INITIAL REVIEW ENGI NEERING REPORT : No
PMN: 13

- 0109 Standard Review Draft 12/20/2012

ENGINEER: Macek \ DDH PV (kg/yr): 1,000,000 YX

SUBMITTER: Trinity Manufacturing

USE: 1) Eighty (80%) percent of the notification substances are used as a flame retardant/plasticizer in polymers. 2) Twenty (20%)

per cent of the notification substance is used as an extreme pressure lubricant in metal working fluids (MWFs).

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 pers onal 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: Con tact 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 for the PMNINITIAL REVIEW ENG INEERING REPORT : No
PMN: 13

- 0109

MFG: Batch Manufacturing of PMN

Number of Sites/ Location: 1 Trinity Manufacturing, Inc. Hamlet NC 28345

- 8821 Days/yr: 50 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 50 bt/yr based on submitted PV of 1,000,000 kg/yr.

Process Description: Alpha olefin feedstock 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

- - > 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 Cleanin g Losses of Liquids from Multiple Vessels basis: EPA/OPPT Multiple Process Vessel Residual Model, CEB standard 2%
residual. The submission and technical contact state that all equipment is
dedicated and cleaning is not performed. As conservative, CEB asses ses cleaning of equipment for 1 day/yr to address the possibility of equipment cleaning due to unfor e seen circumstances with releases to uncertain media.

Incineration Output 2: 7.2E+0 kg/site

- day over 50 days/yr from 1 site or 3.6E+2 kg/yr
to: off

- site in cineration (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/da y resulting in a release of 7.2 kg/site

- day.

Landfill Output 2: 3.0E+0 kg/site

- day over 50 days/yr from 1 site or 1.5E+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 9.1E+2 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 50 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 50 days/yr Number of workers (all sites) with dermal exposure: 6
Basis: L oading Liquid Product into Tank Trucks; EPA/OPPT 2

- Hand Dermal Contact with Liquids Model.INITIAL REVIEW ENGINEERING REPORT : No
PMN: 13

- 0109

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 for mulation sites, 120 exposure days/yr, PMN used as a liquid at 100% and formulated to 15%. CS calculates a use rate of 277.78 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: 6.7E+1 kg/site

- day over 1 day/yr from 6 sites or 4.0E+2 kg/yr
to: uncertain

from: Cl eaning 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 and technical contact state 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.

Air Output 2: 5.6E

- 2 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 emis sions 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 t his assessment.

Incineration Conservative: 5.6E+0 kg/site

- day over 120 days/yr from 6 sites or 4.0E+3 kg/yr to: Incineration per technical contact from: Equipment Cleaning Losses of Liquids from a Mixing Tank basis: EPA/OPPT Multiple Process Vessel Residu al Model, CEB standard 2%
residual. The submission does not address equipment cleaning at downstream
formulation sites. Technical contact states equipment cleaning at customers is not expected but submitter is uncertain. However, due to the PMN being use d in straight oil fluids, cleaning would not use water and wastes would be
incinerated to burn the base oil. Due to uncertainty at multiple downstreamsites, CEB assesses releases to incineration using the standard model loss fraction assuming cleaning on ce per day.

Incineration or Landfill Output 2: 5.6E+0 kg/site

- day over 120 days/yr from 6 sites or 4.0E+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 8.4E+3 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 (4 workers/site) exposed to PMN during unloading and l oading.

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 ENG INEERING REPORT : No
PMN: 13

- 0109

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

Number of Sites/ Location: 29
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: (200,000 kg/yr) / (12,000 gal/site

- yr x 1 kg /L x 3.785 L/gal x 0.15) = 29 sites. Environmental releases are of concern for this PMN. As conservative, CEB assumes 247 days/yr of operation and the ESD estimate of 29
sites to maximize kg/site

- day release. CEB also assumes no dilution as
conservative. C S 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

-- > 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 Technical Contact Est.: 5.4E

- 1 kg/site

- day over 247 days/yr from 29 sites GS Estimate: 2.9E+0 kg/site

- day over 247 days/yr from 29 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. indust ry 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 cl eaning: (1

- 0.03) x 0.11 =
0.1067. Releases are assessed to water via on

- site WWTP or POTW per submission

and ESD. Technical contact states that the type of use for this MWF is not typical (see contact report) and would not yield 11% loss during drag out. The loss from dragout (left on the part) would be closer to 2% and accounting for upstream losses from container cleaning: (1

- 0.03) x 0.02 = 0.0194. Both release estimates are provided.

Water or Incineration or Landfill High End: 9.4E

- 1 kg/site

- day over 221 days/yr from 29 sites or 6.0E+3 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 addres s end use. Due to uncertainty at multiple downstream sites, these

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

- although the ESD estimate is provided (uncertain media), discussion with
technical contact for the Formulati on step indicates it is unlikely the containers would be rinsed with water. Instead, the containers may either be
rinsed with base oil or not rinsed and disposed of via incineration.

Air Output 2: 1.3E+0 kg/site

- day over 247 days/yr from 29 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 us es 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

Incineration GS Estimate: 1.2E+1 kg/site

- day over 247 days/yr from 29 sites or 8.8E+4 kg/yr
Tech. C ontact Est.: 1.5E+1 kg/site

- day over 247 days/yr from 29 sites or 1.1E+5 kg/yr to: incineration (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 incineration (straight oils) with at least one bath changeout occu r ring per day at a facility with multiple baths in use. Account for upstream losses, the loss rate is calculated
as: (1

- 0.03) x (1

- 0.05

- (0.02 to 0.11)

- 0.38) = 0.4462 (using GS es timates for
upstream losses)

- 0.5335 (using Technical Contact estimates for upstream losses).

Incineration or Landfill Output 2: 9.6E+0 kg/site

- day over 247 days/yr from 29 sites or 6.9E+4 kg/yr to: incineration or landfill (ESD)
from: Filter Media and O ther 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 incineration or
landfill (straight oils). Accounting for upstream container cleaning losses: (1

- 0.03) x 0.36 = 0.3492.

RELEASE TOTAL 2.1E+5 kg/yr

- all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 1,392 Basis: The 2011 ESD for MWF Use estimates 48 workers/site.

CEB assesses 48 workers/site as co nservative, due to uncertainty at downstream
use sites.

Inhalation:

Exposure to Mist (non

- volatile) (Class I) Typical: 1.3E+0 mg/day over 247 days/yr High End of Range: 2.1E+0 mg/day over 247 days/yr Number of workers (all sites) with inhalation exposure : 1, 392 Basis: Exposure During Metalworking Operation; User

- defined Inhalation Model.

The 2011 ESD for MWF Operations estimates typical mist concentrations ranging from 0.87 to 1.42 mg/m3 for straight oils. 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 15% of the mist. (GS assumes that water conc. is 0% for straight oils and the PMN is then estimated to be 15/1 =
15% 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: 1,392 Basis: Unloading Liquid Raw Material from Drums; EPA/OPPT 2

- Hand Dermal Contact with Liquids Model.

Exposure to Mist at 15.00% concentration Output 1: 2.9E+3 mg/day over 247 days/yr
Number of worke rs (all sites) with dermal exposure: 1,392 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 ope r ations.INITIAL REVIEW ENG INEERING REPORT : No
PMN: 13

- 0109

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 ESD for Plastic Convertin g. CS calculates a use rate of 640 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: 1.6E

- 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 va rious 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 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: 6.4E

- 2 kg/site

- day over 250 days/yr from 5 sites or 8.0E+1 kg/yr to: water, incineration, or landfill (RM

- 2) from: Spillage During Raw Material Handling
basis: User

- D efined 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: 1.3E+1 kg/site

- day over 250 days/yr from 5 sites or 1.6E+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: 3.2E+2 kg/site

- day over 1 day/yr from 5 sites or 1.6E+3 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 f or 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: 1.6E+1 kg/site

- day over 250 days/yr from 5 sites or 2.0E+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 Conver ting 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: 1.6E

- 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 b etween 0.002 to 0.05% with engineering controls depending on the type of coversion 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: 7.0E

- 3 kg/site

- day over 250 days/yr from 5 sites to: air or landfill w/ 99% dust collect ion 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 collectio n 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: 7.0E

- 1 kg/site

- day over 250 days/yr from 5 sites or 8.7E+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% 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 3.9E+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.

Inhal ation:

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: Basis: Inhalation Exposure During Co n verting Process; User

- defined Inhalat ion

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 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.: 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

- 0109

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 artific i al turf). For the liquid

PMN (P13

- 0109), customers are looking fo r 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 flu id, 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 wo uld 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 incorpor ated 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 pro vides 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 submis sion 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.