Environmental Release of Duomeen 218i to Surface Waters during Manufacturing, Transport, 

Packaging, and Waste Effluent Treatment

Background

The PMN substance, known as Duomeen 218i, is a long-chain hydrocarbon diamine (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 releases 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 bulk 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 product 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 cleaning. 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 Waters

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, and 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 not 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 

the 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 process 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 include 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 PMN 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 processes.

- 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 starting 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 the 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 would 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 dilution 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 washing 
occurs 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 timeaverage 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 material or as a result of drumming and washout of the tank cars following 

dispensing and drumming of the PMN material.