INITIAL REVIEW ENGINEERING REPORT
PMN: 04-0319

ENGINEER: Jon \ DGR PV (kg/yr): 15,000,000 (Import only)

SUBMITTER: Transmare Houston Inc.

USE: Carrier for herbicides and pesticides (30%); paint (30%) and ink (20%) formulations; indoor heating oil (10%); solvent blend for cleaning (10%).

OTHER USES:

MSDS: Yes Label: No

Gen Eqpt: impervious gloves/chemical safety goggles & face shield/local exhaust ventilation Respirator: respiratory protection

Health Effects: flammable TLV/PEL: PMN (Mosspar M) 100 mg/m ; (MSDS)

CRSS (2/19/2004): Chemical Name: Distillates (Fischer-Tropsch), hydroisomerized middle, C10-13-branched alkane fraction S-H20: 0.001 g/L

VP: 0.48 torr

MW: 142.29 Phys State: NEAT: Liquid; MFG: NK, Import; PROC/FORM: NA; END USE: Destroyed as heating oil; Solution: added to pesticides, paint and ink formulations, and cleaning solvents

Consumer Use: No

SAT (2/20/2004): Related cases: IDENTICAL TO (INCOMPLETE) Migration to groundwater: Moderate PBT rating: P1B2T2 Health: 1-2 Dermal, Drinking Water, Inhalation, Other(Ingestion); XB: No testing desired Eco: 3 Water; XB: No testing desiredINITIAL REVIEW ENGINEERING REPORT
PMN: 04-0319

OCCUPATIONAL EXPOSURE RATING: 2-3

NOTES & KEY ASSUMPTIONS:

POLLUTION PREVENTION CONSIDERATIONS: The PMN material is a non-odorous substitute for kerosene. Its use will result in a significantly reduced exposure to aromatics, because this material does not contain the aromatics that kerosene does. Therefore, the overall risk to human health and the environment will be reduced.

EXPOSURE-BASED REVIEW: NoINITIAL REVIEW ENGINEERING REPORT
PMN: 04-0319

PROC 1: receive imported PMN from ships to storage tanks

Number of Sites: 1 Submitter site (Deer Park, TX 77536) Days/yr: 15 (past case ) Note: unloading from ship to storage tank expected to occur on less than 200 dpy

Basis: Submission estimates 200 days/yr for both unloading from ship to storage, and loading from storage to trucks or ships. Previously, in , 5 days/yr were estimated for the unloading from import ship. The PV for this PMN is 3 times greater than in , therefore 15 days/yr was assumed.

Process Description: 1,000 to 10,000 metric tons of PMN are imported by ship => PMN is pumped to storage tank facility (Max 3,500 metric tons/tank). (Submission)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

Water 1 kg/site-day over 12 days/yr from: releases to wastewater treatment plant. Submission estimates 0.1 kg/month after treatment (90% removal) to the Houston ship channel (TPDES 01731). Because PMN is a PMN is mixture of C10-C13 parafins, used the submitter estimates and not worst case estimates (see Incineration) - per (US EPA/CEB), water releases from oils/gases to water is not expected.

Air worst case: 26.045 kg/site-day over 15 days/yr typical: 26.045 kg/site-day over 15 days/yr from: Unloading Liquid Raw Material from Storage/Transport Vessels; Loading Liquid into Storage/Transport Vessels basis: EPA/OAQPS AP-42 Loading Model. Submission estimates 1 kg/day fugitive air releases.

Incineration <200,000 kg/yr 4,080.23 kg/site-day over 11 days/yr using CEB worst case
estimates from: Cleaning Liquid Residuals from Storage/Transport Vessels basis: EPA/OPPT Bulk Transport Residual Model; Submission estimates 50% of non-fugitive emissions are to waste water treatment plant (surface water), 50% to off-site energy recovery (incineration). Submission estimates 1 kg/month released to incineration. Landfill: not expected (submission)INITIAL REVIEW ENGINEERING REPORT
PMN: 04-0319

PROC 1 (continued):

OCCUPATIONAL EXPOSURES SUMMARY Tot. # of workers: <3 (CEB standard default, Submission estimates 1 worker) Days/yr: 15

INHALATION:

Exposure to Vapor (Class II) PEL: 1000 mg/day over 15 days/yr (based on PEL) Model: 110,266.7 mg/day over 15 days/yr (based on container volume) Number of workers (all sites) with inhalation exposure: <3 basis: Unloading Liquid from Storage/ Transport Containers; EPA/OPPT Mass Balance Model: large container size (1.4 million gal) makes model output very large. Note: The respirator class is: II. Gas/vapor (all substances in the gas form)

Inhalation Monitoring Data Review 1) Uncertainty (estimate based on model, regulatory limit, or data not specific to industry): YES 2)a) Exposure level > 1 mg/day? YES

OR b)Hazard rating for health of 2 or greater? NO Inhalation Monitoring data desired? YES (both criteria met)

DERMAL:

Exposure to Liquid at 100.00% concentration 1,764.00 mg/day over 15 days/yr Number of workers (all sites) with dermal exposure: <3 basis: Cleaning Liquid Residuals from Storage/ Transport Vessels; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.INITIAL REVIEW ENGINEERING REPORT
PMN: 04-0319

PROC 2: Transfer to Tank Trucks or Ships

Number of Sites: 1 Submitter site (Deer Park, TX 77536) Days/yr: 200 (Submission) Basis: Submission estimates continuous process, 200 days/yr and 75,000 kg/day.

Process Description: PMN (100%) is pumped from storage tank facility to trucks or ships (est. 1,200 gal). (Submission)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

Water 1 kg/site-day over 12 days/yr from: releases to wastewater treatment plant. Submission estimates 0.1 kg/month after treatment (90% removal) to the Houston ship channel (TPDES 01731). Because PMN is a PMN is mixture of C10-C13 parafins, used the submitter estimates and not worst case estimates (see Incineration) - per (US EPA/CEB), water releases from oils/gases to water is not expected.

Air 1.0 kg/site-day over 200 days/yr from: Loading Liquid Product into Tank Trucks basis: EPA/OAQPS AP-42 Loading Model estimates 0.358 kg/site-day typical and worst case. Submission estimates 1 kg/day fugitive
air releases.

Incineration <200,000 kg/yr 3497.34 kg/site-day over 4 days/yr using CEB worst case estimates from: Cleaning Liquid Residuals from Storage/Transport Vessels basis: EPA/OPPT Bulk Transport Residual Model; Submission estimates 50% of non-fugitive emissions are to waste water treatment plant (surface water), 50% to off-site energy recovery (incineration). Submission estimates 1 kg/month released to incineration.

Landfill: not expected (submission)INITIAL REVIEW ENGINEERING REPORT
PMN: 04-0319

PROC 2 (continued):

OCCUPATIONAL EXPOSURES SUMMARY Tot. # of workers: <3 (CEB standard default, Submission estimates 1 worker) Days/yr: 200

INHALATION:

Exposure to Vapor (Class II) worst case: 57.4943 mg/day over **4 days/yr** typical: 0.024 mg/day over **4 days/yr** Number of workers (all sites) with inhalation exposure: <3 basis: Cleaning Liquid Residuals from Storage/Transport Vessels; EPA/OPPT Mass Balance Model Note: The respirator class is: II. Gas/vapor (all substances in the gas form)

Exposure to Vapor (Class II) worst case: 19.5318 mg/day over **200 days/yr** typical: 2.17 mg/day over **200 days/yr** Number of workers (all sites) with inhalation exposure: <3 basis: Loading Liquid Product into Tank Trucks; EPA/OPPT Mass

Balance Model Note: The respirator class is: II. Gas/vapor (all substances in the gas form)

Inhalation Monitoring Data Review 2) Uncertainty (estimate based on model, regulatory limit, or data not specific to industry): YES 2)a) Exposure level > 1 mg/day? YES

OR b)Hazard rating for health of 2 or greater? NO Inhalation Monitoring data desired? YES (both criteria met)

DERMAL:

Exposure to Liquid at 100.00% concentration 1,764.00 mg/day over 15 days/yr Number of workers (all sites) with dermal exposure: <3 basis: Cleaning Liquid Residuals from Storage/ Transport Vessels (User-Defined); EPA/OPPT 2-Hand Dermal Contact with Liquids

Model.INITIAL REVIEW ENGINEERING REPORT
PMN: 04-0319

PROC 3: Formulation of Paints, Inks, Insecticide Carrier and Cleaning Solvent (90% of PV)

Number of Sites: 8 unknown formulating sites Days/yr: 235 Basis: Submission estimates 8 sites at 200 days/yr for formulation of paints, inks, insecticide carrier and solvent

uses.

Process Description: PMN is transported by trucks or ships => PMN unloaded to storage tanks (est. 5,000 gal) => PMN is transferred to mixing tanks (est. 500 gal) => PMN is mixed with other feedstocks to make formulation (30-50% PMN) => Formulation loaded into 5 gal cans or 55 gal drums. (Submission)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

**Water** 80 kg/site-day over 235 days/yr

**or Incineration or Landfill:** 180,000 kg/site-yr from: Cleaning Liquid Residuals from Tank Trucks Used to Transport the Raw Material (16 kg/site-day); Equipment Cleaning Losses of Liquids (80 kg/site-day) from a Single, Large Vessel basis: EPA/OPPT Bulk Transport Residual Model, CEB standard 0.2% residual.; EPA/OPPT Single Vessel Residual Model, CEB standard
1% residual. Because PMN is a PMN is mixture of C10-C13 parafins, did not use worst case water estimate for container cleaning - per (US EPA/CEB), water releases from oils/gases to water is not expected. Submission states steam cleaning of storage tanks approximately every 6 months. Once PMN is combined with other materials, resumed worst case water assessments.

Air worst case: 0.129 kg/site-day over 235 days/yr typical: 0.11 kg/site-day over 235 days/yr from: Cleaning Liquid Residuals from Tank Trucks Used to Transport the Raw Material; Equipment Cleaning Losses of Liquids from a Single, Large Vessel; Loading Liquid Product into Drums; Unloading Liquid Raw Material from Tank Trucks basis: EPA/OPPT Mass Transfer Coefficient Model.; EPA/OPPT Mass Transfer Coefficient Model.; EPA/OAQPS AP-42 Loading Model.; EPA/OAQPS AP-42 Loading Model.INITIAL REVIEW ENGINEERING REPORT
PMN: 04-0319

PROC 3 (continued):

OCCUPATIONAL EXPOSURES SUMMARY Tot. # of workers: <3 (CEB standard default, Submission estimates 1 worker) Days/yr: 235

INHALATION:

Exposure to Vapor (Class II) worst case: 548 mg/day over 235 days/yr typical: 18.3 mg/day over 235 days/yr Number of workers (all sites) with inhalation exposure: <3 basis: unloading Liquid Product from tank trucks; EPA/OPPT Mass

Balance Model Note: The respirator class is: II. Gas/vapor (all substances in the gas form)

Inhalation Monitoring Data Review 3) Uncertainty (estimate based on model, regulatory limit, or data not specific to industry): YES 2)a) Exposure level > 1 mg/day? YES

OR b)Hazard rating for health of 2 or greater? NO Inhalation Monitoring data desired? YES (both criteria met)

DERMAL:

Exposure to Liquid at 100.00% concentration 1,764.06 mg/day over 235 days/yr Number of workers (all sites) with dermal exposure: 3 basis: Cleaning Liquid Residuals from Tank Trucks Used to Transport the Raw Material; EPA/OPPT 2-Hand Dermal Contact with Liquids Model.INITIAL REVIEW ENGINEERING REPORT
PMN: 04-0319

USE 1: Component of Printing Inks at 30-40% formulation and 20% PV (3,000,000 kg/yr)

Number of Sites: <4,312 Days/yr: 250 (CEB standard default) Basis: Number of unknown user sites from Generic Scenario for Use of Printing Inks (1994): 3,000,000 kg/yr x 59,505 (sites in industry) / 30 to 40% PMN / 138E6 (PV of industry) = 3,234 to 4,312 sites)

Process Description: unload PMN (30-40% in ink formulation) from containers -> transfer to printing press -> rollers -> paper -> all volatile components evaporate from paper into the atmosphere (per generic scenario)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

WATER Not expected per generic scenario.

AIR <8 kg/site-day over 250 Days/yr from: evaporation basis: Per generic scenario, assume all solvent portion of the ink is released to the atmosphere. (3,000,000 kg/yr - cleaning and container residue losses 150,000 kg/yr) / 250 days/yr / 1,437 sites = 2.6 kg/site-day

INCINERATION OR LANDFILL: 150,000 kg/yr from: equipment cleaning and container residue basis: CEB std. est for entire process equipment cleaning is 2% and liquid container residue is 3% -> 3,000,000 kg/yr x 5% = 150,000 kg/yrINITIAL REVIEW ENGINEERING REPORT
PMN: 04-0319

USE 1 (continued):

OCCUPATIONAL EXPOSURES Summary Tot. # of workers: <25,900 (generic scenario: 5-6 per site) Days/yr: 250 (CEB standard default)

INHALATION

Exposures to vapor (Class II) Worst: <4,200 mg/day over 250 Days/yr Typical: 140 mg/day over 250 Days/yr basis: Generic scenario and open surface and transfer models vapor generation spreadsheet: 3 ft diameter open surface over 8

hours Number of workers with inhalation exposure: <25,900 Note: The respirator class is: II. Gas/vapor (all substances in the gas form)

Inhalation Monitoring Data Review 4) Uncertainty (estimate based on model, regulatory limit, or data not specific to industry): YES 2)a) Exposure level > 1 mg/day? YES

OR b)Hazard rating for health of 2 or greater? NO Inhalation Monitoring data desired? YES (both criteria met)

DERMAL:

Exposure to Liquid at 30-40% concentration 720 mg/day over 15 days/yr Number of workers (all sites) with dermal exposure: <25,900 basis: Incidental contact, 2 hands (transferring liquids, per generic scenario)INITIAL REVIEW ENGINEERING REPORT
PMN: 04-0319

USE 2: Cleaning solvent at 50% PMN, 10% of PV (1,500,000 kg/yr) Number of Sites: <200 unknown user sites (generic scenario) Days/yr: 345 (generic scenario for wet cleaning process in IC fabrication)

Process Description: (CEB assumption) unload PMN directly to treatment tank or in the case of use in aqueous process, transfer to dilution tank for dilution with water where it is diluted to 5% PMN (as in generic scenario for wet cleaning process in IC fabrication) => clean parts in bath => rinse parts (from Past case: )

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

WATER: Not expected, waste incinerated

INCINERATION OR LANDFILL: 1,500,000 kg/yr from: spent bath, container residue basis: Assume all of spent solvent is disposed.

AIR: worst case: 0.88 kg/site-day over 345 Days/year typical: 0.88 kg/site-day over 345 Days/year from: evaporation, open surface basis: Open surface model vapor generation spreadsheet. 3 feet open surface over 24 hours - 0.8832 kg/dayINITIAL REVIEW ENGINEERING REPORT
PMN: 04-0319

USE 2 (continued)

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers: 600 (1 worker per shift, 3 shifts per generic scenario) Days/yr: 345 (generic scenario for wet cleaning process in IC fabrication)

INHALATION: Not expected, cleaning is all done in closed systems.

DERMAL: Exposure to Liquid at 50% concentration 882 mg/day over 345 days/yr Number of workers (all sites) with dermal exposure: 600 basis: EPA/OPPT 2-Hand Dermal Contact with Liquids Model.INITIAL REVIEW ENGINEERING REPORT
PMN: 04-0319

USE 3: Insecticide carrier at 40-50% PMN and 30% of PV (4,500,000 kg/yr)

Number of Sites: 12,932 Days/yr: 26 Basis: Generic scenario for agricultural pesticides and nonagricultural pesticides does not provide number of sites; from 1999 Statistical Abstract of the US there were a total of 1,912,000 farms in 1997 using a total of 817 million pounds of pesticide active ingredient = 194 kg active/farm; 4,500,000 kg PMN/yr / 0.4-0.5 PMN/conc. = 11,250,000 kg/yr concentrate x 0.223 active = 836,250 kg active/yr / 194 kg active/farm = 12,932 farms; CEB assumption that pesticide application takes place an average of once every two weeks; 194 kg active/site-yr / 26 day/yr = 7.5 kg active/site-day (past case P01-0170).

Process Description: Insecticide is unloaded from container (40- 50% PMN solvent carrier) => mixing => load application equipment => spray application (generic scenario)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

WATER: 0.54 kg/site-day over 26 Days/year from: equipment cleaning (generic scenario) and container residue basis: CEB std. est. for single vessel equipment cleaning is 1% and liquid container residue is 3%: 4,500,000 kg/yr / 12,932 sites / 26 days x 4% = 0.535 kg/site-day; past case P01-0170 assessed all to water however, since this PMN is volatile the majority of the release is expected to be air.

AIR: 12.85 kg/site-day over 26 Days/year from: evaporation after **LAND application**
basis: PMN is a volatile chemical used as a carrier for the insecticide. [4,500,000 - (4,500,000 x 4%) ] / 12932 sites / 26 days/yr = 12.85 kg/site-day

Incineration: not expectedINITIAL REVIEW ENGINEERING REPORT
PMN: 04-0319

USE 3: continued

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers: 38,796 (CEB std. est. 3/site consistent with past case ) Days/yr: 26

INHALATION: Exposure to mist (Class I) 0.11-0.14 mg/day over 26 Days/yr Number of workers with inhalation exposure: 38,796 basis: CEB Generic Scenario estimates 27 ug/m3 for a tractor driver using a boom sprayer; 0.027 mg/m3 x 1.25 m3/hr x 8 hr/day x 0.4-0.5 PMN/pest. = 0.108 to 0.135 mg/day Note: The respirator class is: I. Particulate (including solids or liquid droplets)

Inhalation Monitoring Data Review 1) Uncertainty (estimate based on model, regulatory limit, or data not specific to industry): NO 2)a) Exposure level > 1 mg/day? NO

OR b) Hazard rating for health of 2 or greater? NO Inhalation Monitoring data desired? NO

DERMAL:

Exposure to Liquid at 40-50% concentration: 4,400 mg/day over 26 days/yr basis: EPA/OPPT 2-Hand Dermal Immersion in Liquid Model.INITIAL REVIEW ENGINEERING REPORT
PMN: 04-0319

USE 4: Indoor heating oil at 100% PMN for 10% of PV (1,500,000 kg/yr)

Number of Sites: 100's unknown user sites (CEB assumption) Days/yr: 250 (CEB std est.)

Process Description: Unload PMN from tank truck (100% PMN) => transferred to storage tank => PMN sent to furnace/burner => PMN combusted (CEB assumption).

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY INCINERATION: 1,500,000 kg/yr over 250 days/yr from: Burner and container residue basis: PMN is used as heating oil. All PMN is burned.

Water / Landfill: not expected

Air: <23 kg/site-yr

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers: 100's (CEB std. est. <3/site) Days/yr: 250 (CEB std est.)

INHALATION: Exposure to vapors (Class II) Worst: 6.9 mg/day over 250 Days/yr Typical: 0.23 mg/day over 250 Days/yr Number of workers with inhalation exposure: 100's basis: Generic scenario and open surface and transfer models vapor generation spreadsheet: 2 inch diameter open surface over 1 hours for transferring liquid Note: The respirator class is: II. Gas/vapor (all substances in the gas form)

Inhalation Monitoring Data Review 5) Uncertainty (estimate based on model, regulatory limit, or data not specific to industry): YES 2)a) Exposure level > 1 mg/day? YES

OR b) Hazard rating for health of 2 or greater? NO Inhalation Monitoring data desired? YES

DERMAL: Exposure to liquid at 100% concentration: 1764.00 mg/day over 250 days/yr basis: EPA/OPPT 2-Hand Dermal Contact with Liquids Model. USE 5: Paints used at 30% PMN for 30% PV (4,500,000 kg/yr)INITIAL REVIEW ENGINEERING REPORT
PMN: 04-0319

(Referenced: Generic scenario for UV curable roll coating and Automotive Spray Painting)

Site/Location: 77 Days/yr: 250 (CEB std. est.) Basis: Generic Scenario for UV Curable Roll Coating: 4,500,000 kg/yr / 30% PMN / 784 kg paint used/day / 250 days/yr = 77 sites

Process Description: Paint formulation is unloaded from containers (30% PMN) => transferred to application equipment (rollers or spraying) => rolling or spraying application => cured onto substrate (CEB assumption)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

WATER: 11.7 kg/site-day over 250 Days/year from: equipment cleaning and container residue basis: CEB std. est. for entire process equipment cleaning is 2% and liquid container residue is 3% -> 4,500,000 kg/yr / 250 days/yr / 77 sites x 5% = 11.7 kg/site-day Note: Media of release is not certain, could be released to incineration, landfill, or water. Water is assessed as the worst
case estimate.

-ORINCINERATION -OR- LANDFILL: 225,000 kg/yr from: equipment cleaning and container residue basis: CEB std. est. for entire process equipment cleaning is 2% and liquid container residue is 3% -> 4,500,000 kg/yr x 5% = 225,000 kg/yr

AIR: 222 kg/site-day over 250 Days/year from: evaporation during curing or drying of paint basis: All PMN is evaporated since the PMN chemical is volatile. (4,500,000 kg/yr - 225,000) / 250 days/yr / 77 sites = 222 kg/site-dayINITIAL REVIEW ENGINEERING REPORT
PMN: 04-0319

USE 5: continued

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers: 540 (generic scenario for UV curable roll coating, 7/site) Days/yr: 250 (CEB std. est.)

INHALATION:

Exposure to mist (Class III) Roll coating 0.14-0.91 mg/day over 250 Days/yr Spraying 53 mg/day over 250 Days/yr Number of workers with inhalation exposure: 540 basis: Generic scenarios for UV curable roll coating and Automotive spraying. Roll coating: 0.04 to 0.26 mg/m 3 x 1.25

m 3 /hr x 8 hrs/day x 0.35 PMN = 0.14 to 0.91 mg/day. Spraying: 15 mg/m 3 x 1.25 m 3 /hr x 8hr x 0.35 PMN = 52.5 mg/day Note: The respirator class is: III. Combination Gas/Vapor and Particulate (gas and liquid/solid physical forms are both present: a good example is paint spray mist, which contains both liquid droplets and vapor).

Inhalation Monitoring Data Review 1) Uncertainty (estimate based on model, regulatory limit, or data not specific to industry): YES 2)a) Exposure level > 1 mg/day? YES

OR b) Hazard rating for health of 2 or greater? NO Inhalation Monitoring data desired? YES

DERMAL:

Exposure to Liquid at 30% concentration: up to 3,000 mg/day over 250 days/yr Basis: EPA/OPPT 2-Hand Dermal Immersion in Liquids Model.INITIAL REVIEW ENGINEERING REPORT
PMN: 04-0319

CBI CONTACT REPORT (Telephone Log)

PMN: 04-0319

Call By: Dan Roper(ERG) for EPA/OPPT/CEB

Call To: Cynthia Bishop (Gardere) 214.99.4506

Submitter: Transmare Houston Inc.

Date: February 23, 2004

Time: 9:45 am

Submitter was contacted to confirm that P-04-319 is the same substance with the same uses as Previous contact report follows with notes in bold.