INITIAL REVIEW ENGINEERING REPORT : No

PMN: 12-0539

CEB Staff Draft 10/2/2012

ENGINEER: Macek \ BCS

PV (kg/yr): 2,500,000 YX

SUBMITTER: Trinity Manufacturing

USE: 1) Extreme pressure additive for lubricants (20 %) 2) Flame retardant 

for rubber (80 %). 

MSDS: Yes Label: No

Gen Eqpt: Eng Controls: Under normal conditions of use, natural ventilation 

should effectively remove and prevent buildup of any vapor/mist/fume/dust 

generated from the handling of this product. // Eye/Face: If splashes are

likely to occur, wear safety glasses with side-shields or a face shield with 

safety glasses. // Skin: Normal work clothing (long sleeved shirts and long 

pants) is recommended. If splashes are likely to occur, use apron or impervious 

suit, such as a Tyvek coverall. If liquid contact is likely to occur, 

manufacturer recommends nitrile gloves (ex: N-DEX Nitrile). Respirator: No 

personal respiratory protective equipment normally required. If mist is 

generated (heating, spraying) and engineering controls are not sufficient,

wear NIOSH-approved organic vapor respirator with (R or P) particulate filter 

for oil mist. Health Effects: Contact with eyes may cause slight

irritation/Prolonged or repeated skin contact may result in mild irritation or 

redness/May cause slight irritation of respiratory tract. Avoid breathing 

vapors or mist of this product.

TLV/PEL:

none established
INITIAL REVIEW ENGINEERING REPORT : No

PMN: 12-0539

MFG: Batch Manufacturing of PMN

Number of Sites/ Location: 1

Trinity Manufacturing, Inc. Hamlet NC 28345-8821

Days/yr: 125

Basis: Per submission, 1 submitter site, 150 bt/yr, 24 hr/bt, 20,000 kg/bt, PMN 

produced as a liquid at 100%. CEB assumes PMN is produced as liquid at 100% to

conservatively assess exposures. CS calculates 125 bt/yr based on submitted PV 

of 2,500,000 kg/yr.

Process Description: Alkanes, C19-C28 charged to a reactor ---> chlorine gas in 

fed to reactor ---> byproduct gas is recovered and treated and produces waste

PMN stream, bleach and HCl product ---> reaction forms PMN (liquid, 100%) --> QC 

sampling ---> stabilizer added ---> transfer to storage ---> loading PMN product 

(liquid, 100%) into tank trucks (submission)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

Water or Incineration or Landfill

Conservative: 4.0E+2 kg/site-day over 1 day/yr from 1 site or 4.0E+2 kg/yr

to: uncertain

from: Equipment Cleaning Losses of Liquids from Multiple Vessels

basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% 

residual. The submission states that all equipment is dedicated and cleaning is 

not performed. As conservative, CEB assesses cleaning of equipment for 1

day/yr to address the possibility of equipment cleaning due to unforeseen 

circumstances with releases to uncertain media.

Incineration

Output 2: 7.2E+0 kg/site-day over 125 days/yr from 1 site or 9.0E+2 kg/yr

to: off-site incineration (submission)

from: Waste from Byproduct Gas Recovery

basis: User-Defined Loss Rate Model. The submission estimates 7.2 kg/bt of PMN

is released to off-site incineration from waste PMN produced during byproduct 

gas recovery. CS calculates 1 bt/day resulting in a release of 7.2 kg/site-day.

Landfill

Output 2: 3.0E+0 kg/site-day over 125 days/yr from 1 site

or 3.8E+2 kg/yr

to: RCRA Subtitle D landfill (submission)

from: Carbon Waste from HCl Carbon Treatment

basis: User-Defined Loss Rate Model. The submission estimates 3 kg/bt of PMN is 

released to a RCRA subtitle D landfill from waste carbon produced HCl carbon 

treatment. CS calculates 1 bt/day resulting in a release of 3 kg/site-day.

RELEASE TOTAL

1.7E+3 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 9

Basis: The submission estimates up to 3 workers/worker activity and identifies 3 

activities with a potential for exposure. As conservative, CEB assumes up to 9 

workers potentially exposed.
Inhalation:

Inhalation exposure is expected to be negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 100.00% concentration

High End: 8.8E+2 mg/day over 125 days/yr

Number of workers (all sites) with dermal exposure: 3

Basis: Sampling Liquid Product; EPA/OPPT 1-Hand Dermal Contact with Liquids 

Model.

Exposure to Liquid at 100.00% concentration

High End: 1.8E+3 mg/day over 125 days/yr

Number of workers (all sites) with dermal exposure: 6

Basis: Loading Liquid Product into Tank Trucks; EPA/OPPT 2-Hand Dermal Contact 

with Liquids Model.
INITIAL REVIEW ENGINEERING REPORT : No

PMN: 12-0539

PROC: Formulation of Metalworking Fluids (20% of PV)

Number of Sites/ Location: 6

unknown site Harvey IL

unknown site Cleveland OH

unknown site Mantua NJ

unknown site Crystal Lake IL

unknown site Perrysburg OH

unknown site Chicago IL

Days/yr: 120

Basis: Per submission, 6 MWF formulation sites, 120 exposure days/yr, PMN used 

as a liquid at 100% and formulated to 15%. CS calculates a use rate of 694.44

kg/site-day.

Process Description: PMN (liquid, 100%) is unloaded from tanks trucks ---> 

transfer to storage ---> feed into blending tank ---> packaging of metal working 

fluids containing PMN (liquid, 15%) (submission)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

Water or Incineration or Landfill

High End: 3.8E+1 kg/site-day over 1 day/yr from 6 sites

or 2.3E+2 kg/yr

to: uncertain

from: Cleaning Liquid Residuals from Tank Trucks Used to Transport the Raw 

Material

basis: EPA/OPPT Bulk Transport Residual Model, CEB standard 0.2% residual. The 

submission states that tank trucks are reused and are not cleaned between uses. 

To account for the possibility of tanks being removed from service, CEB assesses 

releases from container cleaning for 1 day/yr with releases to uncertain media.

Water or Incineration or Landfill

Conservative: 1.4E+1 kg/site-day over 120 days/yr from 6 sites or 10.0E+3 kg/yr

to: uncertain

from: Equipment Cleaning Losses of Liquids from a Mixing Tank

basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% 

residual. The submission does not address equipment cleaning at downstream 

formulation sites. Due to uncertainty at multiple downstream sites, CEB assesses

releases to uncertain media using the standard model loss fraction assuming 

cleaning once per day.

Air

Output 2: 1.4E-1 kg/site-day over 120 days/yr from 6 sites

to: fugitive air (2002 EU RA, 2010 Japan RA)

from: Fugitive Air Emissions

basis: User-Defined Loss Rate Model. Data from a 2002 EU RA for MCCP estimates 

16 kg/yr (16/83,332.8 = 0.02% for this operation) of MCCP may be released to air 

from fugitive air emissions generated by preheating and blending at a typical 

MWF formulation site A 2010 Japanese RA for SCCPs suggests 0.005% release to 

air during MWF formulation which calculates to a lower estimated release of 4.17 

kg/site-yr. The LF of 0.02% is used in this assessment.

Incineration or Landfill

Output 2: 1.4E+1 kg/site-day over 120 days/yr from 6 sites or 10.0E+3 kg/yr
to: incineration or landfill (2002 EU RA)

from: Off-Spec Material

basis: User-Defined Loss Rate Model. Data from a 2002 EU RA estimates a 1-2% 

loss rate from disposal of off-spec batches released to solid waste. Due to 

uncertainty at multiple downstream use sites, CEB includes this release

source using the high end estimate with releases to incineration or landfill.

RELEASE TOTAL

2.0E+4 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 24

Basis: The submission indicates 26 workers (~ 4 per site). CEB conservatively 

assesses all workers to PMN during unloading and loading.

Inhalation:

negligible (VP < 0.001 torr)

Dermal:

Exposure to Liquid at 100.00% concentration

High End: 1.8E+3 mg/day over 120 days/yr

Number of workers (all sites) with dermal exposure: 24

Basis: Unloading Liquid Raw Material from Tank Trucks; EPA/OPPT 2-Hand Dermal 

Contact with Liquids Model.

Exposure to Liquid at 15.00% concentration

High End: 2.6E+2 mg/day over 120 days/yr

Number of workers (all sites) with dermal exposure: 24

Basis: Loading Liquid Product into Drums; EPA/OPPT 2-Hand Dermal Contact with 

Liquids Model.
INITIAL REVIEW ENGINEERING REPORT : No

PMN: 12-0539

USE1: Use of Metalworking Fluids (20% of PV)

Number of Sites/ Location: 73

unknown sites

Days/yr: 247

Basis: The submission does not address the use of formulated MWFs containing the 

PMN. The lubricant products contain 15% PMN. The 2011 ESD for MWF Operations

estimates 247 days/yr of operation. Using the approach in the ESD, the number of 

sites is estimated as: (500,000 kg/yr) / (12,000 gal/site-yr x 1 kg/L x 3.785 

L/gal x 0.15) = 73 sites. CEB assumes 247 days/yr of operation and the ESD 

estimate of 73 sites to maximize kg/site-day release. CEB also assumes no 

dilution as conservative. CS calculates a use rate of 27.58 kg/site-day.

Process Description: Bulk MWF containing PMN (liquid, 15%) is unloaded from 

transport containers ---> transfer to mixing vessel ---> possible dilution of if 

water-based MWF ---> transfer to metal shaping trough ---> metal shaping 

operation ---> shaped metal part is rinsed and dried ---> spent MWF is drained 

and discarded (ESD)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

Water

Output 2: 2.9E+0 kg/site-day over 247 days/yr from 73 sites

to: on-site WWTP or POTW (ESD)

from: Dragout Losses

basis: User-Defined Loss Rate Model. The 2011 ESD for MWF Operations estimates a 

loss rate of 11% from dragout with releases to on-site WWTP or POTW. These data 

are based on U.S. industry data collected during the development of effluent 

guidelines for the metalworking industry. Due to uncertainty at multiple 

downstream sites, CEB assesses dragout releases using the ESD estimate of 11% 

and accounting for upstream losses from container cleaning: (1-0.03) x 0.11 = 

0.1067. Releases are assessed to water via on-site WWTP or POTW per submission 

and ESD.

Water or Incineration or Landfill

High End: 9.4E-1 kg/site-day over 219 days/yr from 73 sites or 1.5E+4 kg/yr

to: water, incineration, or landfill (ESD)

from: Cleaning Liquid Residuals from Drums Used to Transport the Raw Material

basis: EPA/OPPT Drum Residual Model, CEB standard 3% residual. The submission 

does not address end use. Due to uncertainty at multiple downstream sites, these 

releases are assessed to uncertain media using a 3% loss rate per the ESD.

Water or Incineration or Landfill

Output 2: 9.6E+0 kg/site-day over 247 days/yr from 73 sites or 1.7E+5 kg/yr

to: water, incineration, or landfill (ESD)

from: Filter Media and Other Recycling Waste

basis: User-Defined Loss Rate Model. The 2011 ESD for MWF Operations estimates 

these releases to account for a 36% loss rate with releases to water, 

incineration, or landfill (water-based fluids) or incineration or landfill

(straight-oil). Accounting for upstream container cleaning losses: (1-0.03) x 

0.36 = 0.3492. CEB assesses these releases to water, incineration, or landfill 

based on uncertainty at multiple downstream use sites.

Water or Incineration or Landfill
Output 2: 1.2E+1 kg/site-day over 247 days/yr from 73 sites or 2.2E+5 kg/yr

to: water, incineration, or landfill (ESD)

from: Spent Metalworking Fluid

basis: User-Defined Loss Rate Model. The 2011 ESD for MWF Operations also 

assesses 100% release with the spent MWF disposed to water (water-based fluids) 

or incineration or landfill (straight oil fluids) with at least one bath

changeout occurring per day at a facility with multiple baths in use. Based on 

uncertainty at multiple downstream use sites, CEB assesses the spent MWF to 

water, incineration, or landfill. Account for upstream losses, the loss rate is 

calculated as: (1-0.03) x (1-0.05-0.11-0.38) = 0.4462.

Air

Output 2: 1.3E+0 kg/site-day over 247 days/yr from 73 sites

to: air (2002 EU RA)

from: Misting/Evaporation

basis: User-Defined Loss Rate Model. A 2002 EU RA for MCCP estimates 

misting/evaporation losses to range from 2 to 5% depending on the type of MWF 

begin used. Based on uncertainty at multiple downstream sites, CEB uses the

most conservative estimate of 5% loss to air from misting/evaporation. Account 

for upstream losses from container cleaning: (1-0.03) x 0.05 = 0.0485

RELEASE TOTAL

4.9E+5 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 3,504

Basis: The 2011 ESD for MWF Use estimates 48 workers/site. CEB assesses 48 

workers/site as conservative, due to uncertainty at downstream use sites.

Inhalation:

Exposure to Mist (non-volatile) (Class I)

Typical: 1.5E+0 mg/day over 247 days/yr

High End of Range: 5.3E+0 mg/day over 247 days/yr

Number of workers (all sites) with inhalation exposure: 3,504

Basis: Exposure During Metalworking Operation;

User-defined Inhalation Model. The 2011 ESD for MWF Operations estimates typical 

mist concentrations ranging from 0.19 to 0.39 mg/m3 and high end concentrations

ranging from 0.87 to 1.42 mg/m3 depending on the type of MWF used. These 

estimates are based on the geometric mean (typical) and 90th percentile data 

(high end) of data collected by NIOSH from 942 machinists at 79 shops across

the U.S. A range of inhalation exposure estimates are based the high end for the 

range of geometric means and 90th percentiles. CEB assumes the PMN is 37.5% of 

the mist. (GS assumes that water conc. is 60% and the PMN is then estimated to 

be 15/40 = 37.5% of the mist.

Dermal:

Exposure to Liquid at 15.00% concentration

High End: 2.6E+2 mg/day over 247 days/yr

Number of workers (all sites) with dermal exposure: 3,504

Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2-Hand Dermal Contact 

with Liquids Model.

Exposure to Liquid at 15.00% concentration
Output 1: 2.9E+3 mg/day over 247 days/yr

Number of workers (all sites) with dermal exposure: 3,504

Basis: Exposure During Metalworking Operation; User-defined Dermal Model. The 

2011 ESD for MWF Operations estimates an average dermal surface loading

rate for MWFs of 2.9 mg/cm2-hr during metalworking operations. These data are 

more conservative than the EPA/OPPT 2-Hand Dermal Contact Model and are used to

provide a conservative estimate of dermal exposure during MWF use due to 

uncertainty at downstream operations.
INITIAL REVIEW ENGINEERING REPORT : No

PMN: 12-0539

USE2: Compounding of Rubber Products (80% of PV)

Number of Sites/ Location: 5

unknown site Mebane NC

unknown site Youngsville NC

unknown site Marysville OH

unknown site Calhoun GA

unknown site St. Mary's OH

Days/yr: 250

Basis: Per submission, the PMN is used at 100% in rubber product manufacturing 

at 5 customer sites and is present in rubber products at 10%. CEB assumes 250 

days/yr based on 2004 GS for Plastic Converting. CS calculates a use rate of 

1,600 kg/site-day.

Process Description: PMN (liquid, 100%) unloaded from tank trucks ---> mix with 

raw rubber---> rubber product processing (PMN, 10% entrained in solid ) ---> 

finishing rubber article (submission, CRSS)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

Water

Suggested Estimate: 4.0E-1 kg/site-day over 250 days/yr from 5 sites

to: water or air (ESD, 2010 EU CSR)

from: Fugitive Air Emission During Forming and Molding basis: User-Defined Loss 

Rate Model. Data from various literature sources suggests that fugitive air 

emissions generated during rubber converting can range between 0.002 to 0.05% 

with engineering controls depending on the type of conversion process (e.g. 

extrusion, injection molding, calendaring). The 2004 ESD for Plastics Converting 

estimates that 50% of air emissions will settle and be ultimately released to 

water while the other 50% remains in air. As conservative, CEB assesses

fugitive air emissions at a loss rate of 0.05% with 50% to water and 50% to air.

Water or Incineration or Landfill

Suggested Estimate: 1.6E-1 kg/site-day over 250 days/yr from 5 sites or 2.0E+2 

kg/yr

to: water, incineration, or landfill (RM-2)

from: Spillage During Raw Material Handling

basis: User-Defined Loss Rate Model. A 1992 RM-2 assessment for SCCPs estimated 

releases from spills to be 0.1% of the PV with 90% of releases going to 

incineration landfill and 10% going to water. A 2010 EU CSR assessment

on MCCPs estimated these releases to be 0.01% of PV with releases to water or 

solid waste. The 2010 EU CSR estimate is derived from more recent data sources 

and is therefore used as a basis to estimate releases from spillage.

Water or Incineration or Landfill

Conservative: 3.2E+1 kg/site-day over 250 days/yr from 5 sites or 4.0E+4 kg/yr

to: water, incineration, or landfill (ESD)

from: Equipment Cleaning Losses of from Multiple Vessels

basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2% 

residual. The 2004 ESD for Plastics Converting estimates releases from equipment 

cleaning using the EPA/OPPT model loss rate of 2% with releases to water, 

incineration, or landfill.

Water or Incineration or Landfill
High End: 3.8E+1 kg/site-day over 1 day/yr from 5 sites or 1.9E+2 kg/yr

to: uncertain

from: Cleaning Liquid Residuals from Tank Trucks Used to Transport the Raw 

Material

basis: EPA/OPPT Bulk Transport Residual Model, CEB standard 0.2% residual. The 

submission states that tank trucks are reused and are not cleaned between uses. 

To account for the possibility of containers being removed from service, CEB 

assesses releases from container cleaning for 1 day/yr with releases to 

uncertain media.

Water or Landfill

Suggested Estimate: 4.0E+1 kg/site-day over 250 days/yr from 5 sites or 5.0E+4 

kg/yr

to: water or landfill (ESD)

from: Scrap Material

basis: User-Defined Loss Rate Model. A 1992 RM-2 assessment for SCCPs estimated 

scrap from trimming to be 1% of the PV with 90% of releases going to landfill. 

The 2004 ESD for Plastics Converting estimated these releases to be 2.5% of PV 

with releases to water or landfill. This is based on the assumption that large 

pieces of scrap material will be disposed to landfill via solid waste and

dust generated during trimming will settle to the floor and be washed away to 

wastewater during cleaning. Due to multiple unknown downstream sites, CEB 

conservatively assesses a 2.5% loss rate with releases to water or landfill 

based on the ESD.

Air

Suggested Estimate: 4.0E-1 kg/site-day over 250 days/yr

from 5 sites

to: water or air (ESD, 2010 EU CSR)

from: Fugitive Air Emission During Forming and Molding

basis: User-Defined Loss Rate Model. Data from various literature sources 

suggests that fugitive air emissions generated during rubber converting can 

range between 0.002 to 0.05% with engineering controls depending on the

type of conversion process (e.g. extrusion, injection molding, calendaring). The 

2004 ESD for Plastics Converting estimates that 50% of air emissions will

settle and be ultimately released to water while the other 50% remains in air. 

As conservative, CEB assesses fugitive air emissions at a loss rate of 0.05% 

with 50% to water and 50% to air.

Air

Output 2: 1.8E-2 kg/site-day over 250 days/yr from 5 sites

to: air or landfill w/ 99% dust collection efficiency (RM-2)

from: Dust Generation During Trimming

basis: User-Defined Loss Rate Model. A 1992 RM-2 Assessment of SCCPs estimates a 

loss rate of 11g/kg of rubber produced with 1% of releases to air and 99% to

landfill based on a 99% dust collection efficiency. Based on a LCCP 

concentration of 10%, the loss rate for PMN during plastic converting is 11g/kg 

of plastic x 0.1 = 1.1 g/kg of plastic, or 0.11%.

Landfill

Output 2: 1.7E+0 kg/site-day over 250 days/yr from 5 sites or 2.2E+3 kg/yr

to: air or landfill w/ 99% dust collection efficiency (RM-2)

from: Dust Generation During Trimming

basis: User-Defined Loss Rate Model. A 1992 RM-2 Assessment of SCCPs estimates a 

loss rate of 11g/kg of rubber produced with 1% of releases to air and 99% to
landfill based on a 99% dust collection efficiency. Based on a LCCP 

concentration of 10%, the loss rate for PMN during plastic converting is 11g/kg 

of plastic x 0.1 = 1.1 g/kg of plastic, or 0.11%.

RELEASE TOTAL

9.4E+4 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY

Tot. # of workers exposed via assessed routes: 240

Basis: The submission estimates 1 worker/site. The 2004 ESD for Plastic 

Converting estimates up to 48 workers/site. CEB uses the ESD estimate as 

conservative.

Inhalation:

Exposure to Vapor (Class II)

2008 EU RA Data: 7.0E-1 mg/day over 250 days/yr

OSHA PEL: 1.5E+1 mg/day over 250 days/yr

Number of workers (all sites) with inhalation exposure: 240

Basis: Inhalation Exposure During Converting Process;

User-defined Inhalation Model. A 2008 EU RA on MCCPs and a 2010 EU CSR on MCCPs 

contains monitoring data from rubber manufacturing operations in the EU. The 

monitoring data suggest MCCP air concentrations ranging from 0.01 to 0.07 mg/m3 

based on monitoring conducted at 1 site. It is unknown whether these data 

represent area or personal monitoring data. Based on uncertainty in multiple

downstream use sites and the fact that these data are only based on 1 site, CEB 

assesses exposures based on the high end of the EU data range (0.07 mg/m3) and 

the OSHA PEL (15 mg/m3 x 0.1 = 1.5 mg/m3).

Dermal:

Exposure to Liquid at 100.00% concentration

High End: 1.8E+3 mg/day over 250 days/yr

Number of workers (all sites) with dermal exposure: 240

Basis: Unloading Liquid Raw Material from Tank Trucks; EPA/OPPT 2-Hand Dermal 

Contact with Liquids Model.