BEST PRACTICE PROGRAMME

GUIDE 20

RUBBER COMPOUNDING IN THE

RUBBER PROCESSING INDUSTRY

September 1991

Prepared f o r the Department of the Environment's Energy

Efficiency Office by ETSU, Harwell, Oxon OX11 ORA.
 PREFACE

The compounding and mixing of rubber is one of the most energy

intensive operations in the rubber industry. In theory only a
small amount of energy is needed to form the various
interactions between the materials which are so vital to the
performance of rubber. However, in reality, very
considerable amounts of energy are needed to get the
ingredients into their right places in the mix.
This Energy Consumption Guide shows some of the variation in
electricity consumption for mixing across the industry. For
the first time it is possible for a company to see how its
mixing energy compares to others with similar operations and
mixes - and to consider how it can save both energy and money.
The British Rubber Manufacturers' Association congratulates
the Energy Efficiency Office on producing this Guide and
strongly recommends that all United Kingdom Rubber
Manufacturers examine it carefully in order to extract the
maximum financial benefit from the data and suggested actions.

Mr W R Pollock
Director
' British Rubber Manufacturers' Association
June 1991
 GUIDE SUMMARY

The rubber processing industry spent €80 million on energy in

1990, €11 million of which was spent on mixing and air
compression.
For this Guide, a postal questionnaire was used to gather
information on energy usage from the rubber compounding sector
of the rubber processing industry. The companies who
responded produce over 4 0 % of the rubber compounded in the UK.

The energy consumption per kg of rubber compound for the

companies surveyed varied between 0.25 kWhfkg and 3.25 kWh/kg:
even between companies making the same product there was
considerable variation in specific energy consumption (SEC).
Differences in plant type, mixing method and product mix
preclude the definition of ideal figures for specific energy
consumption across the sector. However, information is
provided which allows individual compounders to assess their
performance in comparison with other compounders having
similar outputs and operating characteristics. The survey
suggests that there is scope for a 10% saving in the next 1-2
years.
An action plan is presented showing opportunities for saving
energy in: material pre-heating, additions control, motor load
control, cooling, ram operation, extender oil use and dust
extraction.
 CONTENTS

section Page NO.

PREFACE

GUIDE SUMMARY

1. INTRODUCTION 1

2. PROCESS DESCRIPTION 2

3. ENERGY USAGE AND COST 5

4. THE SURVEY 8

5. OPPORTUNITIES FOR ENERGY SAVING 16

6. ACTION PLAN 18

7. FURTHER INFORMATION 21
 1. INTRODUCTION

This Energy Consumption Guide is aimed at those companies in

the rubber processing industry that mix rubber compounds for
their own use or for sale to other companies. The Guide is
limited to the following processes:
raw material transfer to the mixer;
mixingjdump mill operations.
Downstream processes are expected to be covered in further
publications.
The objectives of the survey were:
To provide companies with an up-to-date and
representative picture of energy usage per kg of
rubber compound; the specific energy consumption
(SEC). Also, because of the number of parameters
affecting the SEC, sufficient information is to be
provided to allow individual compounders to make
valid comparisons with SEC figures of other
compounders.
To review the different mixing methods and suggest a
practicably achievable minimum SEC.
To list a set of short, medium and long term payback
measures that will enable the industry to reduce
SEC'S without degrading the quality of their
product or the throughput of their process.

ETSU would like to thank the following for their help in

preparing this Energy Consumption Guide:
Mr D Sharps, Michelin Tyre plc;
Mr J Twentyman, Avon Tyre plc;
Mr K Davison, J H Fenner Ltd;
Dr R German, BRMA.

- 1 -
 2. PROCESS DESCRIPTION

Rubber compounding involves mixing materials to provide a

batch of rubber with consistent and specific properties. This
is achieved by using mixing and milling techniques with
processing variations which depend on the type of equipment
available and the product requirements. Support services
required are low pressure air, dust extraction, cooling water,
compressed air and raw material pre-heat; the last two being
more significant in energy terms.
Two process routes are shown in Fig 1, which cover most of the
systems found in the compounding sector. Raw materials are
weighed and transferred into the internal mixer. Carbon black
and fillers are dusty, so extraction is needed at the points
where these materials enter and leave the various handling
systems. Materials are either forced into the mixing chamber
by the effects of the mixer turning and by the action of a ram
operated by compressed air, or fed directly onto open mills
where mixing takes place. After internal mixing the compound
is transferred to the dump mill (some companies also employ
additional in-line mills). Both the internal mixer and mill
systems are cooled by water - usually from recirculating
cooling systems.
From the dump mill the compound is fed to other downstream
processes which are not considered in this Guide, eg extruders
or calenders. Some plants with sheeter mills are included
where electricity consumption cannot be separated from the
compounding process.
Raw Material Weighing, Transfer and Pre-heat
Methods available for weighing and transfer range from basic
systems where materials are manually weighed and fed into
mixers, to fully automatic systems. Automated systems can
incorporate pneumatic conveying of materials to weigh hoppers,
pneumatically operated valving on hoppers to provide raw
material selection and low pressure air fluidised conveying of
material to the mixers. Dust suppression systems form an
important part of all raw material handling plants. Dust
extraction and separation plant can often be the most energy
intensive part of this process.
Natural rubber pre-heating utilises either warm air or direct
steam heating to ensure that the material contains no crystal
formations. This is usually achieved through storage in rooms
which are maintained at about 35OC by convective type warm air
systems. Alternatively, retorts are used to contain the 5

blocks which are then heated by low pressure steam.

- 2 -
 - Typical multi-stage mixing process (Natural Rubber)

-
1 NR pre-heat
I
I
I
weigh
I 1
internal mixer for mas1.cal on

I
I dumo milildumo extruder I

I cool
I
II

1
I dum0 mill: sheetina 1
I
I cooler I

store

rL--
nlerna rn /I:secona stage

I
dump mill

blending mill: mixing 8. sheeting

I
Store
I
Typical single-stage mixing process

I raw materials weighing. leeding 8 curative addition

1
I
r inlernql mixer
I
I
I
dump mill
1
i for soft compounds
I curattves
I
I
[ blending mill

A
I cooler

Store

Fig 1 Process routes

- 3 -
Internal Mixers
Internal mixers depend upon several elements to provide good
compounding: speed, time, ram pressure, power input and
cooling. Having been weighed and delivered to the mixer, the
materials are pulled and pushed into the mixer by the action
of the rotor and ram respectively.
Mixing speed depends upon the type of rotor and the type of
compound processed. Ram pressure can be used as an aid in the
temperature control of the mix.
Operators aim to maximise work energy input to the compound
over the shortest time possible without overheating. The
mixture is cooled to limit the temperature rise whilst
maximising the work input by mixing.
Many compounders pre-masticate natural rubber in the mixer in
order to reduce its viscosity before compounding. To the
elastomer (natural rubber, SBR. EPDM, etc) vulcanizing agents
and accelerators, accelerator activators, retarders,
antioxidants, pigments, softeners and extenders, waxes,
blowing agents and chemical plasticisers are added. Of
these, the use of black as a reinforcing filler and oil as an
extender/process aid have a significant effect on energy
requirements in the mixing process.
Mills

.
*
Mills can be used for a variety of purposes:
as a dump mill receiving material from the
internal mixer and re-shaping it ready for further
processing;
as an open mixer, though specific energy consumption
is much higher than for an internal mixer;
for the addition of curatives to mixed compounds;
for warming compound to reduce viscosity and
increase workability prior to calendering or
extrusion.

Steam or hot water is used to pre-heat mill rolls before work

commences. During working time, the mill rolls are cooled,
both to control product temperature and to protect the rolls.

- 4 -
 3. ENERGY USAGE AND COST

Based on data from compounders responding to the survey

questionnaire, the distribution of energy use can be given for
individual sites. However, it is useful to set this energy
consumption and its cost in the context of some figures for
the rubber processing industry as a whole.
Fig 2 shows an approximate breakdown of current delivered
energy consumption and cost by fuel type.
Annual Consumption - 4.6 Million MWh
Annual Cost - f80 Million

Energy consumption and cost for mixing reflect mainly

electricity for mixing and air compression.
Annual Consumption - 287,000 MWh
Annual Cost - fll Million

LPG
1% Fuel Oli
22%

ANNUAL CONSUMPTION 4.6Million M W h (16.5 PJ)

Other Electricit

LPG 17%
1%

ANNUAL COST f 8 0 M
Basis: 4 t h Qtr. 1990 Drices from D.En.

Fig 2 UK Rubber processing industry: total delivered energy

- 5 -
Mixing Energy Breakdown
Fig 3 has been prepared from data in the questionnaire and
shows how the distribution of energy consumption varies
between a typical tyre and a typical general rubber goods
factory .
Comparison of operations between sites has been made on the
basis of electricity consumption only, since fuel energy
figures for polymer pre-heating were supplied by only two
respondents. The remaining text and figures are therefore
concerned with electricity alone.

(a) Typical large (b) Typical general rubber

tyre factory goods factory

Mixing Rubber pre-heat

~ Compressed air
*

Fig 3 Energy distributions in the mixing operation from 1991

survey results
- 6 -
Auxiliary Services
The energy consumption for natural rubber pre-heating and for
provision of compressed air, whilst representing a relatively
small part of the total energy consumed, is important because
there is usually a significant opportunity for saving in these
areas. This also applies to the electricity used in the
provision of cooling water for the mixers and mills, which
accounts for less than 1% of mixing energy requirements.
Energy used in transferring raw materials to the mixer is a
very small part of the overall energy consumption of the
compounding process and will not be considered further.

- 7 -
 4. THE SURVEY

A questionnaire was mailed to 73 companies in the rubber

processing industry in September 1990. To ensure that as many
companies responded as possible, telephone contact was made as
necessary over the following two months.
The response to the survey was good with over 50% of the
original questionnaires being returned. The respondents
account for the production of 228,000 tonnesjyear which
represents about 4 0 % of the total industry tonnage.
Questions were asked about quantity and type of product,
machine size and number, throughput rate, batch size and plant
loading, variations in operation (eg blending), details of
pre-heating level, cooling, means of control, annual energy
consumption and motor details. Finally, information was
requested about energy saving measures which had been
implemented, with a view to incorporating this experience into
a Good Practice Guide on rubber mixing.
Specific Energy Consumption
Fig 4 illustrates the distribution of SEC for those companies
responding to the survey. SEC’S range from less than 0 . 2 5
kwhjkg up to 3 . 2 5 kWhjkg.
Figs 5 and 6 show the specific electricity consumption as
kWh/kg output ranked firstly in ascending order and secondly
in sub-sector groupings to allow a broad comparision between
companies in particular product areas,
Clearly the range of specific electricity figures is large and
prediction of a single standard figure against which to
compare individual sites is impossible. The range of

.
variables upon which electricity consumption depends includes:

..
method of mixing (internal mixer or mill);
number of mixing stages;
machine size and type;

..
product mix in terms of compound material and
viscosity (including the percentage of NR and CR);

..
batch size and batch time;
control of power input;

..
proportion of master batching;
proportion of blendingjmixing on the two-roll mill;

..
control of ingredient addition;
amount of re-work;
percentage utilisation;

..
frequency of product change and machine
cleaningjwarming;
use of mills for compound heating;
internal mixer and mill cooling efficiency.
- 8 -
No of companies

14

12

10

0
0 - 0.251 0.501 0.751 1.001 1.251 1.501 3.001
0.25 - 0.5 - 0.75 - 1.00 - 1.25 - 1.50 - 1.75 - 3.25

Fig 4 Specific electricity consumption

frequency distribution

- 9 -
 kWh/Kg OF OUTPUT
2
1 3.25

~ . _ _ _ _ ~~.~
- ~ .. -. . . . ~.. ~ ~~ ~

1.5

. .~ . ~ ~ .. . . . . . .. .~.
1

.
0.5
~

0
2 8 10 30 2 8 14 13 2 3 2 7 2 1 1 2 2 4 3 2 9 10 12 18 8 11 0 18 6 2 5 2 2 4 7 8 2 0 16 17

COMPANY CODE

Fig 5 Specific electricity consumption

comparison between sites
kWh/Ka OF OUTPUT
2
3.251

1.5

0.5

Fig 6 Specific electricity consumption

comparison by industry sub-sectors
- 10 -
The amounts of each compound by type and viscosity €or all 30
responding companies has been charted in Fig 7. The chart
shows the impact of the four respondents out of the 30 who
manufacture mainly tyres from NR and SBR in the viscosity
range 50 to 80 IFUiD.

TONNES OF COMPOUND (Thousands)

40

35

30

25

20

15

10

5 HARDNESS
(IRHD)

-
60

80
06

0
NR SBR NBR EPDM HALOBUTYL CR MlSC

COMPOUND TYPE

Fig 7 Rubber tonnage by viscosity

(hardness-IRDH) compound type

- 11 -
 Minimum Maximum
Custom compounders 0.32 0.33
Moulding and other products 0.23 1.14
Belts and hoses 0.24 1.45
Tyres 0.37 0.80
Seals 0.20 1.62
Rollers 0.78 3.25

Fig 8 shows compounded rubber output vs. electricity

consumption for each of the 3 0 responding companies.
Table 2 lists the key factors responsible for the variation in
SEC figures and the relevant data for each of the responding
companies.
Using these two sets of data, a compounder can assess an SEC
figure for a particular output, to compare with actual SEC.
This will provide the compounder with a broad indication of
performance in his operation compared with that of the
companies who responded to the survey questionnaire.

.
- 12 -
 MWh/y
42000

. .
.
.
. ........
36000
I
i I

+___
I
l2O0O __. ._
I
Enlarged Below :

0 10000 20000 30000 40000 50000 60000

TONNES / Y

MWh/y
3000

2000
!

0
IOOC

C
2000 4000 6000 8000 10000
TONNES / Y

Fig 8 Scatterplot of electricity vs. output

- 13 -
 Table 2 summary of Survey Data

COMPANY OUTPUT SEC &4TCHES MTCH WENDINQJ OPENMiU N4TURAL

WOE PERHOUR Sm REMU MWNG RUBBER
T M r kWh/l((l KG % % %

TYRES

2. 28030 0.80 30 zx1 275 31 6 28 53 11

5 m m 0.67 20 190 50 48 6 31 Js 19
11 23 610 0.65 16 180 240 65 14 58 27 1
29b 40m 0.37 5R8 195 PO 23 1 4 4 5 5 1

aexdudingprbhaatluuel-mptim - 9OWlvbmswlput
b abc pod- other GRG. *mar prehealed
BELTS & HOSES

1 13M 0.33 12 100 50 1W

3 n m
.... 0
... 3 6 1% 10 8 51 30 11
im
~~

13 0.30 11 70 2 5 0 5 0
16 a 3000 0.53 12 60 10 10 50 30 10
19 b 4000 0.35 9 150 10 7 9 0 3
20 380 1.45 5 72 1W
23s 6030 0.30 12 135 10 9 3 8 4 5 6
26 137W 0.24 15 203 ea 67 33
L)tignifisantr~mkraquiredon mills belore fuamer pnrsssinp
b voallquan~~loufpufmixed-tMrmallmiib.~metpeheat
-
c a x ~ i n g ~ ~ r p r b h e a t f l l e l m n s u m p t i o1 n
30kVfMon~oupui
SEALS
4 62M 0.33 7 240 12 1 95 4
6 8 m 1.22 9 70 m v.rmall 21 11 4542 1
8 b 350 0.61 3 40 10 5 9 0 5
15 C 330 1.62 6 32 m m 31 32 30 26 12
18 d 180 0.66 15~2 ZL 50 50 60 10 30
24 e 450 1.04 50115 VAR €4 mal1 70 m 10
mi 2000 0.20 10 65 5 20 7 39 42 12

a 50%femilledthrwghdumpmill
b rnbjngonmilboniy,fawmatsrialrn-ter btllched by ohera
c 20%rem~mroughdumpmilion~,cmlinQ~slemproblsMincrsarsSEC
d 50%remkedonmiilsloradditiveadditione
B sdlerhslchesmixedonmiil, 50%rs-mixonmills
lele&isityrnnsumptionruspecf. low
ROLLERS
17 380 3.25 2 50 1W 25 10 53 37
25 250 0.78 4 50 10 90 10 m m
MOULDINGS&OTHER PRODUCTS
7 a 750 1.14 15 52 ea 1W 2 85 13
9b 9w 0.65 8 60 50 2 5 4 4 4 6 5
10 c 2m 0.23 6 70 50 35 5 5 5 5
12 d 2000 0.44 8 70 15 aoall 55 5 3 5 5 5 5
14 e 2030 0.28 9 1W 32 1 9 8 0 11
27 I 1860 0.32 7 115 10 10 103 10 50 30 10
30g 5x0 0.24 10 im 15 30 15 55

52 9 6 4 2 1 6
30 42 42 15

- 14 -
Other important elements of energy consumption for which some
results were obtained from responders were material pre-heat,
compressed air usage and cooling water loading.
Pre-heating, mainly of natural rubber, is carried out to
ensure that there are no crystalline formations in the core of
the block. The two valid responses were from companies using
warm rooms. Fuel consumptions were 0.13 kWh/kg output and
0.09 kWh/kg for 3,000 tonnes and 9,000 tonneslyear of output
respectively. Since rubber needs 0.012 kWh/kg to raise its
temperature from 10°C to 35OC, the best of these two
compounders is 15% efficient in overall terms. Both these
respondents used warm rooms, which are indirectly heated and
have high standing losses; hence the low overall efficiencies.
For compressed air use, the average consumption represented 8 %
of the total electricity consumption. This in turn is
equivalent to 0.05 kWh/kg across all sectors.
Cooling, whilst only a small proportion of total electricity
consumption, at 1.5% or about 0.01 kWh/kg has a much more
significant effect on overall batch cycle time. Cooling water
inlet temperatures vary from once through systems at 10°C to
tempered systems at 35OC. This range results in significant
differences in heat exchange, the higher inlet temperature
providing 20% less heat transfer capacity than the lower for a
similar cooling water temperature rise.

- 15 -
 5. OPPORTUNITIES FOR ENERGY SAVING

Whilst many parameters influence electricity consumption,

there are a number of common elements which can be controlled
both to reduce consumption and in some instances to cut cycle
time and improve product quality.
At present the compounding sector of the rubber industry
spends about E l l million per year on electricity and about
€100,00O/year on fuel for pre-heating.
Practicable Minimum Energy Consumption
A minimum energy consumption figure across the whole industry
is impossible to set because of the number of factors
governing energy consumption and the variety of practices
throughout the industry. Instead a target of a 10% saving
over a 1-2 year period is suggested for the compounding
industry.
This would be a saving across the industry of 28 million kWh/
year, valued at about €1.1 million.
The savings potential for different sites ranges from
€2,00O/year on a 500 tonnefyear GRG site to €50,00O/year on a
2 0 , 0 0 0 tonne/year tyre plant operation (calculations based on
electricity at 4p/kWh).
Internal Mixing
Savings can be obtained by improvements in control of batch
operations through:
polymer and oil pre-heat;
optimum control of additions;
controlled addition of ingredients, particularly
extender oils to maximise work input;
matching of work input to the ability of the compound
to accept work on the basis of integrated power
consumption;
reduction of motor power consumption between batches
and at break times.
Another factor influencing energy consumption and product
quality is mixer cooling. Supplying cooling water at optimum
temperatures to clean heat transfer surfaces in the mixer will
contribute to minimum energy consumption both in the mixing
and the cooling systems. The consistency of the cooling will
contribute towards a better product.

- 16 -
It may be that chilling could reduce overall electricity usage
by maintaining cycle times around the year. A lower limit on
water temperature will need to be set to prevent condensation
and consequent problems of slip between the compound and the
mixer walls.
Utilisation of exhaust air from the rams or of alternative and
more efficient methods of providing ram power on larger mixers
may be worthwhile.
Milling
Control of mills depends mainly on effectively matching power
supply with demand, minimising power consumption when
operating at no-load conditions and optimising cooling water
system operation as described above.
The main saving is likely to be achieved by switching mill
motor power either down or off. With smaller mills it should
be possible to switch motors off provided they are switched on
in sufficient time to allow the rolls to reach stable working
temperatures. Larger motors may require installation of a
motor controller which will sense low load conditions and
reduce the voltage supply to the motor accordingly.

- 17 -
 6. ACTION PLAN

This action plan lists some projects which are worthy of

investigation. Payback depends on the scale of the equipment
but is broadly classified as short ( S ) - less than one year,
medium (M) - one to three years, or long term (L) - over three
years.
Many of the measures discussed below will also lead both to
improved throughput and consistency of production. These
benefits will be reflected in further reductions in unit
operating costs which will substantially reduce the project
payback periods indicated from an assessment of energy savings
alone.

Area Energy saving Measures Payback

Period

Material
pre-heat
. Use well sealed and insulated
rooms or chambers for holding
. polymer.
Separate polymer blocks to allow
S

.
circulation of warm fluid to the
largest possible surface. S
Employ fully recirculating warm air

.
systems where these are in use or
proposed. S

.
Control pre-heat temperature (in
warm rooms or chambers). S
Store polymer outside the heated

.
container in closely packed blocks
to limit heat loss. S
Check heater efficiency on a weekly

.
basis using a portable efficiency
monitor. S

..
Consider the use of microwave pre-
heating. L
Heat extender oils. L
Employ waste heat if available from
other site operations for pre-heat
duties. L

- 18 -
 Area Energy Saving Measures Payback
Period

.
-

Control of Monitor and control formulations to

additions minimise off-specification materials

.
by using accurate weighing methods
(+/-0.2%). s
Install kilowatt-hour meters on a l l
mixers both to allow recording of
consumption throughout each batch and
hence tighter control over processing
and to provide data for more detailed

.
kWh/batch checks, ie monitoring and
targeting. M
Install systems to measure and record
temperature in the mixer and use this
in conjunction with kWh recordings to

.
optimise processing. M
Motor load Consider the application of variable
control speed control on mixer and mill
drives using speed in conjunction
with integrated power control to

.
optimise energy consumption during
on load and off load operation. M
As a less expensive option to
variable speed drives, consider
soft start devices on mills. M
(See Good Practice Guide 2 - Guidance
Notes for Reducing Energy Consumption

.
Costs for Electric Motors and Drives).
Cooling system Temperature optimisation employing

.
chillers (using condenser heat for
the polymer pre-heat duty). M-L
Application of pressure controlled
variable speed pumping in conjunction

.
with temperature control of mixer
batches. L

.
Control of tower fans from tower
base water temperatures. M
Monitoring of water quality in terms
of salts and iron content to minimise

.
fouling on cooling surfaces. S
Ram operation Where low pressure air is used for
conveying, consider collecting ram

.
exhaust air at low pressure for
this duty. M-L
On large machines, consider the use
of alternative methods of providing
ram power such as linear motors. L
- 19 -
 Area Energy Saving Measures Payback
Period

c
Extender oil use Ensure that all systems are well
insulated and temperature controlled
where heat loss is significant. S
On circulating systems, use pressure
controlled variable speed drives. S

Dust extraction Use variable speed drive to optimise

system operation flow through control of pressure
drop across filters.
General High efficiency motors. L
applications (See Good Practice Guide No 2)

- 20 -
 7. FURTHER INFORMATION

The following literature and information are available:

. Case Studies and Guides

Case Study No 34 - Energy Monitoring and Target
Setting at a Tyre
Manufacturing Site.

Good Practice
Guide No 2 - Guidance Notes for Reducing
Energy Consumption Costs of
Electric Motor and Drive
Systems.

These and more general literature on energy efficiency

can be obtained from:
Energy Efficiency Enquiries Bureau
ETSU
Harwell
Didcot
Oxon
OX11 ORA

Tel: 0 1 2 3 5 4 3 6 7 4 7
Fax: 0 1 2 3 5 4 3 3 0 6 6

. Fuel Efficiency Booklets

NO 4 - Compressed Air and Energy Usage.
NO 9 - Economic use of Electricity.
These can be obtained from:
Department of Energy
Blackhorse Road
London
SE^ ~ J H

- 21 -
. Information on Energy Efficiency in Buildings can be
obtained from:
Enquiries Bureau
BRECSU
Building Research Establishment
Garston
Watford
WD2 7JR
Tel: 01923 664258
Fax: 01923 664097

. General information on the rubber processing industry

can be obtained from:

British Rubber Manufacturers' Association

90 Tottenham Court Road
London
W1P OBR
Tel: 0171 580 2794
Fax: 0171 631 5471

The Energy Efficiency Office also holds seminars,

workshops and site visits around the UK, which cover a <

wide range of projects.

Details of these events and all Energy Efficiency Office
literature can be obtained from your Regional Energy
Efficiency Office.
Information on energy efficiency demonstration projects
worldwide can be obtained through CADDET, an activity of
the International Energy Agency. Brochures, reports and
a free subscription to a quarterly newsletter are
available through Dr R A W Shock at ETSU, who can be
contacted on Tel No: 01235 432621.

- 22 -