Environmental Release of Duomeen 218i D uring Use at The Sole Product Formulation Site in Painesville, Ohio

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

- . AkzoNobel manufactures the PMN substance at a single site, at which environmental releases of the PMN substance are anticipated to be minimal. The PMN materials that are drummed at the A&R drumming facility at 8440 S. Tabler Road in Morris , Illinois will be shipped to the sole product formulator in Painesville, Ohio . All (100%) of the PMN mater ial drummed at the Morris, Illlinois facility will be used to formulate transmission fluid at the Lubrizol Painesville, Ohio formulation site. The PMN material will be further derivatized by Lubrizol to produce a friction modifier in automobile transmission fluid which will increase the fuel economy of the the vehicle

. Lubrizol will submit their own PMN but th e evaluation of environmental re leases at the formulation site is the subject of this report. This report addresses 3 potential sources of release: (1) cleaning residues from emptied drums that contained PMN material (drum re

- conditioning); (2) cleaning of vats, mixing vessels, other con tainers; and (3) miscellaneous incidental spills.

Description of the Formulating Process The PMN material will be charged from drums into a completely enclosed single

- batch reactor system containing other reactants at the formulator’s site. A typical ba tch size will be 15 to 20 metric tons. Two or more consecutive batches will be made to minimize product switching and the requisite cleaning of the reactor between runs. The actual number of batches per campaign will depend on a number of factors, includin g demand, inventory, and processing efficiency. Formulation of transmission fluid containing the PMN substance will occur between 30 and 50 days per year, or a little less than once per week. Solvents are used in the process, and the reactor is a completel y closed process. The reactor is heated to temperature while venting through a reflux condenser and ultimately to a high

- temperature flare. There would be no anticipated releases of the PMN substance for the vent stream, i t is a closed process vented to combustion devices. Present in the venting line is a vacuum stripping process to recover a portion of the material. Recovered distillate material is either reused in subsequent reactions, sent to an on

- site incinerator, recovered for fuel value, or sent to an approved off

- site management firm. The PMN material will be comp letely deriva tized in this process into another molecule for which Lubrizol will file a PMN

.Releases From Drum Reconditioning

After loading of the PMN substance into reactor vessel s for product formulation, the emptied PMN material drums will be sent to a drum reconditioner for cleaning, refurbishment and reuse. Typically, Lubrizol does not clean on

- site the drums in which the PMN material was received. The typical drum size is 450 lbs (202 kg). It is anticipated that a drum reconditioner would handle between 26 and 44 drums per day. The identity of the current drum reconditioner is DeWitt Barrels 1125 Comstock Street, Marne, Michigan

. Dewitt use a steam flush to clean the drums, the residue and condensate goes to a cement kiln as a tank wash where it is burned in their kiln. Measures are taken so that at no time the waste will end up in the water or be disposed of into surface waters.

Releases During Cleaning of Reactor Vessel at the Formulation Site It is not anticipated that any PMN substance would be present in waste material in the reactor following formulation of transmission fluid at the Painesville, Ohio facility. The PMN substance will be fully derivatized into a new molecule for which Lubrizol will file the PMN.

Releases At Formulator’s Site From Incidental Spills There may be a number of limited low level and diffuse intermittent or incidental releases of the PMN material to soil and air at the formulator’s site in Painesville, Ohio . Minor drips may occur during charging of raw materials into the reactor . These minor drips and minor spills will be cleaned up per standard procedures for on

- site waste management. Drips occurring during drumming of the formulated transmission fluid product will be cleaned u p and managed by on

- site waste management. Air emissions will be negligible as vent systems for these types of products usually discharge at high temperature to vapor incineration systems. Any emissions to air from minor ground

- level spills will be extreme ly limited due to the low vapor pressure of the PMN substances. Runoff from the formulation site to surface water or groundwater will be extremely limited by the anticipated small size of any spills, timely cleanup of minor drips and spills, and the use of good industry practices at the formulation site.