure.pdf Pt.I, Sec.B, 1e. 1

Page 19 SANITIZED SUBMISSION

## X Measured 1 psi Measured 38 1.01 - 1.03 Measured

99% Measured 20 xylene <0.001% Measured 20 4-15 Measured 90 Measured 760

95-110 deg F Measured

Page 20 SANITIZED SUBMISSION

## ATTACHMENT HEADER SHEET
Attachment Number 001 Attachment Name CAS IES Report 

## Associated PMN Section Number

Pt.I, Sec.B, 1c. Does not contain CBI 

## Report Number XPMN120124391362500

## ATTACHMENT HEADER SHEET
Attachment Number 002 Attachment Name Nature of Reaction 

## Associated PMN Section Number

Pt.I, Sec.B, 1e(2). Does not contain CBI 

## Report Number XPMN120124391362500

## ATTACHMENT HEADER SHEET
Attachment Number 003 Attachment Name Range of Composition 

## Associated PMN Section Number

Pt.I, Sec.B, 1e(3). Does not contain CBI 

## Report Number XPMN120124391362500

## ATTACHMENT HEADER SHEET
Attachment Number 004 Attachment Name Operation Description 

## Associated PMN Section Number

Pt.2, Sec.B, 1a. Does not contain CBI 

## Report Number XPMN120124391362500

## ATTACHMENT HEADER SHEET
Attachment Number 005 Attachment Name Operation Description 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number XPMN120124391362500

## ATTACHMENT HEADER SHEET
Attachment Number 006 Attachment Name Assessment Report 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number XPMN120124391362500

## ATTACHMENT HEADER SHEET
Attachment Number 007 Attachment Name MSDS 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number XPMN120124391362500

## ATTACHMENT HEADER SHEET
Attachment Number 008 Attachment Name Additional Information Regarding Human Expposure and Environmental Release



## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number XPMN120124391362500

## ATTACHMENT HEADER SHEET
Attachment Number 009 Attachment Name Interim Report on PMN Substance Analog in CHO HGPRT Forward Mutation Suspension Assay 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number XPMN120124391362500

## ATTACHMENT HEADER SHEET
Attachment Number 010 Attachment Name Interim Report on PMN Substance Analog in Ames Salmonella Reverse Mutation Assay



## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number XPMN120124391362500

## ATTACHMENT HEADER SHEET
Attachment Number 011 Attachment Name Interim Report on PMN Substance Analog in CHO Clonal Cytotoxicity Assay



## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number XPMN120124391362500

## ATTACHMENT HEADER SHEET
Attachment Number 012 Attachment Name Payment check 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number XPMN120124391362500

## ATTACHMENT HEADER SHEET
Attachment Number 013 Attachment Name Structure 

## Associated PMN Section Number

Pt.I, Sec.B, 1e. Does not contain CBI 

## Report Number XPMN120124391362500