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 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: Wear safety

glasses with side-shields. // Skin: Normal work clothing (long sleeved shirts 

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 controls are not sufficient, wear NIOSHapproved 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 PEL
INITIAL 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 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 Air or Incineration or Landfill

Output 2: 2.1E+0 kg/site-day over 300 days/yr from 4 sites 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 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 Landfill
Suggested 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 assesses 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-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: 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 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: 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 plastic, 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 Residuals 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 exposed 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 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: 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 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). 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 PELLimiting Model. Per CEB 2004 GS on Plastics Converting, assumed 25% of workers

potentially exposed during unloading/charging 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 Contact with Liquids Model. Per guidance in CEB GS on Plastics 

Converting, assumed potential exposure to 25% of the workers during 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 P13-0107 - 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 rubber 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 artificial turf). For the liquid 

PMN (P13-0109), 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 formed. 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 empty. 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 or 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 this chemical will be used in straight oil 

formulations (not water-based), cleanings would be sent for incineration to burn 

the base oil.