FRAMOCHEM-ISOCHEM AT KAZINCBARCIKA HUNGARY SITE______________________________________________________________________

1/ PRODUCTION CAPACITIES :

ACYLCHLORIDES 7000 mtpa CHLOROFORMIATES 3000 mtpa CARBONATES 2500 mtpa

2/ TOTAL PRODUCTION IN 2008:

ACYLCHLORIDES 3650 mt CHLOROFORMIATES 1500mt CARBONATES 1300 mt

3/ TRADE IN 2008

At least 95 % of the total output volume was exported ; Framochem,s acylchlorides exports by countries between 2002 and 2005 Is given in the attached .doc file “02-05” ;Where does the trade information come from? Directly from Framochem or from the Eurostat trade statistics? If the latter are Acyl chlorides listed with a separate HTS number?

The trade information is extracted from Eurostat /with at least 80 % probabilityI would say these Hungarian exports under this HS codes are constituted by Framochem Acylchloride exports-between 02 and 05;the total sum of exported product is OK ;I can not imagine other Hungarian exporter under the given HS code-so I stronglyassume it must be Framochem-interestingly exports for 06as well as 07 let alone08 are not given by Hungary.

4/ ACYLCHLORIDES production capacity

TRAIN 1 : 15mtpday – 17 mtpday - for the phosgenation of C8,C9,C10 Carboxylic acids; TRAIN 2 : 1mtpday-3mtpday - for the phosgenation of C4,C5,C6,C7 Carboxylic acids ;

These acylchlorides are being produced as raw grade as well as distilled grade;

In which train would the production of crude oleic acid chloride of end January beginning of February have taken place?

TRAIN 1

5/Phosgene capacity: 12 000 mtpa : CO from Linde ,chlorine gas from Borsodchem ;

6/ Utilities from Borsodchem as well as other local companies ;

7/ Raw material integration: Raw materials are all imported mainly from Germany, Belgium, Netherlands, France and the UK ; /for spot as well as contract prices /Would these raw materials be the carboxylic acids (fatty and not)?

I am not sure,since the quantity of fatty carboxylic acids within the total import ofCarboxylic acid is max. 30mtpa-namely oleic acid after 2006..But in any case I am attaching a .pdf contg. the very recent Hungarian saturated carboxylic acids import s,which in turn are also in a relatively good agreement with the annual production volumes of Framochem,s acylchlorides ;note:these are imports of HS 291590/in 2002,20003 just right after the Grand ParoisseToulouse explosion there you see a marked increase in import of saturated carboxylicacids,excl. linoleic,palmitic,lauric ,oleic and stearic acids ;prior to 2005/2006I do not know how much fatty acids they were annually processing to acylchlorides. I do not speculate at all about historical fatty acid imports ,because there are over-lappings,that is to say more than one importer to the country.-anyway even historical fatty acid imports to Framochem might have been low,I would guess around max 100mtpa altogether because of the mentioned difficulties during the phosgenation process itself/which turned out to be unecomical-this piece of info is from today/ but also during the distillation process.

8/ Process technology : batch reactor phosgenation ;perhaps there are also present Some continues process elements ;

9/ FATTY ACID CHLORIDES :

There is no technical capability of producing DISTILLED fatty acid chlorides , Although some efforts were made in about 2005/2006 to produce palmitic acid,

Stearic acid ,oleyl acid chlorides ;on the other hand there have been produced some limited quantities of raw fatty acid chlorides in the past, but the company says it is not profitable to produce raw fatty acid chlorides because of the low selling price they can get for these products ; Generally speaking the company has no interest in producing fatty acid chlorides of whatever grade. / difficulties during synthesis as well as distillation/. Disengagement from fatty acid chlorides production in 2005/2006; If they really have disengaged from fatty acid chlorides production as they claim, how come they did produce 20 mT oleic acid chloride this year? Has there not been any fatty acid chlorides production at all in 2008?

This quantity of oleic acid chloride was raw oleic acid chloride and most likely very much an exception from that disengagement,I will come up with total fatty acid chlorides production for 2007 and 2008,although today the head of the procurement divison said there were no fatty acid imports at all for those years except oleic acid .Further “inquiry”shall conduct after my contact at the technology department will be available again. There are no available technical data sheets; there are no available material safety data sheets on fatty acid chlorides ; About 1000kg of raw stearic acid chloride/made via phosgenating a feed consisting of 95% of stearic acid and 5% of palmitic acid / is still on stocks ; Also about 20mt of oleic acid chloride was prepared in late January/early February this year immediately transported to customer; Is this crude oleic acid chloride? Any chance of finding out who the customer is or at least for which applications the oleic acid chloride was used? As mentioned earlier,this is RAW OLEIC ACID CHLORIDE .

10/ Some acylchlorides being produced are : /mtpa/

- valeroic acid chloride cca. 300mt- 400mt - 4-chlorobutyric acid chloride cca. 350mt - neodecanoic acid chloride cca. 1200mt; - isononanoic acid chloride cca. 1200mt, - acrylic acid chloride cca. 30mt; - 2-EH acid chloride cca. 80mt; -methacrylic acid chloride cca.60mt - n-octanoic acid chloride cca.25 mt - oleic acid chloride cca. 20mt - other cca. 350mt

Can you confirm that Framochem is the only production location within Isochem where acid chlorides (fatty and not) are manufactured? Yes,I can confirm this.

Isochem lists in the product list on their web page five fatty acid chlorides with the following remarks:Cocoyl chloride Please contact usLauroyl chloride AvailableOleoyl chloride Upon OrderPalmitoyl chloride Upon OrderStearoyl chloride Please contact us

If Framochem is the only acid chloride production location within Isochem then there should be lauroyl chloride available on stock.Although lauric acid chloride is listed in the product list,still I have the information,that there is no lauric acid chloride synthesis there.The head of the purchase department confirmed he has not bought lauric acid recently.

11/ Phosgenation catalyst:

Most likely guanidinium salt ;

12/ Price of the raw oleic acid chloride: at this point unknown Any chance of obtaining the information?

An open question,I am not too confident about getting this info.

In my answers there are some new infos I managed to extract from the head of the purchase department;as mentioned I shall get back to my contact in the synthesis division as soon as he well be available again. So to recap again: the use of fatty acids as raw material/exceptOleic acid/ is categorically denied independently by three sources :-the deputy director for synthesis and manufacture,- the head of the purchase department, - a chief technologist of the acylchlorides synthesis processes ;

! ! ! !

Best regards

Stefan