INITIAL REVIEW ENGI NEERING 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 produ ct. // 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, spray ing) 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 mil d irritation or redness/May cause slight irritation of respiratory tract. Avoid breathing vapors or mist of this product.

TLV/PEL:
none establishedINITIAL 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

conservat ively 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 st ream, 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 Inc ineration 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 unfor e seen circumstances with releases to uncert ain 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 Subt itle 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 identif ies 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 F luids (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 formula tion 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 t ank

--- > 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: Cle aning 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 pos sibility 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 uncertain ty 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)

fr om: 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
Outpu t 2: 1.4E+1 kg/site

- day over 120 days/yr from 6 sites or 10.0E+3 kg/yrto: 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 batche s 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 ESTIMAT E 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:

Expo sure 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 L iquid 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 calcu lates 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 rel eases 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 es timate 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 day s/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 u se. 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 (wat er

- 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 uncertain t y at multiple downstream use sites.

Water or Incineration or LandfillOutput 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 a lso 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 occur r ing per day at a facility with multiple baths in use. Based on uncertainty at mult iple 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 e stimates 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 Li quid Raw Material from Drums; EPA/OPPT 2

- Hand Dermal Contact with Liquids Model.

Exposure to Liquid at 15.00% concentrationOutput 1: 2.9E+3 mg/day over 247 days/yr Number of workers (all sites) with dermal exposure: 3,504 Basis: Exposure During Metalwork ing 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 Mo del and are used to provide a conservative estimate of dermal exposure during MWF use due to uncertainty at downstream ope r ations.INITIAL REVIEW ENG INEERING 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 custo mer sites and is present in rubber products at 10%. CEB assumes 250 days/yr based on 2004 G S 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 E U 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 engineerin g controls depending on the type of co n version 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, incinera tion, 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 spil lage.

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 Ve ssel Residual Model, CEB standard 2%

r esidual. 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 LandfillHi gh 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
submissio n 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 wit h 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 sol id 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 ES D.

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 co n version process (e.g. extrusion, injection molding, calendaring). The
2004 ESD for Plastics Converting estimat es 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

- da y 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% tolandfill 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 Exposu re During Co n verting 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 bas e d on 1 site, CEB

assesses expos ures 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: 2 40 Basis: Unloading Liquid Raw Material from Tank Trucks; EPA/OPPT 2

- Hand Dermal Contact with Liquids Model.