INITIAL REVIEW ENGINEERING REPORT : No
PMN: 13

- 0107 Standard Review Draft 12/17/2012

ENGINEER: Macek \ DDH PV (kg/yr): 500,000 Import Only YX

SUBMITTER: Trinity Manufacturing

USE: 100% for rubber flame retardant

MSDS: Yes Label: No

Gen Eqpt: Eng Controls: Under normal condi tions 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: Wear safety glasses with side

- shields. // Skin: Normal work clothing (long sleeved sh irts and long pants) is recommended. If liquid contact is likely to occur,

manufacturer recommends nitrile gloves (ex: N

- DEX Nitrile). Respirator: No personal respiratory protective equipment normally required. If dust is generated and engineering control s are not sufficient, wear NIOSH

approved particulate filtering facepiece (N95 or better). Health Effects: Prolonged contact of dust with eyes may cause slight irritation./ Prolonged or repeated inhalation of dust may cause slight
irritation of respiratory tract. Avoid breathing dusts of this product. / Small amounts (a tablespoonful) swallowed during normal handling operations are not likely to cause injury; swallowing amounts larger than that may cause injury.
TLV/PEL:
none established for the PMN

Dust 15 mg/m3 OSHA PELINITIAL REVIEW ENGINEERING REPORT : No
PMN: 13

- 0107

PROC/USE: Compounding of Rubber Products

Number of Sites/ Location: 4
unknown site Conover NC unknown site Atlanta GA unknown site Omaha NE unknown site Middlefield OH Days/yr: 300 Basis: Per submission and technical contact, the PMN is used at 98% in rubber product manufacturing at 4 customer sites, 300 d/yr and is present in rubber products at 10

- 15% (sheets or long rolls (conveyer belts, or under layment for artificial turf). ChemSTEER estimates daily throughput of the PMN chemical as 417 kg/site

- day.

Process Description: PMN (solid, 98%) unloaded from 25 kg bags

-- > mix with raw

rubber and other additives

-- > rubber product processing (PMN, 10

- 15% entrained
in solid )

--- > finishing rubber article (submission, technical contact and CRSS)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY

Water Suggested Estimate: 1.0E

- 1 kg/site

- day over 300 days/yr
from 4 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 ra nge 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 estimates that 50% of air emissions will settle and be ultimately

releas ed 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 Air or Incineration or Landfill Output 2: 2.1E+0 kg/site

- day over 300 days/yr from 4 si tes or 2.5E+3 kg/yr to: Uncertain, per GS from: Unloading Solid Raw Material from Transport Containers basis: EPA/OPPT Dust Emissions from Transferring Solids Model (revised July 2007) estimates 0.5% of the quantity transferred is released to water, incineration, land or air.

Water or Incineration or Landfill Conservative: 8.3E+0 kg/site

- day over 300 days/yr from 4 sites or 1.0E+4 kg/yr to: water, incineration, or landfill (ESD) from: Equipment Cleaning Losses of fro m 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, incinerati on, or landfill.

Water or LandfillSuggested Estimate: 1.0E+1 kg/site

- day over 300 days/yr from 4 sites or 1.3E+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 ass esses a 2.5% loss rate with releases to water or landfill

based on the ESD.

Air Suggested Estimate: 1.0E

- 1 kg/site

- day over 300 days/yr from 4 sites to: water or air (ESD, 2010 EU CSR) from: Fugitive Air Emission During Forming and Molding basis: User

- Def ined 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, injec tion 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: 4.6E

- 3 kg/site

- day over 300 days/yr from 4 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 Asse ssment 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: 4.5E

- 1 kg/site

- day over 300 days/yr from 4 sites or 5.4E+2 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 plasti c, or 0.11%.

Landfill Output 2: 4.2E+0 kg/site

- day over 300 days/yr from 4 sites or 5.0E+3 kg/yr to: RCRA Subtitle D Landfill, per submission from: Cleaning Solid/ Powder Residuals from Containers Used to Transport the Raw
Material basis: EPA/OPPT Solid R esiduals in Transport Containers Model, CEB standard 1%
residual. Submission states 0.2 kg/day in empty bags will be sent to RCRA
Subtitle D Landfill.RELEASE TOTAL 3.1E+4 kg/yr

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers expos ed via assessed routes: 192 Basis: The submission estimates 2 workers/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 m g/day over 250 days/yr OSHA PEL: 1.5E+1 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 96 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 person al 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 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). Per CEB 2004 GS on Plastic Converting, assumed 50% of workers potentially exposed during converting and trimming processes.

Exposure to Particulate (Class I) Upper Bound: 1.5E+2 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: 48 Basis: Unloading Solid Raw Material from Transport Containers; OSHA PNOR PEL

Limiting Model. Per CEB 2004 GS on Plastics Converting, assumed 25% of workers potentially exposed during unloading/cha rging activities.

Dermal:

Exposure to Liquid at 7.50% concentration High End: 1.3E+2 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 48 Basis: Equipment Cleaning Losses of from Multiple Vessels; EPA/OPPT 2

- Hand
Dermal Contac t with Liquids Model. Per guidance in CEB GS on Plastics Converting, assumed potential exposure to 25% of the workers du r ing equipment cleaning. Dermal exposure potential would be to liquids. The concentration of
the chemical of interest would be 50% of it's concentration in the resin. for
this PMN chemical this would be 7.5%.

Exposure to Solid at 98.00% concentration High End: 3.0E+3 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 48 Basis: Unloading Solid Raw Material from Transport Containers; EPA/OPPT Direct

2

- Hand Dermal Contact with Solids Model.: No

MEMORANDUM of TELEPHONE CONVERSATION

CALL BY: Daryl Hudson Organization: ERG for EPA/OPPT/CEB

CALL TO: Jim MacNeil

Organization: Trinity Manufacturing, Inc.

Date: 12/05/2012

Time: 9:00 AM

Phone: 910

- 331

- 4733

Concerning what TSCA ?

PMN: 13

- 0107

Mr. MacNeil and I discussed both P13

- 0107 and P13

- 0109. The answers below apply to both cases except where noted.

Q1:For P13

- 01 07

- what size are the imported bags? A1: 25 kg.

Q2: Please confirm the number of customers for P13

- 0107 as one place states 1 site, another states 4 sites and provides locations.
A2: 4 customer sites.

Q3: Will the customers make the final finished rub ber article? What kinds of rubber articles are produced?

A3: For P13

- 0107 (imported solid), the customers are extruding more rigid rubber products (conveyer belts and under layment for artific i al turf). For the liquid

PMN (P1 3

- 0109), customers are looking for more flexible products (no specific products provided). Customers using both PMNs will do PROC and make final products at their facilities.

Q4: Please elaborate on the Extreme Pressure Additive in Lubricants use for P13

- 0109.

A4: It's metalworking fluid, but not in the way most people think of MWF. The application is for drawing and stamping. Only a small amount of lubricant is

used and must adhere to the work piece over an extended period of time while the part is for med. Example: stamping an automobile bumper from a piece of metal

takes several stamping steps. The lubricant must adhere and stay on the part throughout the entire process. Therefore, dragout losses would not be as typically stated in the Use of MWF GS. The loss on the product would be approximately 2%.

The following questions all pertain to P13

- 0109:

Q5: Will there be cleaning at the end of the campaign?A5: No cleanouts are anticipated. Dedicated reactor and it can be drained to virtually emp ty. Any residual would be incorporated into the next batch. If an emergency happens and clean out is needed, the wastes would be collected in a tote and sent to a TSDF or equivalent facility.

Q6: Please confirm whether the PMN will be loaded into totes o r tank trucks as the submission provides for both.

A6: 100% tank trucks.

Q7: Will empty tank trucks be cleaned and what would be the frequency of cleaning?

A7: No cleanings will occur. Trinity has an agreement with the tanker truck company for dedicated use of the trucks.

Q8: The submission states no releases at your customer (MWF formulation) sites.
Will there be no equipment cleaning? A8: Trinity does not know know what equipment cleaning frequency would occur (if any) at customer sites. Because th is chemical will be used in straight oil formulations (not water

- based), cleanings would be sent for incineration to burn
the base oil.