Environmental Release of Duomeen 2 18i to Surface Waters during M anufacturing, Transport, Packaging, and Waste Effluent Treatment

Background The PMN substance, known as Duomeen 218i , is a long

- chain hydrocarbon d iamine (CAS No. 1581757

- 23

- 4 ). The IUPAC name is 1, 3

- propanediamine, N1, N1

- diisooctadecyl

- . Akzo Nobel manufactures the PMN substance at a single site, at which environmental release s of the PMN substance are anticipated to be minimal. It is anticipated that the majority of the PMN substance released during manufacture occurs during cleaning of reactors; any waste material will be collected and disposed of in the FDCC where it is destroyed by thermal oxidation . When produced, the PMN substance from this operation is loaded into bulk tank cars and shipped to a third party toll company, A&R Transport for drumming. The A&R drumming facility is located at 8440 S. Tabler Road in Morris, Illinois , where the b ulk wagon is offloaded. It is our understanding that there is no waste material generated during the drumming process, and that all of the material that can be transferred is drummed. This includes a partial drum as the final output to make sure that all the PMN material that can be transferred by mechanical pump is removed from the lines to the extent possible. No material is introduced to a wastewater treatment system at the drumming facililty in Morris, Illinois.

Potential of Release to Surface Water Reactor Cleaning Typically, the PMN Chemical Substance will be made to order and the equipment utilized will not be cleaned out after each batch. The equipment is not cleaned if similar products are made in the same reactor following the production of the PMN substance. The only time that clean out would occur is when a completely different pro duct is made in the same rector following the production of the PMN Substance. It is estimated that the equipment cleaned is no more than 6 times per year and no more than 32 kg of the PMN chemical substance is released as a result of each cleani ng. The released material is disposed of in the FDCC where it is destroyed by thermal oxidation. The nickel in the Spent Catalyst is recovered by calcining where the PMN Substance is destroyed.

Potential of Release to Surface Water s The emptied tank wagons are then moved to another A&R facility at 2223 Empress Road in Joliet, Illinois (60436) , where the wagons are washed out. It is estimated that a maximum of 5 gallons of PMN material is produced during washout of each tank wagon, a nd is often less than this volume. Typically on days on which washout occurs, an average of 1 to 2 wagons would be washed out, with a maximum of 3 bulk wagons being washed out. The receipt of bulk wagons by A&R would be staggered, and most workdays would n ot see washouts of the PMN substance occurring. Washout of the PMN substance at the A&R site is anticipated to occur only 13 days per year. This equates to a mass of PMN substance released of 64 kg per batch. The washout wastewater is treated on

- site at th e A&R facility in a sedimentation tank where any solid material is collected and disposed of properly. Because the PMN material is insoluble in water, it is anticipated that the majority of it would be removed by this process. The effluent from this proces s is then introduced into a sanitary sewer system, whereby it flows to one of the 3 Publicly

- Owned

- Treatment

- Works (POTWs) in Joliet, Illinois for further treatment. The following summarizes aspects that were used to develop estimates of concentrations of the PMN substance in the plume as discharged from the relevant POTW in Joliet, Illinois.

- The East Side POTW, which receives tank washings from A&R’s on

- site treatment facility, has a maximum design capacity of 45.5 million gallons per day (MGD) at maximum flow. The average flow at the East Side POTW since 2001 has ranged from 11.9 MGD to 18.2 MGD.- The PMN substance will be removed at a greater than 75 percent extent in A&R’s flocculation

and sedimentation tank due to the low water solubility of the PMN substance.

- CAS tests indicate that the PMN substance is almost completely removed from wastewater by conventional biological wastewater treatment plants. Based on the physical and chemical properties of the PMN substance, it is anticipated that the conventional treatment processes employed at the WWTP in Joliet, IL will remove most of the remaining PMN substance from the
water.

- The processes at the East Side POTW in Joliet, Illinois includ e screening and grit removal, primary clarification, aeration, and final clarification. The use of biological treatment and the use of flocculants in the clarification steps are anticipated to result in removal of greater than 90 percent of the remaining P MN substance at each step. Thus the total removal as a result of treatment at the POTW is greater than 95 percent based on structures similar to the PMN substance and available physical

- chemical and fate data on the PMN material, as a result of these proce sses.

- The fraction of PMN material remaining in the outflow of the East Side POTW (based on treatment processes at the A&R washout facility and at the East Side POTW) would then be: (1

- 0.75) x (1

- 0.95) = (0.25 x 0.05) = 0.0125, or 1.25 percent of the st arting amount from washout.

- A maximum of 3 tank cars washed out at the A&R facility would result in a total of 15 gallons of PMN material being released into the sedimentation tank at the A&R facility in Joliet, Illinois

. Thus, a total volume washed out in metric units is: (15 gal) x (3.7854 liters/gal) x (1000 cm3/liter) = 56,781 cm3. Multiplying by the density of 0.8 g/cm3, this gives a total mass delivered to the

on

- site A&R treatment facility during a worst

- case washout day at A&R (Morris, Illinois) of 45,425 g of PMN material.

- Considering the total removal factor ( A&R on

- site treatment and East Side POTW combined) of over 95 percent, the amount of PMN material being discharged at the outfall from the POTW in

a 24

- hour period is: (0.0125) x (45,425 g) = 568 g

- Diluting this mass into the lowest average daily flow rate for the East Side POTW, we obtain the highest 24

- hour average concentration of PMN material in the plume entering the receiving water body at th e POTW outfall location. (568 g PMN) x [(1/11,900,000 gal/day) x (1/3.7854 liter/gal)] x (1000 mg/g) = 0.013 mg/l = 0.013 ppm

In addition, USGS monitoring reports an average flow rate of 2380 cubic feet per second for the Des Plaines River in Joliet, IL

. The dilution factor contributed by the volume of the receiving river would render the already low concentration of PMN substance in the POTW effluent to nearly zero.

Conclusions Aquatic biota in the waters receiving discharges from the East Side POTW wou ld experience concentrations in the plume no greater than 0.013 ppm, under this worst

- case washout scenario. The 96

- hour LC50 for Zebrafish is 0.1 mg/l for the PMN substance. Thus, the anticipated worst

- case levels in the discharge plume (not considering d ilution in surface water) would be 8

- fold less than the available ecological benchmark for a structurally

- similar surrogate chemical. Because the PMN material is infrequently produced at only one facility, and because days on which tank car washingoccurs are highly staggered, the anticipated level in the plume could be time

- averaged across 3 days,

2 of which would involve no discharge of the PMN substance. The resulting 96

- hour average level of the PMN substance in the plume would be (0.013 ppm)/3 = 0.0043 ppm. Thus, the 96

- hour time

average level of the PMN substance in the discharge would be approximately 23

- fold less than the 96

- hour Zebrafish LC50 of 0.1 mg/l. Thus, no adverse ecological effects are anticipated as a result of production of the PMN mater ial or as a result of drumming and washout of the tank cars following dispensing and drumming of the PMN material.