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 balance 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 in 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., the 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