INITIAL REVIEW ENGINEERING 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%)

percent 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 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 for the PMN
INITIAL REVIEW ENGINEERING 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 Cleaning 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 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 50 days/yr from 1 site or 3.6E+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 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: Loading 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 formulation 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: 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 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 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

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 Residual 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 used 

in straight oil fluids, cleaning would not use water and wastes would be 

incinerated to burn the base oil. Due to uncertainty at multiple downstream 
sites, CEB assesses releases to incineration using the standard model loss 

fraction assuming cleaning once 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 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: 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. 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 --> 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. 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. 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 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. NOTE 

- although the ESD estimate is provided (uncertain media), discussion with 

technical contact for the Formulation 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 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

Incineration

GS Estimate: 1.2E+1 kg/site-day over 247 days/yr from 29 sites

or 8.8E+4 kg/yr

Tech. Contact 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 occurring 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 estimates 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 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 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 conservative, 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 workers (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 operations.
INITIAL REVIEW ENGINEERING 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 Converting. 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 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: 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-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: 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 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: 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 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: 1.6E-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 between 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 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: 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% 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

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.

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:

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.
: 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 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.