INITIAL REVIEW ENGINEERING REPORT PMN: 14

- 0502 Manufacturing

Ethox Chemicals, LLC Greenville SC 29605 Number of Sites/ Location: 1

Days/yr: 6
Basis: Submitter specified 1 site, 19,000 kg/st

- bt, 72 hr/bt, and 2 bt/yr. CEB assumes 100% PMN in final product. Due to a mass balance discrepancy, CEB assumes 1 site, 2 batches, and 100% PMN in product. This presents conservative environmental release estimates. ChemSTEER calculates 140,000 kg PMN/st

- bt and 6 days/yr.

Process Description: Raw materials (including P14

- 0501 and potassium hydroxide)

-- > Reactor (PMN formed)

-- > Sampling

-- > Drum PMN (liquid, 100%) into totes or drums using an electric pump (per submission)

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.

Incineration Central Tendency: 9.8E+1 kg/site

- day over 2 days/yr from 1 site or 2.0E+2 kg/site

- yr from 1 site or 2.0E+2 kg/yr

- all sites to: incineration from: Equipment Cleaning Losses of Liquids from a Single, Large Vessel
basis: Submitter discussion / amendment that the facility will collect and incinerate the 2 day reactor cleaning losses. EPA/OPPT Single Vessel Residual Model, CEB standard 1% residual. Submitter estimates 114 kg PMN/bt (~0.6% LF based on batch size specified) as well as close to the LF for a gravity and pumped tank. released to POTW (on

- site biological treatment) from cleaning of the reaction vessel. Note, within the process description, this release is estimated as 95 kg (~0.5% LF) whereas in the release estimates it is estimated as 114 kg (~0.6% LF).

RELEASE TOTAL 2.0E+2 kg/yr

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 0 Basis:Inhalation: negligible (VP < 0.001 torr)

Dermal: Dermal not required, per SAT. Exposure based assessment, but health testing was not desired.INITIAL REVIEW ENGINEERING REPORT PMN: 14

- 0502 Use: Oil Fracturing

unknown site(s) Number of Sites/ Location: 1

Days/yr: 350

Basis: Submitter does not provide information on the end use. The 2011 ESD on Chemicals Used in Oil Well Production estimates 350 operating days/yr and 1,460 kg oil/st

- bt. CEB assumes 100% PMN in raw material. ChemSTEER calculates 0.54 sites. To correct mass bala nce discrepancy, CEB assumes 1 site, 350 day/yr, and 100% PMN in raw material. ChemSTEER calculates a new batch size of 800 kg PMN/st

- bt.

Process Description: PMN unloaded (liquid, 100%)

-- > Storage tank

-- > Oil well

-- > Crude oil/water separator

-- > PMN i n oil layer transported to a refinery and destroyed, PMN in water phase re

- used, deepwell injected, or land dispersed (per ESD)

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.

Deepwell Injection High End: 2.4E+1 kg/site

- day over 350 days/yr from 1 site or 8.4E+3 kg/site

- yr from 1 site or 8.4E+3 kg/yr

- all sites to: Deep well injected (per submissions) from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material basis: Per submitter amendment on Jan 30, after use of the products the end user will rinse drums whcih contained these products and use this wash liquid in the fracking site; i.e., th e material will go into the fracking well.

RELEASE TOTAL 8.4E+3 kg/yr

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 0 Basis:Inhalation: negligible (VP < 0.001 torr)

Dermal: Dermal not required, per SAT. Exposure based assessment, but health testing was not desired.CALL BY: Rachel Corbett

CALL TO: John McKiernan Organization: Ethox Chemicals, LLC
Date: 04/30/2014
Time: 12:45 PM

PMN: 14

- 0502 Organization: ERG

Phone: 864

- 277

- 1620
Concerning what TSCA CBI? MEMORANDUM of CBI TELEPHONE CONVERSATION