# From Boucher Michael 

# Sent Tuesday September 

# 23 2008 

# 417

# PM

# GMT To Edwards.Dennisepamail.epa.gov 

# Cc Shackleford.Bettyepamail epa.gov 

# Noble.Velmaepa.gov Ross.Philipepamail.epa.gov 

# Boucher Michael 

# mbouchermckennalong 

# com Subject 

# Buckman Laboratories 

## Inc--Meeting request 

# Attach Amended petition.pdf

Dear Dennis Following our electronic submission of the attached petition to

# EPAon September 

## 2008 would like to respectfully 

### renew request 

### on behalf of our client 

## Buckman Laboratories 

### Inc 

# Buckman for face-to-face 

### meeting at

## OPP in Arlington with 

## you Phil 

## Ross and yourcolleagues in the Antimicrobial Division to discuss the substance of

## Buckmans petition In 

### August following 

# my initial meeting request understood that 

### you were looking forpossible meeting dates 

### and would be responding to

## me with suggestions but never heard anything further

### fromyou with respect to 

### meeting 

# Now that there is something concrete and detailed to discuss 

### namely the attached petition 

## am hoping that 

### you will be able to suggest date or dates to 

### meet with 

## me and representatives of

## Buckman to discuss the serious 

### problemsassociated with the

### ongoing distribution and sale of unregistered 

### ammonia for water treatment thank 

### you for

### your kind consideration of this 

### meeting request and look forward to reply at

### yourconvenience Thank 

## you Dennis Sincerely 

### Michael Boucher Counsel to

## Buckman Laboratories 

### Inc 

# McKENNA LONG ALDRIDGE LLP Attorneys at

## Law Michael Boucher 

## Tel

# 202 496-7729 

## Fax

# 202 496-7756 Cell 

# 202 306-1645 mboucher@mckennalong.com
1900 Street 

# NW Suite 100 

### Washington 

## D.C 20006-1102 United States of

### America 

## Tel

# 202 496-7500 http//www.mckennalong.com 

# ALBANY ATLANTA BRUSSELS 

# DENVER LOSANGELES 

# NEW YORK PHILADELPHIA 

# SAN DIEGO SAN FRANCISCO 

# WASHINGTON D.C

Original 

### Message 

## From Boucher Michael Sent Tuesday September 

## 02 2008 

## 431 

# PM To Edwards.Dennis@epamail.epa.gov 

# Cc Sanders.Frank@epamail.epa.gov Shackleford.Betty@epamail.epa.gov 

## NobleVelma@epa.gov Ross.Philip@epamail.epa.gov Boucher Michael Subject 

# RE Petition

### on behalf of

## Buckman Laboratories 

### Inc

### Dear Dennis
Attached is slightly 

### amended version of

## Buckmans petition 

### added missing citation 

### on page and fixed 

### one typographical error 

### on page 13 look forward to discussing with 

### you what

# EPA can 

### do to resolve the outstanding registration issues surrounding 

### ammonia forwater treatment 

### Thank 

## you Michael Boucher Counsel to

## Buckman Laboratories 

### Inc Michael Boucher 

## McKenna Long Aldridge 

## LLP 1900 Street 

# NW Suite 100 

### Washington 

# DC 20006-1110 

# 202 496-7729 -7756 

# fax e-mail 

## mbouchermckennalong.com

Original 

### Message 

## From Boucher Michael Sent Tuesday September 

## 02 2008 

## 221 

# PM To Edwards.Dennisepamail.epa.gov 

# Cc Sanders.Frankepamail.epa.gov Shackleford.Bettyepamail.epa 

## gov Noble 

## Velmaepa.gov Ross.Philipepamail.epa.gov Boucher Michael Subject Petition

### on behalf of

## Buckman Laboratories 

### Inc

Dear Dennis
Attached is petition that 

## we are filing 

### on behalf of our client 

## Buckman Laboratories 

### Inc under section

# 553e of the Administrative Procedures 

## Act U.S.C 

# 553e The petition requests that 

# EPAimmediately prohibit any further distribution or sale of unregistered 

### ammonia forwater treatment 

### Thank you for

### yourconsideration of

## Buckmans petition 

# We will telephone 

### you to learn 

## how

# EPA will handle and process the petition Sincerely 

### Michael Boucher Counsel to

## Buckman Laboratories 

### Inc Michael Boucher 

## McKenna Long Aldridge 

## LLP 1900 Street 

# NW Suite 100 

### Washington 

# DC 20006-1110 

# 202 496-7729 -7756 

# fax e-mail 

## mbouchermckennalong.com

Original 

### Message 

## From Edwards.Dennisepamail.epa.gov Edwards.Dennis@epamail epa

## gov Sent Thursday July 

### 10 2008 

## 510

# PM To Boucher Michael 

# Cc Sanders.Frankepamail.epa.gov Shackleford.Bettyepamail.epa 

## gov Noble 

## Velma@epa.gov Ross.Philipepamail.epa.gov

### SGo1dbergsteptoe corn Subject Petition to Cancel Registration of

### BusanR 1215 

# EPAReg 

# No 1448-433



### Dear

# Mr Boucher 

## On June 

## 25 2008 you sent letter to the

### Agency concerning petition filed 

### on behalf of

# NALCOconcerning the

### Agencys approval of

### your client 

## Buckman Laboratories Inc.s applications forregistration of

### two arnrnonia products as pesticides 

# NALCO in its petition has asked the

### Agency to reconsider its approval of those registrations and has raised questions about the status of arnrnonia products as pesticides 

## when used in cornbination with chlorine treated 

### water In

### your letter arnong other things 

### you have asked for 

### copy of the petition as well as any correspondence 

### between the

### Agency and 

# NALCOconcerning its petition 

## You also asked for 

### copy of an interirn response that the

### Agency sentto

# NALCO after receiving its petition This ernail responds to those requests fordocurnents only 

### and is not addressing at this tirne any other staternents or requests that 

### you have included in

### your letter

In filling 

### your request 

## we are providing 

### you with the docurnents 

### which constitute the petition and support docurnents as well as subsequent correspondence 

### between the

### Agency and 

# NALCOconcerning sorne questions the

### Agency has 

### had as of this point about 

# NALCOs petition and support docurnents 

# We are also providing 

### you with 

### copy of the

### Agencys interirn response to

# NALCOwhich you specifically asked about in

### your letter Additionally since

## we are sending 

### copy of this ernail and the attachrnents to counsel for 

# NALCO we are including 

### your letter to 

### Frank Sanders dated June 

## 25 2008 as well as sorne ernail exchanges 

### between you and 

### Agency counsel 

### on this rnatter Please note that

## we are not including ernail 

### exchanges that 

### Agency staff 

### had with

# NALCOcounsels firm

### which pertained only to the

### need for review of various docurnents forconfidential business information and subsequent redactions 

### The docurnents 

### you are being provided 

### have been reviewed and redacted as appropriate to rernove any confidential business information 

### The following docurnents are being provided to

## you
Decernber 

### 2007 ernail frorn Seth 

### Goldberg to 

### Debbie Edwards It is contained in the file narned 

### 12-4-07 ernail to

## EPA.Redacted See attached file 12-4-2008 ernail to 

### EPA.Redacted.pdf
Decernber 

### 2007 request frorn 

# NALCOto reconsider It is contained in the file narned 

### Redacted Request to Reconsider Arnrnonia Registration 

## See attached file 

### Redacted Request to Reconsider Arnrnonia Registration.pdf

October 

## 31 2007 ernail frorn Seth 

### Goldberg to 

### Debbie Edwards It is contained in the file narned 

### 10-31-07 ernail 

### redacted 

## See attached file 10-31-07 ernail 

### redacted.PDF 

# An attachrnent to the October 

## 31 2007 ernail frorn Seth 

### Goldberg concerning arnrnonia It is contained in the file narned 

### Arnrnonia Cornpound Briefing Paper 

# REDACTED See attached file Arnrnonia 

### Cornpound Briefing Paper 

# REDACTED.PDF

product label for 1448-432 

# MUP that 

### was attached to the October 

## 31 2007 Goldberg ernail It is contained in the file narned 

### 1448-432 

# MUP

## See attached file 1448-432 

## MUP.pdf

product label for 1448-43 

# EP that 

### was attached to the October 

## 31 2007 Goldberg email It is contained in the file 

### named 1448-433 

# EP See attached file 1448-43 

### EP.pdf

The Agencys interim response to

# NALCOdated February 

## 2008 concerning its petition It is contained in the file 

### named 

# NALCOresp ltr

### 2.7.08 

## See attached file 

### Nalco resp ltr 2.7.08.pdf



### Email correspondence 

### from

## Brown with Steptoe 

### which is

# NALCOs counsel dated June 

## 26 2008 It is contained in the file 

### named 

# Brown Steptoe to 

### Holmes email 

### 6-26-2008 

## See attached file 

## Brown Steptoe to 

### Holmes email 

### 6-26-2008.pdf

Email exchanges involving 

## Brown Steptoe and 

## Holmes They are contained in the file 

### named 

## Email to

## Brown and 7-7-2008 

### reply 

## See attached file 

### Email to

## Brown and 7-7-2008 reply.pdf 

### 10 July 

### 2008 

## Ammonia Supplemental Information provided to the

### Agency by

## Brown Steptoe It is contained in the file

### named 7-7-2008 

## Ammonia

supplemental 

### information 

## See attached file 7-7-2008 

## Ammonia supplemental information.pdf 

### 11 Emailexchanges between Ross 

## Agency counsel in this

### matter and 

### Boucher counsel for

## Buckman Laboratories 

### Inc. They are contained in the file 

### named Ross-Boucher-email-exchanges-ammonia 

## See attached file 

### Ross-Boucher-email-exchanges-ammonia.pdf 12 Boucher letter to 

### Frank Sanders dated June 

## 25 2008 It is contained in the file 

### named Letter to

# EPA re petition to cancel 

### Busan 

## 1215 See attached file Letter to

# EPArepetition to cancel 

### Busan 1215.pdf Should 

### you have any questions please direct 

### them in writing to

## me with 

### copy to Philip 

### Ross in our Office of General 

### Counsel 

## You should also provide 

### copy of any correspondence pertaining to this matter to counsel for

# NALCO Sincerely 

### Dennis Edwards Chief Regulatory 

### Management Branch Antimicrobials Division 703 -308-8087

# BUCKMANLABORATORIES INC.S

# REPLYTONALCO

# COMPANYSDEC 2007 

# REOUESTTHATEPA

# RECONSIDERITS

# REGISTRATION 

# FORAMMONIA PRODUCTS AS

# PRECURSORS TOCHLORAMINE USED IN

# WATERTREATMENT AND 

# BUCKMANLABORATORIES INC.S

# REOUESTTHATEPA

# IMMEDIATELY PROHIBIT 

# FURTHER DISTRIBUTION 

# ANDSALE OF UNREGISTERED 

# AMMONIA FOR

# WATERTREATMENT

Michael Boucher 

# MCKENNA LONG ALDRIDGE 

# LLP 1900 Street

# NW Washington 

# D.C 20006 

# 202 496-7729 Counsel to 

## Buckrnan Laboratories 

## Inc

September 2008

# TABLE OF

# CONTENTS Page Overview II 

## Both Nalco and

# Buckman sell

# ammonia for

### use in 

### proprietary systems in

## which 

# ammonia and sodium hypochlorite react to 

## form

# MCAwhich is 

### the active ingredient supplied 

## byeach system for

## water treatment III Registration 

## of

# ammonia is

## necessary because

# MCA is 

### too unstable to exist as 

### marketable 

# commodity no EPA-approved sodium hypochlorite label 

### has instructions for

### use with 

# ammonia to 

### safely

## produce

# MCAandthe continued use 

## ofunregistered 

# ammonia to 

## produce

# MCA presents 

## unnecessaryand potentially unreasonable risks to 

# human health 

## and the 

## environment 

# IV Ammonia does not sequester orrelease 

# chlorine and is

### not 

## an adjuvant 

# ammonia does react with 

## sodium hypochlorite to 

## produce an entirely 

# new active ingredient 

# MCAwhich has distinct 

### properties 

## fromhypochlorous acid 

# EPA should 

## promptly deny

# Nalcos Petition to 

## revoke

# Buckmans ammonia registrations 

## because the

# Agency has properly registered 

# Buckmans ammonia as



### precursor 

## of

# MCAfor

## watertreatment 11 

# VI EPA should 

## immediately prohibit further 

### distribution 

## and sale 

### ofunregistered 

# ammonia for

## watertreatment 

## because the continued sale 

## ofunregistered 

# ammonia to 

### the 

## same customers for 

## and for 

### the 

## same uses 

## as

# Buckmans registered

# ammonia presents 

## unnecessaryand potentially unreasonable risks to 

# human health 

## and the 

## environment contradicts 

## and undermines the

# Agencys proper registration 

## of

# Buckman ammonia and unfairly 

## damages the 

## commercial value 

## of

# Buckmans registrations 

### 12 

# VII Conclusion 14 

# EXHIBIT Food additive petition

## ofthe 

## Zentox Corporation to 

### provide for 

### the safe use 

## of

# MCA as 

## an antimicrobial agent in 

### poultry process chiller 

## water 

# EXHIBIT Label 

## ofNalcon 60620 

# EXHIBIT Nalco 

# Company proposal for

# OxiPRO microbiological control 

## program 

# EXHIBIT Nalco 

# Company slide 

### presentation 

# PM Biocide Trial 

## Operator 

# Overview 

# EXHIBIT EPA-registered label 

## ofBusan 1215 

# EXHIBIT Photograph ofBusan 1215 Feed System 

# EXHIBIT Linedrawing ofBusan 1215 Feed System

# TABLE OF

# CONTENTS continued


# EXHIBIT Process 

## diagram ofBusan 1215 Feed System 

# EXHIBIT In the

## Matterof South CoastChemical 

# Inc E.A.D 139 145 

# 1986 EXHIBIT EPA-registered labels 

## ofNalco 

# Companys sodium hypochlorite products 

# EXHIBIT EPA-registered label 

## ofSunny Sol 

## 150 

# EXHIBIT February 2008 letter 

## fromFrank Sanders to 

### Seth 

## Goldberg



# 11

# Overview Nalco 

# Companys hereinafter 

# Nalcos December 2007 

# RequestThat

# EPA Reconsider Its 

### Registration for

# Ammonia Products as 

### Precursors to 

## Chloramine 

# Used in

## Water Treatment and Provide 

## Assurance That There Is

# No Risk ofEnforcement during the Reconsideration 

## and

# Any Necessary Transition 

## Period hereinafter 

# Nalcos Petition is
tirade 

### against 

# EPAs registrations 

## of

# BCMWEPAReg

# No 1448-432 and Busan 1215

# EPA Reg

# No 1448-433 Buckman Laboratories Inc.s hereinafter 

# Buckmans manufacturinguse 

## and end-use 

# ammonia products respectively 

## The violence of

# Nalcos protest tacitly 

## acknowledges 

# Nalcos need to register its 

# own current end-use 

# ammonia product Nalcon 

# 60620 because Nalcon 60620 and Busan 1215 essentially 

## have the 

## same composition are 

## used bythe


## same industrial 

### users in

### the 

## same manner for

## water disinfection 

## and areconsidered interchangeable products in 

### the 

## marketplace Nalco Petition ignores the

# unknown and potentially unreasonable risks 

### presented 

## bythe 

## ongoing use 

## ofunregistered 

# ammonia to 

## produce monochloramine hereinafter 

# MCA including 

# human health risks 

## fromunapproved residues 

## of

# MCA in 

### paper 

## used for

## foodpackaging and toxicityto 

### aquatic 

## organisms from

# MCAresidues

in industrial 

## waste

# water Not surprisingly 

## Nalco alsoignores the significant 

## and ongoing 

# damagebeing 

## done unfairly to 

### the 

## commercial value of

# Buckman ammonia registrations 

## and

to

# Buckmans ability to 

### recoup its 

### investment in

## such registrations 

## by

# Nalcos ongoing sale 

## of unregistered 

# ammoniawith

# EPAstemporary permissionwhich has lengthened to 

## seven months with noend in 

### sight

Coincidentally 

## we have obtained pre-publication 

### Federal Register notice attached hereto as Exhibit 

### which reports that 

### Zentox Corporation has petitioned the

### Food and Drug Administration to use

# MCA as food additive specifically 

## as an antimicrobial agent in poultry process chiller 

### water emphasis 

## added even though 

# EPAhas not registered

# MCAor

### ammonia for 

### any such 

### use This food additive petition underscores the urgent 

### need for

# EPA to publicly affirm its jurisdiction over

# MCA specifically to prohibit the further distribution 

### and sale of unregistered 

### ammonia for 

### any water treatment 

### use including poultry processing

# To justify 

### the status 

# quo Nalco offers series 

## ofincreasingly erratic 

## and unfocused arguments Initially 

## Nalco alleges that 

# ammonia cannot 

## be registered 

## because it is

### not 

## an active ingredient 

# Nalcos Petition at

# 6-7 but later flip-flops 

## and acknowledges that in 

### fact 

# EPA can register 

### precursor 

## ofan active ingredient 

## where registration 

### of the active ingredient itself is 

### not practical 

# Nalcos Petition at 

### exactly as

# EPA has 

## done with

# BCMW and Busan 

# 1215 because the registration 

## of

# MCA itselffor

## water treatment is 

### impractical 

# Then Nalco agrees
that 

## combining 

# ammonia and sodium hypochlorite 

## produces

# MCANalcos Petition at in 

## chemical reaction 

# known since the early 

## 1900s but alleges that

# MCA is

### not an active ingredient
that is 

### separate 

## from

# chlorine hypochlorous acid 

# Nalcos Petition at 

## 8-9

# 11 even though the production of

# MCA is 

### reaction that is 

### not considered reversible 

# i.e once 

# formed

# MCA
does not readilybreak 

# down into orotherwise 

## produce 

# ammonia and hypochlorous acid/hypochlorite 

# ions and despite that 

# EPA and industry recognize 

# MCAas distinct 

### active ingredient 

## with valuable properties that 

### are different 

## fromthose 

## ofhypochlorous acid Nalco alsoplays variations 

## onthe foregoing 

# theme specifically that 

# ammonia sequesters and releases 

# chlorine by novel 

## chemical process that 

## Nalco never explains 

# Nalcos Petition at 

## 6-7 

# 11-12 and that 

# ammonia is 

### only 

## anadjuvant 

## used with 

# chlorine and thus requires 

## no registration 

# Nalcos Petition at

# 15 even though 

# ammonia reacts 

### completely 

## with sodium hypochlorite to 

## form 

# new active ingredient 

# MCAand thus does not hold orrelease 

## hypochlorous acid 

## and does not 

## resembleany adjuvant Forthe foregoing 

## reasons as articulated 

## and explained in this 

### petition 

# we respectfully request pursuant to 

### section 

# 553e ofthe Administrative Procedures 

## Act 

# U.S.C 

# 553e that 

# EPA deny

# Nalcos Petition 

## and immediatelyprohibit further distribution 

## and sale 

## ofunregistered 

# ammonia for 

### water treatment 

## Nalco has 

## asked for

### time to register 

# ammonia but neither 

## needs

-2-

### nor deserves 

## any additional 

## time Nalco has 

## had notice 

## of

# EPAs policy 

## on the registration 

## of 

# ammonia for

## watertreatment since the

# Agencys registration 

### of

# Buckmans ammonia products


## on

# March 2007 Since then period 

## of18 

## months Nalco has 

## found ample time to 

# make two lengthy 

## and duplicative submissions 

## and one responsive 

## submission to

# EPA in 

### orderto 

### subvert the

# Agencys registration 

## of

# Buckmans ammonia products Neither 

## of

# Nalcos original filings 

### ever 

## had likelihood 

# much less 

### certainty 

## ofpersuading 

# EPA to 

## revoke its 

### considered registrations 

## of

# ammonia which Nalco 

# knew at

### the time 

## of its filings 

## Indeed as 

### recently as 

### July 

# 15 2008 the

# Agency amended Buckmans registration 

## ofBusan 1215 to 

## add 

# new use industrial 

## water

# systemswhich suggests 

## no intent 

## by

# EPA to 

### grant either 

## ofNalco original 

### requests to 

## revoke

# Buckmans ammonia registrations 

## Accordingly in 

### addition to filing petitions 

## with

# EPA Nalco also 

### should 

## have filed 

## or at 

# minimumprepared itself fully to file 

## an application to register 

# ammonia sometime during the past 18 

# months If as it 

## appears Nalco has 

## chosen instead to 

### focus 

## wholly on speculative petition effort 

### intended to 

### manipulate 

# EPA into 

### allowing 

## Nalco to 

## remain on the 

## market without 

## an

# ammonia registration 

# and thereby to 

### continue to 

## compete with

# Buckman unfairly

# and specifically to 

### erode its 

## customerbase the 

# Agency should not

# nowreward Nalco for its

## gamesmanship with any additional 

## timeto register 

# ammonia
In preparing this 

### petition

## on behalf 

## of

# Buckmanwe consulted with scientists 

## and regulatory consultants at

## Technology Sciences 

## Group 

# Incnamely

# Dr Robert Stewart Vice President 

## and Managing Director 

## and

# Dr David 

# Brookman Director 

## ofEnvironmental Chemistry 

# Drs Stewart 

## and

# Brookman have reviewed and concur in 

### our technical representations in this 

### petition

-3-

## II Both Nalco 

# and

# Buckman sell

# ammonia for use in

## proprietary systems in

## which 

# ammonia andsodium hypochlorite react to 

# form

# MCAwhich is 

### the active intredient 

## supplied

# byeach system for

## water treatment 

# Useofeither 

# Nalcos or

# Buckmans end-use 

# ammonia product as 

### labeled generates the



## same main active ingredient 

# MCAmonochloramine which is

## formed by chemical reaction
that 

### occurs at

### the time 

## ofuse The general reaction isas 

## follows Figure base 

# HOCI0C1 NH3/NH4 NHCI 

# NHCI Nd3 Hypoclorous acid 

# Ammonia Monochioramine Dichioramine Nitrogen

hypochiorite ion 

# ammoniumion trichioride


## The reaction is

## normallyterminated at

### the stage

## where 

# MCA is

# formedbut dichloramine 

## and nitrogen trichloride 

### also

# mayoccur
The nominal active ingredient in

# Nalcos end-use 

# ammonia product 

# Nalcon 60620 is 

# ammonium sulfate 

## and in

# Buckmans end-use 

# ammonia product 

# Busan 1215 is

# ammonia total which derives 

## fromanaqueous mixture of

# ammonia and

# ammoniumsulfate 

## Therefore both products provide 

# ammonia or

# ammoniumions in 

### the reaction

# shown in 

### Figure 

# above and both lead to 

### the in-situ 

### generation 

## ofone or

## more chloramines According to its 

### label attached hereto as 

### Exhibit 

## Nalcon 60620 is

## an unregistered formulation consisting 

## of

# 20%ammonium sulfate 

## and

# 80%constituents ineffective as 

### spray 

## adjuvants presumably water Nalco sells

## Nalcon 60620 as 

### part

## of its

# OxiPROTM Deposit Control 

# Technology and specifically for

### use in

# Nalcos 

# OxiPRO Feed 

# System which is
illustrated 

## and described in 

## Nalco proposal 

## and Nalco slide 

### presentation attached hereto as 

### Exhibits 

## and respectively 

# Nalcos label for

## Nalcon 60620 and

# Nalcos materials 

## on the

# OxiPRO Feed System describe process in

## which Nalco technician adds 

## Nalcon 60620 to
-4-

## sodium hypochlorite in 

## molar ratio

## between 

# 11 and

# 21 at 

### controlled 

## temperature under alkaline conditions to 

## produce stabilized 

# oxidantwhich Nalco does not identify 

### but 

## which is 

# MCAupon examination Based upon the available 

## informationuse 

## of

# Nalcos OxiPRO Feed System involves the following preparative steps 

# Aqueous sodium hypochlorite 

# 12.5% is

## added to 

## aqueous sodium hydroxide

# 50%

to 

## produce an initial 

### mixture 

## ofsodium hypochlorite 

## sodium hydroxide andwater

# pH To this initial

## mixture aqueous 

# ammonium sulfate

# 20% is 

## added in 

## molar ratio 

## between 

# 11 and 

# 21 to 

## produce second mixture containing 

## chloramines sodium sulfate 

## sodium chloride 

## and water.2 

## The second mixture is 

### diluted with additional 

## water to 

## produce lowerconcentration 

## of

# MCApresumably 10-12 parts 

### per million hereinafter 

# ppmmeasured as total 

### chlorine 

## which is

### the target 

### stated in

# Nalcos June

# 23 2008 slide 

### presentation 

# Ex at 

## The diluted mixture is

## promptlyadded to 

### the 

## customers process 

## water at

### the desired 

# points According to its 

### label attached hereto as 

### Exhibit 

## Busan 1215 is 

### an EPA-registered formulation 

# EPAReg

# No 1448-433 consisting 

## of7.59% 

# ammonia and 92.4

# 1%inert ingredients 

# Buckman sells 

## Busan 1215 as 

### part

## of proprietary 

## water disinfection 

## system for 

### pulp 

## and paper mills

## and industrial 

### cooling systems mill specifically 

# Buckmans Busan 1215 Feed 

# System The Busan 1215 Feed System is illustrated in 

## photograph line 

## drawing and
process 

## diagram attached hereto as 

### Exhibits 

## and respectively

Nalco process description does not permit estimation of the exact composition of the second 

### mixturewhich 

## may contain dichioramine 

### and possibly 

### even nitrogen trichloride in addition to

# MCA

-5-

### In the 

## Busan 1215 Feed

# System Buckman technician adds 0.5 

# oz ofBusan 1215 to 

# oz ofsodium hypochlorite 

# 15%wt/wt to 

## produce

# MCAunderconditions 

## ofcontrolled temperature 

## and

# pH Specifically use 

## ofthe 

## Busan 1215 Feed System involves the following preparative steps 

# Aqueous ammonia

# pH is 

### diluted 

## withwater Unlike the

# OxiPRO Feed 

# System the 

## Busan 1215 Feed System does not require the addition 

## of base such as 

## sodium hydroxide because basic conditions are 

### maintained 

## bythe

# ammonia The initial

### mixture is

## added to 

## aqueous sodium hypochlorite 

# 12.5% at 

# minimum 

# 32 molar ratio 

## ofsodium hypochlorite to

# ammonia to 

## produce second mixture 

## of

# MCA sodium chloride 

## andwater The second mixture is 

### diluted with additional 

## water to 

### achieve concentration 

## of0.5

to 

# ppm of

# MCA in 

### excess 

## ofthe 

## system oxidant 

# demand

# maximum of 

# ppm measured as total 

## chlorine and the diluted mixture is

## promptly added to 

### the 

## customers process orcooling 

## water

at

### the desired 

# points 

# When Busan 1215 is

## used as 

### directed in 

### the 

## Busan 1215 Feed Process the 

## sodium hypochlorite/hypochlorous acid is 

### completely 

# consumed and chloramines otherthan

# MCAdo
not 

## form readily 

## Forthis

## reason

# MCA is 

### the soleoxidant 

# i.e active ingredient in 

### solutions prepared 

## from Busan 

# 1215
In

# sum careful 

## examination of

# Nalcos OxiPRO Feed System and

# Buckmans Busan 1215 Feed System shows that in

### both 

## systems 

# ammonia and sodium hypochlorite reactto 

## produce chloramines The 

# Buckman system generates

# MCAand the

## Nalco systemgenerates 

# MCAand possibly also other

## chloramines The basic chemistry underlying both processes is 

### familiar

## and has 

## been 

# known since the early 

## 1900s

# U.S Envtl Protection 

# Agency Office 

## of

-6-

# Water Alternative Disinfectants 

## and Oxidants Guidance 

# Manual April 

# 1999 at 

## 6-1 available
at http 

# //www.epa gov/OGWDW/mdbp/alternative disinfectants 

## guidance.pdf hereinafter 

## Oxidants 

# Manual In its

# December 2007 petition 

## Nalco does everything but explain in 

### accurate chemical terms 

# how ammonia is

## used in

## Nalco and

# Buckman water treatment 

## systems Accordingly 

# Nalcos avoidance ofchemistry obscures the fact that

# MCA is

### the pesticidal 

### active ingredient that results 

## fromboth Nalco and 

# Buckmans use 

## of

# ammonia for 

## watertreatment III Retistration of

# ammonia is

## necessary because 

# MCA is 

### too 

## unstable to exist 

### as 

## marketable 

# commodity no 

# EPA-approved sodium hypochlorite label 

## has instructions foruse 

## with 

# ammonia to safely 

## produce 

# MCAand the 

## continued use of 

## unretistered

# ammonia to

## produce 

# MCA presents 

## unnecessary 

# and potentially 

## unreasonable risks to

# human health 

# and the 

# environment Over period 

## of day or

# sowithout 

## any modification of

# pH or

# C12N ratio

# MCA will 

### degrade slowly to 

## dichloramine specifically to ratio 

## of

# 43%

# MCAto

# 57% dichloramine which is itself

### unstable 

## and also has 

## an unpleasant taste 

## and odor to 

# humansOxidants 

# Manual at 

### 6-2 to

# 6-3 Forthis

## reason it is

### impractical to bottle 

## and sell

# MCAas 

## commercial pesticide 

## product and

# wehave been unable to 

### find

## any

# EPA registration 

## of

# MCApast orpresent Instead since the 

## 1930s the universal practice has 

## been to 

### generate

# MCA in situ

# i.e at

### the site

## of

# use
for 

### use as 

## water disinfectant 

## Oxidants Manual at

# 6-1 In 

# 1986

# EPAsEnvironmental Appeals Board affirmed the

# Agencys authority to register 

## parent chemical or

# immediateprecursor that 

# does not itself

## have pesticidal 

### properties but 

## produces pesticidal 

### action at

### the site

## ofapplication 

# when the actual pesticide required to 

## be regulated 

## underthe Federal Insecticide Fungicide.. cannot exist as 

### marketable 

# commodity and

# when the parent 

## chemicallimmediateprecursor is

# the only logical 

### chemical 

## through which the use 

## ofthe pesticide 

## canberegulated 

# In the

## Matterof South CoastChemical 

# Inc

E.A.D 139 145 

# 1986 included as 

### Exhibit 

## hereto Under the foregoing rationale
-7-

# ammonia should 

## be registered despite its 

### lack 

## ofpesticidal 

### properties 

## because 

# ammonia produces pesticidal 

### action at

### the site

## ofapplication 

## i.eproduces

# MCA at

### the use site

## because 

# MCAcannot exist as 

### marketable 

# commodity due to its instability 

## and because 

# ammonia is 

### the only logical 

## chemical through which the use 

## of

# MCAcanbe regulated 

## Nalco proposes in

### effect that 

### the registration 

## ofsodium hypochlorite alone is sufficient

to 

### regulate the use 

## of

# MCAbut there is

## no

# EPA registration 

## ofsodium hypochlorite that 

### addresses use with 

# ammonia to 

## produce

# MCA Nalcos five 

## sodium hypochlorite registrations 

# EPAReg Nos 1706-171 -179 -238 -20001 

# -20002 attached hereto as 

### Exhibit are silent 

### about 

## any use with 

# ammonia as is 

### the registration 

## of

# Sunny Sol 150 

# EPAReg

# No 1744- 

## 2000 attached hereto as 

### Exhibit registered 

## sodium hypochlorite product that 

## Nalco 

# recommends for

### use with 

# ammonia in

# Nalcos OxiPRO Feed 

# System Thus maintaining the

status 

## quo Nalco plan will 

### not ensure that 

### users 

## of

# ammonia and sodium hypochlorite to 

## produce

# MCA will 

## have appropriate labeling including 

## warnings precautions 

## and directions for


# use that 

# EPA has 

## reviewed and approved to 

### ensure the safeuse 

## of

# MCAas 

### pesticide
theoretical alternative to 

### the status 

## quo is to 

# amend all 

### existing 

## sodium hypochlorite registrations either to 

### prohibituse 

## with

# ammonia orto specifically 

### address such use to 

## produce 

# MCAbut this is

## an impractical solution 

## because there are 

## 211 registrants 

### with 

## 379 registrations 

## ofsodium hypochlorite 

# Onthe other

# hand ammonia has only 

## one registrant

# Buckman and only 

## one end-use registration for

## Busan 

# 1215 which is 

### registered specifically for 

### use with 

## sodium hypochlorite to 

## produce

# MCA indeed 

# ammonia currently has 

## no other 

## pesticidal use Accordingly to 

### regulate the use 

## of

# MCAEPAs best 

## and only practical option isto register 

# ammonia as 

### precursor 

## of

# MCA as 

### the

# Agency has 

## done in

# Buckmans case 

## and 

# now needs to 

## do in 

### the case 

## ofNalcon 60620 and all 

### other unregistered 

# ammonia for

## watertreatment

-8-

# EPA also 

## needs to register 

# ammonia to 

### ensure that 

### the use 

## of

# MCAdoes not present unreasonable adverse effects 

## on the 

## environment In the case 

## ofBusan 

# 1215 for

# example

# EPA required 

# Buckman as 

### condition 

## ofregistration to 

### obtain letter 

## fromthe

# Food and Drug Administration regarding 

## whether

# MCArequires 

## food additive tolerance 

## under section 

## 409 of the Federal 

# Food Drug and Cosmetic Act for

## any residues of

# MCA in

## paperused for

## food packaging In addition 

# MCA is 

### toxic to 

### aquatic 

## organisms and

# Buckmans label 

### includes directions for 

### use that limit 

### the quantity 

## of

# MCAadded to 

### the 

## customers process orcooling 

## water to 

# maximumof 

# ppm measured as total 

### chlorine 

## and that tell 

### users

# how to 

### neutralize 

## any 

# MCAdetected in 

### effluent In other

# words by registering 

## Busan 

# 1215 

# EPAwasable to 

### ensure
that 

### the

# MCAproduced with Busan 1215 was used safely specifically so as to 

### prevent 

## unapproved residues in

## food packaging and aquatic toxicity

## from residues in 

### effluent 

## Conversely 

# EPA has not evaluated the use 

## ofany unregistered 

# ammonia product to 

## produce

# MCAand has 

## no assurances 

## with respect to 

## any residues 

## of

# MCA in

## food packaging or 

## waste water 

# Thus unnecessaryand potentially adverse risks to 

# human health 

## andthe 

## environment remain For

# exampleNalcos OxiPRO Feed System releases 10-12 

# ppm of

# MCA measured as total 

### chlorine to 

### the 

## customers process 

## water which is

## more than twice the concentration 

## of

# MCA permitted 

## by

# EPA on

# Buckmans end-use 

# ammonia label

# Ex at 

# IV Ammonia does not seQuester 

## orrelease 

# chlorine and is

## notan 

# adiuvant ammonia does react 

## with 

# sodium hypochlorite to

## produce an entirely 

# new active 

## intredient 

# MCAwhich has distinct properties 

# from hypochlorous acid Nalco identifies 

### chemical substances 

## cyanuric acid diethanolamine disodium zinc ethylene 

## diamine tetracetate 

## dehydrate 

# ammoniumcarbamate and product types stabilizers sequestrants synergists that 

### allegedly 

# perform similar

## functions as

# ammonia but are not registered 

## implyingthat 

# EPA has acted irrationally in 

### registering 

## Busan 1215 

# Nalcos Petition

at 

# 12-15 Nalcos reasoning is 

### flawed 

## and misleading 

# however because 

# ammonia is -9-

### precursor 

## of

# MCA specifically reactant in its 

### formation not 

## an adjuvant 

# Ammonia reacts 

## withsodium hypochlorite in

## water to 

## form different 

## chemical 

# compound 

# MCA and both the 

# ammonia and the 

## sodium hypochlorite are 

## consumed in 

### the reaction 

## Conversely the chemical substances 

## and products that 

## Nalco identifies 

## do not reactto 

## form different 

## chemical 

# compound

or

# compounds and remain chemically 

## unchanged Nalco perpetuates self-serving fiction that 

# ammonia merelysequesters 

# and later releases 

# chlorine hypochlorous acid 

# Nalcos Petition at 

## 6-7 11-12 

# Ex at 

# Ex at 

### This characterization is false for 

### several 

## reasons First the use 

## of

# Nalcos OxiPRO Feed System unmistakablyproduces

# MCAwhich 

# EPA recognizes as 

### separate 

## and distinct 

### active ingredient 

## from chlorine 

## Oxidants 

# Manual at

# 2-30

# 6-1 Second chemical reaction takes place 

# when Nalcos ammonia product is

# used The reaction 

## produces

# MCA and possibly other

## chloramines Third the 

## chemical reaction that 

## produces

# MCA is 

### not considered reversible In other

# words
once the 

## chloramine 

# or-amines have formed through chemical reaction they cannot break 

# down readily into orotherwise 

## produce 

# ammonia and hypochlorous acid/hypochlorite ions.3 

## Furthermore 

# MCA and chlorine 

## have different 

### chemical 

## and antimicrobial properties 

## and such differences favor

# MCA over chlorine in certain 

### applications 

## For

# example

# MCA is 

### increasingly 

## used as 

## secondary disinfectant in 

### drinking 

## water distribution 

## systems because it 

### decays 

## more slowly 

## and produces substantially 

## fewer disinfection byproducts than chlorine 

## Oxidants Manual at 

## 6-10 6-27 to

# 6-29 

# MCAand chlorine also

## have different 

## mechanisms bywhich they inactivate 

## microorganisms 

# MCA reacts 

### with four 

## amino acids 

## cysteine cystine 

## methionine and



# MCAcan hydrolyze very slowly in process that can 

### form chlorine 

### Also making solution of

# MCAstrongly acidic 

# pH 1-2 can cause the

# MCAto 

### decompose and generate 

### some chlorine 

### Under the conditions under 

### which 

# MCA is used forwater treatment 

### no such hydrolysis or decomposition should 

### occur

-10-

## tryptophan and the 

## mechanism ofinactivation is 

### thought to 

### involve inhibition 

## ofproteins or protein 

## mediated processes such as 

### respiration 

## Oxidants 

# Manual at

# 6-12 Also

# MCA typically requires 

## multiple hitsupon bacterial cells 

### before cell 

### death 

## Oxidants 

# Manual at

# 6-12 By
contrast chlorine is 

### capable 

## ofproducing lethal 

### events at

### ornear the cell

# membrane and of affecting 

# DNA Oxidants 

# Manual at

# 2-35 In bacteria chlorine adversely affects cell 

### respiration transport 

## and possibly

# DNA activity 

## Oxidants 

# Manual at

# 2-35 Accordingly 

# MCA
does not kill 

## microorganisms byreleasing chlorine or

# MCA would have the 

## same antimicrobial properties as 

### chlorine 

## and it 

### does 

## not Furthermore 

# EPA has 

## determined that 

# MCA does not control as

# many different 

## microorganisms as 

### chlorine 

## and hypochlorous acid 

## Oxidant Manual at

## 2-36 to 

## 2-39 6-13 to 

# 6-15 Accordingly 

# Nalcos unqualified antimicrobial claims for its

# OxiPRO Feed System 

# Ex Ex imply level 

## ofmicrobial control that is 

### not provided 

## by

# MCA The only

# way to 

### clearlyseparate appropriate claims for

# MCA fromthose for 

### chlorine 

## and hypochlorous acid isto register 

# Nalcos ammonia and all 

### other

# ammonia for

## water treatment 

## and to 

### properly attribute 

### the antimicrobial claims for

# MCA to 

### such 

# ammonia registrations 

# EPAshould promptly deny 

# Nalcos Petition to 

## revoke 

# Buckmans ammonia retistrations 

## because the 

# Atency has properly retistered 

# Buckmans ammonia as 

## precursor of

# MCA for

## water treatment 

# As explained in 

### section II 

# above scientific 

### analysis

## of

# howammonia is

## used in

# Nalcos and

# Buckman proprietary 

## watertreatment 

## systemsshows unambiguously that

# MCA is 

### the active ingredient released 

## bythese 

## systems for

## watertreatment 

# As explained in 

### section III 

# above

# MCA is 

### too unstable to 

## be bottled 

## and sold as 

### marketable 

## commodity 

# and therefore is 

### universally 

## produced in 

### situ 

## Accordingly there are 

## no active orinactive 

# EPA registrations 

### of 

# MCAbywhich 

# EPAcan control the potential risks 

## from using

# MCAwhich include 

## unapproved residues in 

## foodpackaging and aquatic toxicity 

# To address these potential risks 

# EPA must 

# 11register 

## one or

## both ofthe 

## immediate precursors 

## of

# MCAsodium hypochlorite or

# ammonia With one registrant 

# Buckman one end-use registration 

# Busan 

# 1215 and no other pesticidal


## uses 

# ammonia is

### the best

## and only practical 

### candidate for 

### registration 

## which 

# EPA has recognized 

## by registering 

# Buckmansammonia products after carefttl 

### consideration 

## Furthermore as 

### explained in 

### section 

## IV

# above ammonia is 

### precursor 

## of

# MCAnot 

## anadjuvant 

# Ammonia reacts 

### with 

## sodium hypochlorite to 

## produce 

# new active ingredient 

# MCAwhich has

distinct 

### properties 

## fromhypochlorous acid this 

### reaction is

### not reversible 

## and

# ammonia does not sequester orrelease 

## hypochlorous acid 

# Thus 

# EPAsdecision to register 

# ammonia as 

### precursor 

## of

# MCAhas 

## no relationship to 

### the

# Agencys past orpresent regulatory handling 

## ofthe adjuvants
identified 

## by

# Nalco For all 

### ofthe foregoing 

## reasons 

# EPA properly granted registrations to 

# Buckman ammonia products and

# Buckman respectfttlly 

### requests that 

### the

# Agency deny Nalco Petition request to 

## revoke 

# Buckmans registrations 

# VI EPAshould immediately prohibit further distribution 

# and sale of

## unreuistered 

# ammonia for

## water treatment because the 

## continued sale 

### of

## unreuistered 

# ammonia to 

### the 

# samecustomers for

# and forthe 

# same uses 

# as

# Buckmans reuistered 

# ammonia presents 

## unnecessary 

# and potentially 

## unreasonable risks to

# human health 

# and the 

# environment contradicts 

# and undermines the 

# Auencys proper reuistration of 

# Buckmans ammonia and unfairly 

# damaues the 

## commercial value of

# Buckmans retdstrations
If

# EPA has properly registered 

# Buckmans ammonia as 

### precursor 

## of

# MCA for

## water treatmentthen 

# Nalcos ammonia also

## mustbe registered 

## which Nalco has 

## acknowledged by its 

### violent reaction to 

### the registration 

## of

# BCMW and Busan 

# 1215 As demonstrated in 

### section II 

# above Nalcon 60620 and Busan 1215 are 

## commercially interchangeable 

## Both products are 

## used bythe 

## same people for 

### the 

## same purpose 

# namely as 

### source of

# ammonia to 

## produce

# MCA in
situ for

### the disinfection 

## of industrial 

## water 

# Nalcos label 

### description 

## ofNalcon 60620 as 

### stabilizer for 

### active chlorine 

## sources is 

### dishonest in scientific 

## termsbecause it 

### does not 

## match the 

## chemical reactions that 

### actually occur in 

### the

# OxiPRO Feed 

# System -12-

# By letter 

### dated 

## February 

# 2008 attached hereto as 

### Exhibit 

# however 

# EPA has 

## temporarily accepted 

# Nalcos erroneous description 

## ofNalcon 60620 as 

### chlorine stabilizer 

## pending furtherinvestigation Since then 

## seven months and counting 

## Nalco has aggressively 

## marketed and soldunregistered 

# ammonia to 

## commercial users

# who continue to 

## produce and use 

# MCAwithout 

## any

# EPA oversight specifically while 

## Nalco has not 

## had to 

## demonstrate and

# EPA
has not 

## hadthe opportunity to 

## confirm that 

### the use 

## ofNalcon 60620 to 

## produce

# MCA adequately addresses the potential 

# human health 

## and environmental risks 

## fromthe use 

## of

# MCA Meanwhile Buckman cannot explain

# EPAs differential 

### treatment 

## ofNalcon 60620 and Busan 1215 to 

## customers and because these products are interchangeable in

### the 

## marketplace 

# many customers 

# now perceive 

# EPAs registration 

## ofBusan 1215 as 

### pointless 

## and unnecessary an impression that 

### has 

## been reinforced 

## by

# EPAs failure to 

### date to 

### require the registration 

## ofany 

# ammonia products for

## water treatment otherthan 

# Buckman inaction not only contradicts 

# Buckmans ammonia registrations it 

### unfairly 

## damages their 

## commercial value Accordingly the longer that 

# EPA discriminates against 

# Buckman by requiring the registration 

## of 

# Buckmans ammonia while allowing all 

### competitive 

# ammonia products for

## water treatment to 

## be sold without registration the better it 

### serves 

# Nalcos desire to 

### delay registration the harder it is
for

# Buckman to 

### salvage its 

### considerable investment to register 

# ammonia and the longer the public goes without assurance that

# MCA is

### being 

## used safely 

## which is

## provided only

## by

# EPAs registering all 

# ammonia for

## water treatment 

## Furthermore Nalco has 

## had more than 

## enough time

to register 

# ammonia and has 

## chosen instead to 

### focus solely

## on petition 

### process to 

### delay registration for as 

### long as 

### possible while it 

### continues to 

## compete unfairly against 

# Buckman in 

### the marketplace 

## with unregistered 

# ammonia that reflects 

## no regulatory costs 

# Thus 

# EPA should not 

## reward 

# Nalcos delaying tactics 

## and opportunism with any additional 

## time to 

### register 

## Forall 

## of

-13-

### these 

## reasons 

# Buckman respectfully requests that 

# EPA immediatelyprohibit further distribution 

## and sale 

## ofunregistered 

# ammonia for

### use in

## watertreatment 

# VII Conclusion 

# Buckman has 

## demonstrated that its

## and

# Nalcos ammonia products are 

## used in 

### the 

## same 

# wayas precursors to 

## produce

# MCA bythe 

## same industrial 

### users 

## primarily pulp 

## and paper mills but also facilities 

## with industrial 

### cooling 

# systemswho perceive the 

## two products as 

### interchangeable for

## water treatment applications disinfection 

## ofmill

## and industrial 

### cooling 

# water Buckman has 

# shown that its

## and

# Nalcos ammonia products 

## do not 

## sequester orrelease 

## hypochlorous acid 

## and are not 

## adjuvants and that 

# EPA has the authority to register 

# ammonia products as precursors 

## of

# MCA since the registration 

## of

# MCA itself for

## water treatment is 

### impractical 

# Buckman also 

### has 

# shown that 

### onlythe registration 

## ofall

# ammonia products for 

## watertreatment will 

### ensure that 

# EPA has evaluated 

## any potential risks 

## fromthe use 

## of

# MCAand
restore level 

### playing field in 

### the marketplace for industrial 

## water disinfection 

## Forthese



## reasons as 

### explained in this 

### petition 

# we renew our request that 

# EPA deny

# Nalcos Petition 

## and immediatelyprohibit further distribution 

## and sale 

## ofunregistered 

# ammonia for

## water treatment 

# Wewelcome an opportunity to 

### discuss our petition 

### with

# EPA

-14-

### Respectfully 

## submitted



# Dated September 2008 Michael Boucher 

# MCKENNA LONG ALDRIDGE 

# LLP 1900 Street

# NW Washington 

# D.C 20006 

# 202 496-7729 Counsel to 

# Buckman Laboratories 

## Inc

-15-

# EXHIBIT

## DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration 

# No FDA2008F0462 Zentox 

# Corp Filing of 

## Food Additive Petition 

# AGENCY

Food and Drug 

# Administration 

# HHS ACTION

Notice SUMMARY

The Food and Drug Administration 

# FDA is 

## announcing that Zentox 

# Corp has filed petition proposing that the food additive regulations be amended to provide for the safe use of 

## monochloramine as 

## an antimicrobial agent in poultry process chiller 

# water DATES Submit written or electronic comments on the 

# petitioners environmental assessment by date 30 

## days after date of 

## publication in the Federal 

# Register ADDRESSES

Submit written comments to the Division of 

## Dockets Management 

# HFA3OS Food and Drug 

# Administration 5630 Fishers 

# Lane 

# rm 1061 Rockville MD 

# 20852 Submit electronic comments to 

# http//www.regulations.gov FOR FURTHER INFORMATION 

# CONTACT

Judith 

# Kidwell Center for Food Safety and Applied Nutrition 

# HF5265 Food and Drug 

# Administration 5100 Paint Branch 

# Pkwy College 

# Park MD 

# 207403835 3014361071

SUPPLEMENTARY 

# INFORMATION Under the Federal 

# Food Drug and Cosmetic Act 

# sec 409b 21 U.S.C 348 notice is 

## given that food additive petition 

# FAP 8A4775 has been filed by Zentox 

# Corp c/o Burdock 

# Group 801 North Orange 

# Ave suite 

# 710 Orlando FL 

# 32801 The petition proposes to amend the food additive regulations in part l73Secondary Direct Food Additives Permitted in Food for Human Consumption 

# 21 CFR part 

# 173 to provide for the safe use of 

## monochloramine as 

## an antimicrobial agent in poultry process chiller 

# water The potential environmental impact of 

## this petition is 

## being 

# reviewed To encourage public participation consistent with regulation issued under the

## National Environmental Policy Act 

# 40 CFR 

# 1501.4b the agency is 

## placing the environmental assessment submitted with the petition that is 

## the subject of 

## this notice on public display at 

## the Division of 

## Dockets Management 

# see DATES and 

# ADDRESSES for public review and 

# comment Interested persons may submit to the Division of 

## Dockets Management 

# see ADDRESSES written or electronic comments regarding this 

# document Submit single copy of 

## electronic comments or two paper copies of 

## any mailed 

# comments except that individuals may submit one paper 

# copy Comments are to be identified with the docket number found in brackets in the heading of 

## this 

# document Received comments may be seen in the Division of 

## Dockets Management between 

# a.m and 

# p.m Monday through 

# Friday FDA will also place on public display any amendments 

# to or comments 

# on the 

# petitioners environmental assessment without further announcement in the Federal 

# Register 

# If based on its 

# review the agency finds that an environmental impact statement is 

## not 

# required and this petition results in 

# regulation the notice of 

## availability of 

## the 

# agencys finding of 

## no significant impact and the evidence supporting that finding will be published with the regulation in the Federal Register in accordance with 21 

## CFR 

# 25.51b Please note that on January 

# 15 2008 the FDA Division of 

## Dockets Management Web site transitioned to the Federal Dockets Management System 

# FDMS FDMS is 

# Government-wide electronic docket management 

# system Electronic comments or submissions will be accepted by FDA only through FDMS at 

# http//www regulations 

# gov
Dated August 

# 27 2008 Laura 

# Tarantino Director Office of 

## Food Additive 

# Safety Center for Food Safety and Applied 

# Nutrition 

# Doc

# 08 Filed

# 08 845 amBILLING CODE 416001S



# Doc 2008-20293 Filed 08/29/2008 at 

# 845 

# am Publication 

# Date 09/03/2008

# EXHIBIT

# NALCO Nalcon60620
Stabilizing solution for

### use with active chlorine 

### sources Nalcon 60620 is unique stabilizer foractive chlorine sources 

### Nalcon 60620 stabilizer minimizes the decomposition of active chlorine caused by the high chlorine demand ofpaperrnaking waters 

### When used as directed 

### Nalcon 60620 stabilizer reduces the quantity ofactive chlorine that reacts with dissolved and suspended organics thereby maximizing compatibility with sensitive process additives By reducing interactions with sources ofactive chlorine demand including sensitive process additives such as optical brighteners retention aids and %vet and dry strength aids 

### Nalcon 60620 optimizes chlorine stabilization 

### Nalcon 60620 is intended foruse in process waters used in the manufacture ofboth food and non-food paperboard PRINCIPAL 

### FUNCTIONiNG 

## AGENTS Ammonittm sulfate 20.0% 

### CONSTITUENTS INEFFECTIVE AS SPRAY ADJUVANTS 8i0% TOTAL 100.0% 

# KEEP

# OUTOF

# REACHOF CHILDREN 

# WAThNING

FIRST AID IF TN EYEs Hold eyes open and rinse slowly and gently with water for 15-20 minutes Get medical attention if irtItation occurs and persists IFONSKIN Rinse skin immediately with plenty ofwater for 15-20 nrinutev If symptoms develop teek medical attention IFSWALLOWED Call poison control center ordoctor immedintely fortreotment advice Have person sip glass of water Do not induce vnmiting without medical advice Do not give anything by mouth to an unconscious person IFINHALED First aid is normally not required Remove to fresh air treat symptomatically If symptoms develop seed medical advice NOTE TO PHYSICIAN Basnd on the individual reactions of the patient the pltysiciansjudgmeat should be used to control symptoms and clinical condition Have the prnduct container or label with you when calling Poison control Center ordoctor orgoing for treatment 

# PRECAUTIONARY STATEMENTS HAZARDS TO

# HUMANS AND DOMESTIC ANIMALS Warning May cause irritation to the eyes and skin 

### Do not get ineyes on skin oron clothing 

### Db not take internally Use with adequate ventilation Rinse thoroughly with Water after handling Remove contaminated clothing a6d wash clothing before reuse Wear protective eyewear goggles face shield or safety glasses protective clothing and protective gloves rubber chemical resistant when handling 

# STORAGE 

# AND DISPOSAL Store in suitable tightly closed labeled containers In case of spill soak up spill with absorbent material and clean contaminated surfaces with water or aqueous cleaning agents Wastes resulting from the use of this product are not subjected to federal regulation Consult state or local regulations for any additional handling treatment or disposal requirements For disposal contact properly licensed waste treatment storage disposal orrecycling facility 

## DIRECTIONS 

# FORUSE Nalcon 60620 stabilizer can be mixed with source of active chlorine prior to paper machine waters oradded to system currently treated with active chiorines

If

### Nalcon 60620 stabilizer is pre-blended with the active chlorine source the mixture should then be added to process Water streams at orimmediately priorto point of sufficient mixing such as the main water inlet the fan 

### pump or wire pit Use metering pump of sufficient accuracy on each liquid piped with back-flow prevention to produce the liquid blend using an in-line-mixing device such as static mixer 

## DOSAGE For optimal stabilization add Nalcon 60620 stabilizer to active chlorine at molar ratio between 11 and 

## 21 For food contact use no more than needed to achieve the desired effect 

## NOTFOR USE IN FISH 

### BEARING 

## WATERS

Revised 07/25/2007 THIS 

## PRODUCT IS

## NOT REGULATED DURING TRANSPORTATION Nalco Company 1601 West Diehi Road Naperville IL 60563-1198 

### EMERGENCY PHONE

## NO800 424-9300 

### NET CONTENTS 

### SHOWN ELSEWHERE ONCONTAINER

# NALCO

LOT

# NO DENSITY NETWEIGHT 9.1 lb/gal 

# FDA 21 

# CFR 176.170 

# Components of

## paper and paperboard in 

### contact with 

## aqueous and fatty

## foods and 21 

# CFR 176.180 

# Components of

## paper and paperboard in 

### contact with dry

# foods 21 

# CFR 176.210 Defoaming agents used in 

### the 

## manufacture of

## paper and paperboard Hazardous ingredients 

# maybe listed 

## underState 

## Right-to-Know 

# KOSHER This product 

## has beep certified 

## as 

# KOSHER/PAREVE for

## year-rounduse 

# INCLUDING 

# THE PASSOVER 

# SEASON bythe

# CHICAGO RABBINICAL 

# COUNCIL



# NFPA HMIS Proprietary 

# Halogen Stabilizer

ATTENTION For

## more information refer to

### the material safety 

### data

## sheet Empty containers 

# maycontain residual 

### product 

# DO NOT reuse containers unless properly 

### reconditioned 

# CAUTION Maycause irritation 

# with 

# prolonged contact 

# Do not get in

# eyeson skin on clothing 

# Do not take internally 

# Use with 

# adequate ventilation In 

# case of 

# contact with

# eyesrinse 

# immediately with plentyof

# water and seek medical 

# advice After contact with

# skin

# wash immediately with plenty of

# water 

# Wear suitable protective 

# clothing 

# STATE RIGHT-TO-KNOW nnI4 IDr.snras4r ii

# Oi9ciflk cail

.. 

## opi ItLGIf



# KOSHER

Degree ofHazard Extreme High Moderate


# MAI1LINiLS.A Nalco

# Company -Plant 

## 140 Eliwood City 

## North Plant 

## 125 Nalco

# WayELLWOODCITY

# PAUSA 16117 724-752-6200 Material 

## 60620.91 Generated 10/29/2007


# U.S

# DOTShipping 

# Name PRODUCT IS

# NOT REGULATED DURINGTRANSPORTATION

# EXHIBIT

# NALCO
Technology 

# PROPOSAL 

# OxiPROTM

May 2008

duction 

## Leader


# Thank you forthe 

## opportunity to 

## review our

# OxiPRO Deposit Control 

# Technology Please find 

## enclosed ourproposal outlining

# how

# OxiPRO can benefit

# th

Nalcos OXiPROTM Deposit Control 

## Technology offers

## improved paper machine efficiency 

## by controlling microbial-based deposits 

# through Innovative chlorine stabilizing 

### chemistries



## combination of

# new and unique proactive 

## monitoring tools Application expertise strategies to 

## maximize performance Resulting 

## in Improved system stability 

# Reduced treatment cost 

# Reduce sheet defects 

## Increased 

# uptime 

# Wethank 

# you once again for this 

### opportunity to

# work with 

# youand look forward to discussing this 

## proposal with 

## you in

# more detail 

## Sincerely GarydeVries District 

## Account 

# Manager P18 Nalco

# Company cc

# OxiPRO

# Dc

Confidential

# NALCO OxiPRQ Ox1PROTM Deposit Control 

# Technology 

# PROPOSAL
Introduction 

# The following is 

## proposalfor

# OxiPRON microbiological control 

## program for 

## Nalcos OXiPROTM Deposit Control 

## Technology is 

### stabilized

## oxidant

# program It 

## takes 

# an oxidant that 

## has been blended with caustic 

## on site

# and stabilizes it

### with 

## ourunique chemistry specially 

## designed feed system insures 

## the oxidant is 

## completely stabilized 

## Nalcos online microbiological 

## monitoring unit provides 

## Continuous real 

## time resultsforproactive control 

## Nalcos 

# OxiPRO innovative oxidant stabilizer 

## program can

# rovidewith 

## these benefits 

# The mosteconomical microbiological 

## treatment program forneutral conditions Consistently 

# meet or

## extend boil 

## outtarget 

## periods Greatersystem assurance through online 

## monitoring Longer 

# equipment life 

# dueto less 

### corrosive 

## chemistry Improved runnability 

## ofmachine and converting 

# dueto less holes/deposits creating 

## sheet defects 

## and breaks 5pc1fkJotential 

# Befits for

# th Mill 

## Qpeiatioj 

# Innovative chlorine stabilizer 

## Nalco has several stabilized oxidants that 

## can be utilized 

### for

## your

# system Testing 

# and Nalco experience has 

# shown that 

## Nalco

# 60620 Is

# mosteffective in 

## your

# system 

# ImprovedSilo

# treatment strategies to 

# minimizebiomass Nalcos OxiPROTM program creates stabilize 

### oxidants that 

## provide extended control 

## even in 

## the

# mostdemandingsystems Nalco will

# employ slug

## feed to help 

## improve system cleanliness while minimizing 

## adverse effects of

## high free chlorine residuals 

# on machine performance and paper quality 

# Real-timemicrobial 

# monitoring for

# greatersystem assurance 

# and optimization This 

## program 

# comes with 

## Nalcos 

# new patent pending online 

## continuous microbiological 

## monitoring Unitfor

# optimum proactive 

## control Real time

# MB monitoring 

## allows for

## immediate response before system upset can occur

Con fidenflal

# NALCO OxiPRO Deposit Control 

# Technology 

# PROPOSAL improved Machine Efficiency Eliminating biological 

## upsets wHI help 

## improve 

# wetend stability 

## Improved machine 

# and converting runnability

# due to less microbiological holes/deposits 

## Program Objectiveand 

# uccess Criteria 

## Be safe 

# and reliable at all 

## times Maintain clean 

## paper machine system with 

# no microbiological 

## deposits Provide timely 

## monitoring data forproactive 

## control 

# Have no negative impacts 

# onwet end chemistry Provide service 

# needed to 

## maintain the 

# program in 

## peak performance and 

# document the results 

# ProgramCost The program would be billed 

# on price/ton 

## basis Nalco

# 60620 and Nalco 

# BL409 $2.35/swt Bleach 

# 12.5% Supplied 

# by in 

### totes or bulk 

## This pricing also 

## includes 

# One feed systems capable of feeding addition 

## points 

# OneOXiPROTh Monitoring unit Nalco service 

# and support

# program Nalco maintainsownership ofthe 

## feed

# and monitoring 

# equipment

water softener if

# needed would provide the 

## following 

# din water for final 

### dilution Assistance installing 

## the

# equipment Electrical 

# and piping 

## connections to

## the units 

# and feed points Wireless 

## orEthernet connection for

## monitor information transfer 

## Bleach in 

### totes 

## orbulk 

## storage

# or 

# Diofl Nalcos OxiPROIM Deposit Control 

## Technology program for includes 

## feed 

# equipment monitoring 

# equipment stabilized oxidant 

# program and on-site 

## service This discussion will 

## provide details 

# and supporting information forthe 

## proposed 

# program Stabilized 

# Oxidant 

# Chemistry OXiPROTh Technology combines stabilizer 

# Nalco 

# 60620 blended on site 

## bythe 

## feed skid with 

## commercially available 

# 12.5% sodium hypochlorite 

# and

# NaOH

Confidential

# 1NALCO OxiPRO OxiPRODeposit Control 

# Technology 

# PROPOSAL The stabilizer is

## determined by screening performed at

## the Nalco Technical Facility utilizing 

## yourfurnish 

# The stabilizerof choice 

## from the testing is

## Nalco

# 60620 It

# showed to 

## have the 

## bestlow concentration kill 

## aswell 

## asthe best high concentration persistence 

# when compared with the 

## otherproducts This 

## product has

# shown to

## be effective in 

### similar

## environments both in 

### the lab 

# and in mill

## experience This 

## product is 

### currently 

## being utilized in 

### multiple tissues 

# and towel mills 

### with great

## success 

# OxiPROFeed System The feed skid 

## blends the chemistries in 

### the appropriate ratios 

# and delivers the stabilized oxidant to the 

## paper process Below is 

### simple flow 

## sheet of the feed skid 

## operation 

# The feed skids 

## can be designed to 

## run in 

### slug configuration or 

## continuous operation For

## the system

# we recommend utilizing 

### slug 

## feed operation to assure 

## proper

# córage and cost effectiveness



# Addition Points Nalco 

# recommends the following addition points for

# th operation These points 

## could change or

## be reduced pending system requirementsas the 

## program is

## optimized 

# TM Silo 

# TMShower Water 

# Tank



# 125% Sodium Hypochlorite 

## N-60620 Stabilizer



### Confidential

# NALCO OxiPROM OX1PROTh DepositControlTechnology 

# PROPOSAL OXlPROTMOn-Line Monitoring Nalcos on line 

## monitor is

# an important part of this

# system This unit

# was developed byNalco to 

## provide real 

### time information 

# and true proactive control 

# The unitcontinuously 

## monitors four 

## system conditions Microbiological activity level 

### Overall fouling rate 

# ORP 

# 4.pH The unit

## monitors 

# head box orwhitewater system side 

## stream and the 

## sample can 

# be returned 

## back to 

## the process 

# An internet 

## connected computer or cell 

# phone can access thedata Immediately eitheron-site or 

## remotely Target control 

## ranges can be setfor

## each parameter and the unit will 

## send alarmsto 

# computer or

## by cell 

# phone text 

# message alerting 

## the local 

# team to

## take action 

## as required 

# The following is 

### actual 

## data from the 

## monitorthat 

## Nalco representative 

## used to 

## prevent lost 

## time

# upset Similar incidents atthis mill 

## before themonitor

# was installed 

## caused six

## hours of lost

# time

50 

# 40 .30

20

10

WI/Ce W2/C6 WI/Ce 9/4/06 

### woe 9/6/08 9/7/06 9//CG 9/0/00 9/10/06 Wii/66 9/12/08 9/10/06 9/14/06 9/16/08 

### similarIncident last 

## yearcaused hours of

# downtime andan unscheduled boY/out

Confidential

# 1NALCO OxIPRcT OxiPRO Deposit ControlTechnology 

# PROPOSAL
Traditional Microbiological 

# Monitoring In addition to 

## the online 

## monItoring Nalco 

## performs standard microbial 

## surveys using plate 

## counts 

# and chlorine residuals 

## asrequired 

# ATP monitoring Is 

### also 

## used to help calibrate 

## the monitortarget control 

## ranges and troubleshooting variations in 

## theprocess 

# Nalco Service 

# Program Ourexperienced local 

## Nalco

# team will 

### provide regular service forthe 

# program Ourservice 

# program will 

## be tailored to

## your

# needsand 

# mayinclude Nalco representative in 

### the mill 

# On call 

## coverage 

# 24 hours days 

# week Regular maintenance and repairof

## thefeed 

# and monitoring 

# equipment Bl-weekly reports 

## summarizing program performance 

# Weekly machine Inspection for

# MBdepositswith 

# moredetailed inspection during 

# outages Systemtrouble 

## shootingasrequired 

# We look 

## forward to discussing 

## thevalue 

## Nalcos 

# OXIPROTh Deposit Control 

## Program can give 

# Wewant to 

## thank 

# you for

## theopportunity to service 

## your facility 

# and your requestforthis 

## proposal

Confidential

## Questions onNalco 

# OxiPRO System 

# What are the reactions that create the 

### active 

## ingredient 

# The stabilizers in 

### the

# OxiPRO system 

# when mixed with bleach in 

### specified ratio 

## form unique stabilized 

### chlorine intermediate priorto 

### being introduced to 

### the paper 

# makingprocess The stabilized 

### chlorine intermediate ensures that 

### the chlorine is

### not 

## consumed bythe organic 

## components ofthe 

## papermaking process such as 

### fiber 

## and filler 

### This increases the oppofluthtj for

### the stabilized 

### intermediate to 

# come in

### contact with planktonic bacteria orbacteria in 

### biofilm 

## andthen 

## hydrolyze the chlorine 

## back to 

## hypochlorous acid --the 

### biocide 

# What is 

### the 

## mechanism ofdisinfection Disinfection is

## completed through the action 

## ofhypoehlorous acid 

## onbacterial 

# membranes and oxidation 

## ofsulthydryl

## groups 

# What species 

## ofchlorine are

## present Hypochlorous acid is

### present in the 

### beginning 

## and the 

## end ofthe stabilization 

## process 

# What are 

### the 

## by-products.SpentWaste

# Products Sulfate in 

### the case 

## of

# 60620 Hydantoin in 

### the case 

## of

# 03P0125 minororganic salt

### inthe case 

## of60615 

# What are 

### the health hazards 

## ofthe active 

## ingredient The active ingredient is

## hypochlorous acid

# HOd Thehealth hazards 

## of

# HOC1 are well 

# known an 

# documented

# EXHIBIT

# PM BiocideTrial 

# Operator

# Overview

June232008

# PresentationOutline werunning this

# trial 

# Why did

# wechose

Trial 

# Plan details Logistics 

# MostImportant Safety 

# Whyare

this

# program

# Whyare

# we runningthis

# trial Opportunityto

# ImproveOperations Cleanerwatersystem 

# Fewersheet

# breaks defects

# and rejects 

# Reduced downtime Increased 

# machinespeed 

# Bottom line Increase safety if

# the

# program can eliminateboilouts 

# Increase 

# machine efficiency if

# reduce 

# downtime Betterqualityof less

# holes defects

# and sheet

# breaks

# Whydid

# wechose this

# program Meetsourgoals Better 

# monitoringtools 

# Newchemicaltechnologywith

# OxiPRO Direct

# comparisonwith 

# other

# programs Boilouts

# only Stabilized 

# Chlorine 

# OxiPRO 

# DBNPA

# Current

# Program
What are 

# our goals for biocide 

# program Safety 

# No wetend deposits orbreaks related to 

## microbiological 

# No sheet quality 

## issues 

# No boilouts/Washups/Headbox deposits 

# No impact 

# on other chemistries 

# Current Microbiological 

# Program Current biocide 

# program doesnt attack slimeformers 

# on and

____and no program on Using Bleach 

# DBNPA Monitoring with 

# weekly plate 

## counts 

# and

# ORP Boilouts

# when problem occurs 

# Other pH andtemp range is

## good for

### filamentous 

## and slime formers 

## Lower free 

### chlorine in mill 

### freshwater 

# .Sppm Trial will 

# help determine the 

# Program to

# meetourgoals on 

# PM5 Better data analysis better 

## decisions optimization

# Better

# Monitoring Current Monitoring Manualsampling 

# Noformal 

# program Time lag for

# data Reactive to

# problemson the 

# maôhine Platecounts 

# and

# ORP only 

# Monitoring during Trial 

# Automatedand Manualsampling Formal monitoring

# program Realtimedata forbiofouling 

# and

# ORP Ability to

# be Proactive to 

# prevent 

# problems Alarm if

# problemsoccur

# Bioflim

# Control Situation 

# without Stabilization 

# The free chlorine is 

### lost 

# by reacting with the surface ofthe bioflim



# Situation with Stabilization 

# The chlorine is 

## released inside 

## the biolllm 

# matrix Stabilizer 

# NaOCI

# Trial 

# Plan Details TmeIine June24 Monitoring

# Only

# Boilouts 

# Aug Sept 

# OxiPRO months Oct 

# Nov 

# DBNPA months FeedStrategy

# and Application

# FeedStrategy

# andApplicauon

OxIPRO Location 

# and Estimated 

# Dose Machine Silo

# Based on

# 65000 gal 12 

# ppmas total 

# chlorine 

# 65

# GPD60620 38

# GPD Mill 

# Bleach 45 mm 

# slugs times 

# perday Eliminate 

# headbox and approach system biological 

# deposition 

# ShowerWaterChest

# Based on

# 40000 gal 10

# ppm as total 

# chlorine 

# GPD60620

# 15GPD Mill 

# Bleach 10 mm 

# slugsonce per

# day Provide kill 

# and preservative for

# shower waterand mist

# areas

# Logisfics
Locations of

# the

# chemicals

# andfeed 

# system 

# Temporary trial 

# set

# up In 

# the

# basement bypressure weir 

# Move existing totes to 

# otherlocations 

# Longtermplans 

# Hard piped to 

# existing

# systems Monitoring 

# system details 

# Feedsystem details 

# Component of

# thefeed 

# system

10

# OxIPROMonitoring

11

# OxiPROTM

# Feed

# System

Fully

# automated to

# ensuresafety

# and quality of

# product 

# DCSconnections available 

# Start/stop flow rates interlocks etc 

# Push water tie 

# in automatic flush 

# water

# sequence All

# mixing 

# and splitting 

# doneon skid 

# Temperaturemonitoring to

# ensure proper ratios

# and safety Ability 

# to

# shut

# downone addition point 

# while running 

# others Nalco

# owned and maintained

12

# Componentwith 

# Drive

# Water

Basic Configuration 

# Component with drive 

## water

13

# Safety Chemical hazardsreview 

# Loading 

# and unloading safety Temporary operations 

# SOPto refill 

# totes 

# Longterm_hard piped 

# Nalco repto

# handle refills

# PMoperator totruck totes 

# SOPreview 

# Feedsystemsafety Temporary piping 

# tube in

# tube 

# Othersafety

# concerns

14

# EXHIBIT

# UNITED STATES ENVIRONMENTAL PROTECTION 

# AGENCY WASHINGTON D.C 20460

4L

# PRO

mu 

## iyy OFFICE OF 

## UUL PREVENTION PESTICIDES 

### AND TOXIC 

### SUBSTANCES 

# Mr Carl 

# Watson Ph.D Sr Regulatory Toxicologist 

# Buckman Laboratories Inc 

# 1256 

# McLean Blv 

# Memphis 

# TN 38108 Subject 

# Busan 1215 

# EPA Registration 

# Number 1448-433 Application 

# Dated June 2007 Received Date June 

# 11 2007 Dear

# MrWatson The following label revisions 

## submitted in 

## connection with registration 

# underthe Federal Insecticide Fungicide 

# and Rodenticide Act

# FIFRA as

# amended is

# acceptable 

# Proposed Labeling 

# New Use Industrial 

## water 

# systems General

# Comment Should youhave any questions concerning this letter 

## please contact Drusilla 

# Copeland at

# 703 308-6224 or

# Velma Noble

# 70308-6233 Sincerely



# Velma Nobel Product 

# Manager 

# 31 Regulatory 

# Management Branch AntimicrobialsDivision 

# 7510P Enclosure 

# Stamped Label

Internet Address

# URL http//www.epa.gov Recyded/Recyclable Printed with Vegetable Oil Based Inks on Process Chlorine Free Recycled Paper 

### MInimum 80% Postconsumer content

# 1ç4 

# BUSAN 1215 SUSAN isa registered trademark microbiocide for controlling algal bactenal and fungal deposits in influent wmter systems and all process water systems used for the manufacture of paper and paperboard products and in industrial cooling towers recirculating cooling water systems evaporative condensers influent water systems brewery and food pasteurizers rndustnal fresh water systems airwasfiers seawater desalination and reverse osmosis systems paint spray booth sumps non-fish containing decorative fountains and ponds used tor cooling purposes sewage and wastewater systems This product is also used for the control ofalgae bacteria fungi and mollusks in both seawater and freshwater intluent systems ACTIVE INGREDIENTS Ammonia tatal t01NGREDIENTS T5TAt 

# KEEP

# OUTOF

# REACHOF CHILDREN 

# CAUTION

If in Eyes Hold eye open and rinse slowly and gently with water for 15-20 minutes Remove contact tenses if present after the first minutes then continue rinsing eye Call poison control center or doctor for further treatment advice Take ott contaminated clothing Rinse skin immediately with plenty of water for 5-20 minutes CatI poison control center or doctor for treatment advice If on Skin Clothes

If Swallowed Calf poison control center or doctor immediately fortreatment advice Have person sip glass ofwater if able to swallow Do nut induce vomiting unless told to do so by the poison control center or doctor Do not give anything by mouth to an unconscious person

If Inhaled Move person to fresh air

If person is not breathing call 911 oran ambulance then give artificial respiration preferably by mouth-to-mouth if possible Call poeon control center or doctor for further treatment advice HOT UNE NUMBER


### Precautionary 

## Statements HAZARDS TO

# HUMANSAND DOMESTIC ANIMALS CAU11ON Harmful if swallowed Avoid breathing vapor Avoid contact with skin eyes or clothing Wear protective eye-wear goggles face shield or safety glasses impervious chemical-resistant gloves and full body clothing long sleeved shirt and long pants socks and shoes when handling Wesh thoroughly with soap and water after handling and before eating drinking chewing gum or using tobacco ENViRONMENTAl HAZARDS Do not discharge effluent containing this product into lakes streams ponds estuaries oceans or other waters unless in accordance with the requirements of National Pollutant Discharge Etmination System 

### NPDES permit and the permitting authority has been nofifled in wiling pnor to discharge Do not discharge effluent containing this product to sewer systems without previously notifying the local sewage treatment plant authority For guidance contact your State Water Board or Regional Office ofthe EPA Directions forUse

It Is vIolatIon ofFederal law to uae thia product In marner inconsIstent wIth Its labeling PULP AND PAPER MILLS BtJSAN 1215 is used as microbiocide in the manufacture ofpaper and paperboard that contacts fond This product is applied in conjunction with sodium hypochlorite to form monochtoramine stower acting toss aggressive oaidrclng microbiocide The products are added to dilution water to achieve minimum molar ratio of 1.0 to 1.0 BUSAN 1215 to sodium hypochtorite This ratio may be obtained by combining 05 fluid ounces of BtJSAN 1215 to 1.0 fluid ounces of sodium hyscchlorite less than or equal to 15.0% wtlwt To insure both handling safety and effectiveness the monochioramine solution must be generated and fed into the treatment water systems through proper chemical feed skid onlyby trained Buckman representative Use of this product for any other purposes or contrary to the use directions specified below is prohibtied Dosage Rates When noticeably fouled apply suffloent product and sodium hypochforde to achieve total chtorine residual of at 759% least ppm in excess of the system oxidant demand Once control is achtoved treatment rates can be reduced to sub-demand 92.41% rates from 50% to 80% ofsystem demand The product may be added to the system continuously or intermittentiy as needed to 15950% any area of the system where uniform mixing can be obtained For intermittent treatment mix 0.5 fluid ounces ofBUSAN 1215 to 1.0 fluid ounce ofsodium hypochiorite less than or equal to 15.0% wt/wt Apply the solution at rate to obtain ito ppm in excess of the system oxidant demand maximum of ppm measured as total chlorine in the water being treated for to 60 minutes every ito hours The frequency of feeding and the duration of treatment will depend on the severity of the problem Badly fouled systems should be cleaned before initial treatment
For continuous treatment mix 0.5 fluid ounces ofBUSAN 1215 to 1.0 fluid ounce of sodium hypochlorite less than or equal to 15.0% wtlwt Apply the solution at rate to obtain 0.5 to ppm in excess of system oxidant demand maximum of ppm measured as total chlorine in the water being treated on continuous basis The frequency of feeding and the duration of treatment will depend on the severity of the problem Badly fouled systems should be cleaned before initial treatment

If chloramine is detected in the effluent it can be neutralized by the addition of sodium metabisulfite until the chlorareine is no longer detected INDUSTRIAL WATER SYSTEMS BUSAN 1215 is used for the control of algal bacterial and fungal deposits in industoal cooling towers recirculating cooling water systemsevaporative condensers influent water systems brewery and food pasteurizers industrial freshwater systems airweshers seawater desalination and reverse cemosis systems paint spray booth sumpe con-fish containing decorative fountains and ponds used for cooling purposes sewage and wastewatac systems This product is also used forthe control of algae bacteria fungi and mollusks inboth seawater and freshwater influent systems When this product is used to treat sewage and wastewater systems seawater and freshwater influent systems for once-through industrial water systems and seawater desalination and reverse comosis systemsand the system water is not sent to POTW residual levels of chloramine inthe effluent must be monitored and neutralized using on-line monitonng and control eqrspment When this pioduct is used to treat redroilating cooling water systems evaporative condensers influent water systems not part of once-through industrial water systems brewery and food pasteurizers airwashers paint spray booth sumps and non-fish containing decorative fountains and ponds used for cooling purposes effluent detection of chtoramirw should be conducted at toast once per shift If chioramina is detected in the effluent it can be neutralized by the addition ofsodium metabisulfite until the chloramrne isno longer detected This product is appted in conjunction with sodium hypoctilorite to form monochloramrne slower achng tess aggressive omdrzrng microbiocide The products are added to dilution water to achieve minimum molar ratio of i.Otol.0 BUSAN 1215 to sodium hypochlorite This ratio may be obtained by combining 0.5 fluid ounces of BUSAN 1215 to 1.0 fluid ounces of sodium hypochiorite toss than or equal to 15.0% wt/wt To insure both handling safety and effectiveness the reonochloramine solution must be generated and ted into the treatment water process through closed metered chemical feed system The system operator must be trained by Buckman representative in the use of the chemical teed system Use of this product for any other purposes or contrary to the use directions specified below is prohibited Dosage Rates When noticeably fouled apply sufficient product and sodium hysothlodte to achieve total chlorine residual of at least ppm in excess ofthe system orddant demand Once control is achisved treatment retes can be reduced to sub-demand rates from 50% to 80% ofsystem demand The product may be added to the system continuously or interrmttenliy as needed to any ares of the system where uniform mbengcan be obtained For intermittent treatment mis 05 fluid ounces ofBUSAN 1215 to 1.0 fluid ounce ofsodium hypochiorile less than or equal to 150% wt/wt Apply the solution at rate to obtain ito ppm in excess of the system oxidant demand maximum of ppm meseured as total chlorine in the water being treated for to 60 minutes every ito hours The frequency of feeding and the duration of treatment will depend on the severity of the problem Badly fouled systems should be cleaned before initial treatment For continuous treatment mix fluid ounces of BUSAN 1215 to 1.0 fluid ounce ofsodium hypochlonte less than or equal to 15.0% wtlwt Apply the solution at rate to obtain 0.5 to ppm in excess ofthe system oxidant demand maximum of ppm measured as total chlorine in the water being treated on continuous basis The frequency of feeding and the duration of treatment will depend on the severity of the problem Badly fouled systems should be cleaned before initial treatment 

### Storageand Disposal Do not contaminate water food or feed by storage ordsposal PESTICIDE 

### STORAGE Keep container tightly closed Store in dry place Leaking ordamaged drums shoud be paced in overpack drums for disposal Spills should be absorbed in sawdust or sand and disposed of in sanitary landfill Keep container dosed wtten not in use PESTICIDE 

### DISPOSAL Improper disposal ofexcess pesticide spray mixture or rinsate is violation of Federal law If these wastes cannot be disposed of by use according to label instructions contact your State Pesticide or Environmental Control 

### Agency or Hazardous Waste representative at the nearest EPA Regional office forguidance Clean equipment and/or dispose of equipment wash water in manner to avoid contamination ofwater resources CONTAiNER DISPOSAL PLAS11C Triple rinse or equivalent Then offer for recycling or reconditioning or puncture and dispose of in sanitary landfill by ndneration or if allowed by state and local authorities by burning If bumed stay out ofsmoke 

### MEIAL Triple rinse orequivalent Then offer for recycling orreconditioning or puncture and dispose of in sanitary landfill or by other procedures approved by state and local authorities

Manufscfuredby 

## Buckman Laboratories 

### Inc r2w Palm McLoas eke Me.rtil5u Tesiwsee xeira usa 9011278-0330 or

### 1400-BUCKMAN EPA Eat 

### No 1448-TN-I EPA Rag 

### No 1448-433 ProductWeht 9.59 lbs/gal I.ISkgil Net contents are marked am the contaner 1-IMIS 

## NPCA Ratings Health Flammability Reactivity Last Revision 1/11/2008 FIRST AID

Have the product container or label with youwhen calling Poison Control Center ordoctor or going for treatment You may also contact 901-278-0330
or 1-800-BUCKMAN for emergency medical treatment information

# EXHIBIT

# Busan1215

# FeedSystem

# EXHIBITWATER RINSE

PRESSURE RE000INC VALVE RUND EU WATER BOOST PRESSURE REGULATOR

OEIir1ed by EhckEd by Appra.ed by FilE flEE 

### ScM
PITS 

# Bu LaboratoriEs BUSAN 1215 

### DOSING 

## SYSTEM WcndELtmkM 159 in3OJ92579211 1- 

## 9OQ Gnnf FEK 32 al9ZSi.93O NR00 00.01 dItrnn REVI OlAFHRAM

BURKEFIT FLOW FUTURE USE SOLENOIDS

0110

RELIEF VALVE GRUNDFOS PRESSURE PUMPS
RELIEF VALVES

CHEMICAL

POLYPROPILENE ENCLOSURE

IFM FLOW SWITCH

# EXHIBIT

# 12 

# ti Busan1215 Feed 

# SystemDiagram Set water flow rate

# with valve AppUcaton AppHcaton 

# Appcaton AppUcaton



# BLan 1215

# BUSAN 1215 Valve Settings start 

# description position 

# water filter

# bypass closed water filter 

# inlet 

# open water filter 

# outlet 

# open water filter 

# drain 

# closed water booster

# pumpbypass closed dilution 

# water drain

# sampletap 

# closed dilution 

# water supply 

# open emergency flush 

# supply 

# open dilution 

# water flow rate 

# adjustment 

# open 10 

# sample tap

# Busan mixtureto 

# applications 

# closed 11 application 

# point outlet 

# open 12 application 

# point outlet 

# open 13 

# Busan 1215 inlet 

# open 14 

# Busan 1215 strainer isolation 

# valve 

# open 15 

# Busan 1215 calibration 

# column inlet 

# closed 16 

# Busan 1215 outlet 

# open 17 

# Bleach inlet 

# open 18 

# Bleach strainer isolation 

# valve 

# open 19 

# Bleach calibration 

# column inlet 

# closed 20 Bleach 1215 outlet 

# open

# EXHIBIT

# SOUTH COAST 

# CHEMICAL INC 139 

# IN

# THE

# MAimROFSOUTH COASTCHEMICAL INC FIFRA

# 844 

# REMANDORDER

Decided 

# March 11 1986

Before the 

# Administrator 

# U.S Environmental Protection 

# Agency Opinion by 

# Ronald 

# MeCallum ChiefJudicial Officer 

# INTRODUCTION This is 

# an appeal 

# by 

# EPA Region IX from an initial decision 

## ofthe 

# ChiefAdministrative 

# Law Judge dismissing 

# an administrative complaint 

# charging South Coast Chemical Inc of 

# Santa

# Ana Califor nia

# SCC with producing 

# and offering to sell 

### pesticide 

## product in 

## violation of the registration 

# requirements of 

## the Federal Insecti cide 

# Fungicide and Rodenticide 

# Act as 

# amended 

# FIFRA U.S.C

136 et

# seq The dismissal order 

# was issued 

# upon motion without



# hearing 

# The Chief Judicial Officer as the 

# Administrators delegatee has the authority to 

## decide this 

## appeal 

# pursuant to 

# 40 

# CFR 22.30 

# 1984 For the reasons set 

## forth 

# below the Initial 

# Deci sion is 

# reversed the complaint is 

## reinstated 

# and this 

## case is 

# re manded to 

## the presiding officer for

## further 

# proceedings 

# BACKGRO

# UND SCC produces and sells 

# sodium chlorate solution 

# under the 

# name of

# SC 6009 

# INDUSTRIAL 

# MICROBIOCIDE

# SC6009 When this 

## solution is 

### acidified 

# and added to

# water aqueous chlorine dioxide is 

# produced Chlorine dioxide is 

## strong oxidizing agent 

# which is 

# The specific provisions of

# FIFRA at issue 

### are 

# 12a

# 1Aand

# 12a2L Section 

# 12a1A prohibits 

### the distribution offering for 

### sale shipping and holding for sale 

### of 

## any pesticide 

### which is not 

### registered Section 

# 12a2L prohibits production of

pesticide at 

## an unregistered establishment 

# VOLUME

# 140 

# ENVIRONMENTAL ADMINISTRATIVE DECISIONS

used as fungicide or biocide for 

## certain industrial purposes.2 

# Be cause of

## the 

# commercial impracticability of

## transporting 

# aqueous chlo rine dioxide 

# Sec does not 

# mix its 

# sodium chlorate solution 

# with water at its 

## production facility 

# rather the 

# mixing process is 

# per formed at 

## the site

## of application.3 

# The record does not state

# when South Coast

# Chemical Inc began production of 

# sodium chlorate at its 

# Santa 

# Ana facility 

# However on January

# 25 1983 California state pesticide 

## inspector inspected the facility 

# and observed that 

# sodium chlorate 

# was being 

# produced at the site 

# He also obtained 

# samples of promotional literature 

# de scribing

# SC6009 as biocide 

# On January 

# 24 1983 the 

# day before the inspection 

# SCC sent letter to 

# EPA Region IX in 

# San Francisco inquiring 

# whether 

# SC 6009 

# was pesticide subject to 

# FIFRA registration 

# requirements 

# SCC stated in

## the letter 

# that There are 

# no biocidal 

## claims 

# made of 

## the precursors 

# sodium chlorate 

# solution These are the 

# chemi cals 

## that 

# would be sold to 

## the 

# customer 

# who would generate chlorine dioxide at 

## their site for 

## their

# own use 

# SCCs January 

# 24 1983 letter 

# was referred 

# by Region IX to 

# Dr Reto 

# Engler then Chief of the Disinfectants 

# Branch of 

# EPAs Registration 

# Division 

# On February 

# 16 1983 

# Dr Engler responded to 

# SCCs letter stating that 

# SCCs product 

# was subject to 

# FIFRA registration 

# requirements Thereafter 

# SCC applied for registration 

## of its 

## product 

# and its 

## product 

# establishment

# EPA registered

# SC 6009 on 

# March 14 1983 and registered the product establishment on April 

# 13 1983 More than year before 

# SCCsJanuary 

# 24 1983 letter 

# EPA Region II 

# headquartered in 

# Boston 

# Mass had issued 

# determina tion 

## that product similarto

# SC6009 produced by another chemical 

# manufacturer 

# was not 

# pesticide as defined 

# by

# FIFRAand thereThose purposes include controlling 

### microorganisms in oil field injection 

### waters refinery 

### waste waters enhanced oil 

### recovery systems industrial recirculating 

### water cooling 

### towers in 

### once-through fresh 

## and sea water industrial cooling 

### water systems 

## and in 

### pulp and paper mill 

### systems 

## 3The record 

### does not demonstrate whether mixing operations are 

### conducted by 

# SCC or the 

### purchaser 

## However the 

### product label 

### submitted to 

# EPA states that 

### mixing operations 

### will be carried 

### out by South Coast Chemical 

# Inc VOLUME

# SOUTH COAST 

# CHEMICAL INC 141

fore 

# was not subject to 

## registration requirements.4 

# The record does not permit 

# me to 

## reach conclusion as to 

# when 

# 5CC first 

## learned ofthe 

# Region II 

## ruling 

# On October 

# 17 1983 

# EPA filed 

# an administrative complaint against 

# 5CC charging that or 

# about January 

# 25 

# 1983 5CC offered or held for sale 

## the unregistered pesticide 

# SC 6009 and that 

# SCC produced the pesticide at its 

## unregistered production establish 

# ment The complaint 

# proposed 

# $4000 civil 

# penalty$2200 for 

## the alleged unregistered pesticide violation 

# and 

# $1800 for 

## the alleged unregistered establishment violation 

# On September 

# 1984 

# 5CC filed 

# motion to 

## dismiss the 

# com plaint Its 

# motion 

# was granted by the presiding officer 

# on 

# November 

# 27 1984 In his 

## decision the presiding officer 

# stated Prior to 

## the inspection 

# Respondent having become aware of 

## similarsituation 

# made inquiry of

# EPA concerning its 

# product 

# No definitive 

# answer was ever received 

# Due to 

# an uncertainty 

# during this 

## period as to 

## the applicability 

## of

# FIFRA to 

## the 

# product 

# Re spondent nevertheless registered 

# both the product 

# and the establishment in 

# March and April 

# 1983 six 

# months priorto 

## the issuance ofthe 

# complaint Initial 

# Decision 

# The presiding officer 

## concluded that these 

# good faith efforts 

## of

# re spondent should 

# have been taken into 

# account since sanctions 

# permitted by

# FIFRA are preventative in 

# nature and are not intended to 

# be Initial 

# Decision This appeal followed 4Letter from Region II to 

### Chemical Generators 

# Inc dated August 

# 21 1981 appeal the Region 

## argued without citation of 

### authority that the presiding officers 

### statement regarding the preventative nature of 

### the civil 

### penalty provisions of 

# FIFRA is 

### misstatement of 

### the law and the Congressional 

## mandate represented by 

# FIFRA While agree with the Regions position 

### that the Complaint should be reinstated do not agree with its characterization of 

### the civil 

### penalty provisions of

# FIFRA FIFRAs civil 

### penalty provisions 

### are similar to 

### those of the Toxic 

### Substances Control Act

# TSCA 15 

## U.S.C 2615 which are remedial in 

### nature rather than punitive 

## As explained in 

### Briggs Stratton Corporation 

# TSCA Appeal 

# No 

# 811 101 

# ALC 116 119 

# Feb 1981 Civil penalties 

### under 

# TSCA are intended to deter 

### through regula tion not reprimand through 

## punishment Punishment under 

# TSCA is 

### accomplished through the criminal provisions of 

# 16b which impose criminal sanctions 

### on persons 

## who knowingly or willflillyviolate 

### the regulations 

## The presence of 

### these criminal 

### sanctions in 

# 16b and their juxtaposition 

### next to 

### the civil 

### provi Continued 

# VOLUME

# 142 

# ENVIRONMENTAL ADMINISTRATFVE DECISIONS 

# DISCUSSION On appeal 

# SCC claims that its 

# good faith efforts to find 

# out whether 

# FIFRA required that 

# SC 6009 be registered should 

# weigh heavily in its 

## favor 

# and that the presiding officer 

# was correct 

## in concluding that the complaint should be 

# dismissed 

# The Region claims that 

# SCCs good faith is 

## not 

# an appropriate basis for 

## dismissal agree with the 

# Region 

# FIFRA is 

### strict liability 

## statute 

# Accordingly respondents good faith is 

## not defense to 

# charge that the statute 

# has been violated 

# FIFRA is 

## similar in this 

## respect to 

## the 

# Clean 

# Water Act 33 

# U.S.C 

# 1321b1 In 

# U.S Coastal States 

# Crude Gathering 

# Co643 F.2d 1125 

# 5th Cir

# 1981 the Fifth Circuit

# Court of

# Appeals stated Section 

# 1321 provides 

# no defense to 

## the 

# assess 

# ment of the civil 

# penalty indeed it 

## establishes 

# an absolute liability 

# standard which obviates the 

# need for 

## finding offault 

# 643 2d at

# 1125 The court 

# added that shifting 

## the 

# burden of 

## achieving clean 

# waters to 

## users of those 

# waters albeit 

# good faith non-negligent 

# users is 

## valid exercise ofcongressional 

# power Similarly 

# FIFRAs registra tion 

# requirements provide 

# no exception for 

## pesticide producers or users 

# who claim that they acted in

# good faith 

# Good faith 

# may be factor to 

# weigh in 

## considering 

# whether proposed penalty should 

# be reduced 

# or even 

# eliminated however sions in 

# 16a contains this 

## same civil 

### versus criminal sanction 

### juxtaposition is

### strong evidence of 

### Congressional intent to establish statutory 

### scheme which has remedial function insofar as 

### the civil sanctions are 

### concerned 

## The fact that 

# mone tary 

### penalties are involved 

### under 

# 16a does not alter this 

### statu tory 

## scheme term 

## penal is 

### used in different contexts to 

## mean different 

## things Smith 

# No Galesburg 

## Crown Finance 

# Corp 615 F.2d 

# 407 414 

## 7th Cir 

# 1980 The context 

### here dictates 

### the conclusion that the civil 

### penalty provisions 

### are compensatory 

## and remedial in 

### nature For the 

## same reasons 

# FIFRAs civil 

### penalty provisions 

## mustbe viewed as remedial in 

### nature 

## and not punitive See True 

# U.S Supp ERC 1752 

# Wyo 1985 civil penalties for oil spills 

### under the Clean 

## Water Act 33 

## U.S.C 132

# 1b are compensatory and remedial in 

### nature not criminal 

## and punitive that regard 

# FIFRA 14aX4 states

Determination of 

### penalty 

## Whenever the Administrator finds 

### that the violation 

### occurred despite 

### the exercise of 

### due care or 

# VOLUME

# SOUTH COAST 

# CHEMICAL INC 143

whether or not 

# complaint is 

### justified in 

## the first 

## instance is 

# under 

# FIFRA matter for 

## the 

# prosecutor to 

# decide In the absence of 

# an abuse of 

## prosecutorial discretion will 

## not substitute 

# myjudg ment for 

## that of 

## the 

# Region Nothing in this 

## record 

# demonstrates that 

# Region IX abused its 

## discretion in 

## bringing complaint against 

# SCC On January 

# 25 1983 California pesticides inspector discovered that 

# SCCwas pro ducing pesticide 

## product at its 

## plant in 

# Santa 

# Ana At that 

# time neither the product 

# nor 

# SCCs production establishment 

# was reg istered as required 

# by 

# FIFRA SCCs subsequent compliance 

# with 

# FIFRAs registration 

# requirements six 

# months later 

## does not affect 

## the fact 

## ofthe violation 

# Judge Finch seems to 

# have been influenced 

# by the 

# apparent uncertainty at

# EPA as to 

# whether products 

# such as

# SC 6009 should 

# be regarded as pesticides 

# However 

# FIFRA makes it 

### clear 

## that pesticide 

# mustbe registered before it is 

# produced or

# marketed Here

it 

# appears that 

# SCC chose to act first 

# and to 

## inquire later 

# about the 

# Agencys registration 

# requirements and 

# must accept the 

# con sequences If 

## the presiding officer is 

# persuaded by 

# SCCsassertion of 

# good faith 

# however he 

# may take it 

### into 

## account in 

# determining the 

# amount of the 

# penalty Such claims should 

# be presented at 

# an evi dentiary hearing 

# where the 

# Region will 

# have the opportunity to 

## present its 

# own evidence 

# and to 

## conduct cross-examination 

# While have no reason to 

## question 

# SCCs good faith do not find in this 

## record sufficient 

## evidence for 

## finding that the 

# company acted in 

# good faith in 

## trying to 

# determine whether it 

# was subject to 

# FIFRA registration 

# requirements 

# SCC has asserted but 

# has 

# pro vided 

# no evidence that it 

## delayed registering its 

## product 

# because it 

### relied 

# on the 

# Region II 

## letter

# Morover it

# has provided 

# no informa

did 

### not cause significant 

## harm to 

### health or 

### the environment the 

### Administrator 

# may issue 

### warning in lieu of 

### assessing penalty

Pesticide 

### Enforcement Division 

### Case Proceedings Guidance 

## Manual 

# 1983 states civil 

### penalty as 

### authorized by Section 

# 14a of 

# FIFRA is 

### the 

## remedy of choice for 

## most violations civil 

### penalty should be proposed 

## where the violation 

### presents real 

### but not an extreme 

## and unreasonable risk to 

## humans or 

### the 

## environment is unlikely to 

### be an isolated 

### occurrence 

## was apparently committed as result of 

### ordinary negligence inadvertence or 

## mistake Chapter 

## Deter mination of

### Appropriate Enforcement 

## Response

# 513 VOLUME

# 144 

# ENVIRONMENTAL ADMINISTRATIVE DECISIONS

tion 

## as to 

## the date 

# when it

# began to 

## produce 

# and market 

# SC 6009 nor 

# has it 

## stated 

# when the 

# company first 

## learned of the 

# Region II 

### position.8 

# As for 

# SCCs claim that 

# EPA never responded to its 

## inquiry 

# DrReto Englers February 

# 16 1983 letter to 

# 5Cc expressly states 

## that it is 

### in 

# answer to 

# SCCs January 

# 24 1983 letter 

# For all 

## the foregoing 

# reasons the presiding officers 

## rationale for

# dismiss ing the 

# complaint i.e that 

# good faith efforts 

## of 

# Respondent should 

# have been taken into

# account is 

## rejected next consider 

# whether any other rationale exists for 

## dismissing the 

# complaint In its 

# motion 

# SCC requests that the 

# complaint be dismissed 

# pursuant to 

# 40 

# CFR 22.20 for failure to 

## establish 

# prima facie 

## case 

# because the 

# 5CC exercised every reasonable effort to 

# comply with 

# FIFRA and timely registered both the product in 

## issue 

# and the production 

# establishmentThese grounds for 

## dismissal of the 

# complaint are 

# no 

# more than restatement of 

# SCCs good faith claim discussed 

# above and are rejected for 

## the reasons set forth 

## above.9 

# SCC also 

## claims that the complaint should 

# be dismissed for fail 

## ure to state 

## claim 

# upon which relief 

# can be 

# granted 10 in 

# that the 

# complaint erroneously alleges 

## that 

# SC 6009 is 

### pesticide 

## as defined in 

# FIFRA and it is 

# based on regulations that 

# are void for

# vagueness and unconstitutional These two claims are briefly 

## discussed 

# below 8Respondents 

# Memorandum of 

### Points and Authorities in 

### Reply to 

### Appellants 

## Appeal dated 

## December 

# 21 1984 states that 

# SCCs January 

# 24 1983 letter to 

# EPA had attached to it 

### copy of 

### the Region II letter 

## However the 

## January 24 letter 

### does not refer to 

### the Region II letter 

## Moreover the only 

### attachment to 

### which the letter refers is 

### diagram of chlorine dioxide 

### generator Respondents Response to 

### Complainants Prehearing Conference 

# Memorandum February 

# 23 1984 states that 

# SCC discussed the Region II letter 

### with David Jones of 

### Region IX on February 

## 22 1984 year later 

## and that copy of 

### the letter 

## was submitted to 

## him on that 

### date It is 

### noted that letter 

### from 

# Dr Reto Engler of 

# EPA to 

### Region 

# IX dated 

## March 1984 states 

# Dr Englers opinion that 

# SCC relied 

### on the Region II letter in 

### concluding that registration 

## was not required 

## 9Moreover 

# SCCs allegation of failure to establish 

### prima facie 

### case is

## premature Dismissal for

### failure to establish 

### prima facie 

## case under 40 

# CFR 22.20 is similar to directed verdict 

### under the Federal Rules of Civil 

## Proceduresee 

# FRCP Rule 

# 50a motion for directed verdict is properly 

## made only after 

### complainant has 

## had an opportunity to 

### submit evidence at trial 

### See e.g Wilson 

## Good 

# HumorCorp 757 F.2d 1293 

# D.C Cir1985 Phillips 

## Hardware Wholesalers 

# No 831804 Slip 

### Opinion 

## 6th 

# CirMay 15 1985 

# SeeFRCP Rule 

# 12b6 In the context of this 

### hearing 

# SCCs claim falls 

### within 40 

# CFR 22.20 which permits dismissal for 

## other grounds 

## show no right to relief

### on the part of

### the

## complainant 

# VOLUME

# SOUTH COAST 

# CHEMICAL INC 145
Region IX has charged 

# 5CC with violating 

# FIFRA by producing 

# and selling 

# an unregistered pesticide 

# The Agency has determined that 

# SC 6009 is 

### pesticide 

# based on its 

## intended 

# use Although the 

# sodium chlorate solution 

# marketed by

# SCC does not itself 

# have pesticidal properties it 

## produces pesticidal 

## action atthe site 

## of

# appli cation

# As

# EPAexplained in letter to

# SCC SC 6009 is 

### identical to 

## others 

# wherein chemical 

# when placed in 

# water readily 

# changes to 

# an other 

# chemical which is 

## the actual pesticide required to 

# be regulated 

# under the Federal Insecticide 

# Fun gicide 

# and Rodenticide 

# Act The very fact 

## that the latter 

# cannot exist 

## as 

# marketable 

# commodity and only exists in 

# an aqueous 

# medium as it is 

## released 

# bythe parent 

# chemical 

# makes the 

# immediate precur sor the only logical 

## chemical 

# through which the use ofthe pesticide 

# can be regulated.11 

# The Registration Division acted within its 

## authority in 

# determining that 

# SC 6009 is 

### pesticide for 

# purposes of 

# FIFRA registration 

# re quirements 

# and its 

## decision 

# stands Lastly 

# SCC claims that the 

# complaint should be dismissed 

# be cause the 

# complaint is

# basedon 

# FIFRAregulations that are

# unconsti tutionally 

# vague To entertain 

# such challenge 

# however would vio latethe general rulethat attacks 

# on the validity 

## of

# agency regulations 

# are rarely entertained in 

## the context of 

# an administrative 

# enforce 

# ment hearing absent the 

# most compelling of

# reasons American 

# Eco logical Recycle 

# Research Corporation 

# RCRA 833 at 

# pp

# 56 July 

# 18 1985 Moreover the decision to 

## entertain 

# such challenge is 

## discretionary 

# Id In this 

# instance no compelling circumstances exist to justifr 

# departure from the general 

# rule

Letter to 

# SCC dated February 

# 23 1983 from 

# Dr Reto Engler then Chief ofthe Disinfectants Branch of

### the

# EPA Registration 

### Division 

# VOLUME

## 146 

# ENVIRONMENTAL ADMINISTRATIVE DECISIONS

For all 

## the foregoing reasons the initial 

## decision is 

# reversed the complaint is 

## reinstated 

# and this 

## case is

# remanded to 

## the 

# presid ing officer for

## further proceedings consistent 

# with this 

# order.2 Soordered

12

## The Region requests that this 

### case be 

## remanded for 

### hearing on the issues raised 

### by the 

### pleadings on file in this 

## action Regions Appeal Brief 

## Whether

hearing is 

### necessary or 

### whether the factual issues raised 

### herein

# my be resolved in 

## more expeditious 

## and less costly 

# manner is 

### matter for

### the ChiefAdministrative 

# Law Judge to 

### decide 

# VOLUME

# EXHIBIT

## PRECAUTIONARY STATEMENTS HAZARIS TO 

# HUMANS A.Nl 

## DOMESTIC ANIMALS 

# DANGER CORROSIVE CAUSES SEVERE EYE 

## AND SKIN 

### INJURY 

## HARMFUL IF

## INHALED HARMFUL IF

## SWALLOWED Do not get in eyes on skin oron clothing Wear goggles or face shield and nibber gloves when handling Remove and wash contaminated clothing before reuse Wash thoroughly after handling 

# ENVIRONMENTAL HAZARDS This pesticide is toxic to fish and aquatic organisms 

### Do not discharge effluent conlaining this product into lakes streams ponds estuaries oceans or public waters unless in accordance with the requirements of National Pollutant Discharge Elimination System 

# NPDES permit and the permitting authority baa been notified in writing prior to discharge 

### Do not discharge effluent containing this product to sewer systems without previously notifying the sewage treatment plant authority For guidance contact your Stale Water Board or Regional Office of the

## EPA Apply this pesticide only as specified on this label



## EPARegNo 1106-171 

### EPA Eat

## No 1706-IL-1BP 

### EPA Eat

## No 1706-NJ-tPN Lettepin that netchss first letter in hatch number idenliflea the 

### staligiunentnbmb 

# NECtffEN1 SflOflt 

### ELSEWIIWERE 

## ONCONTAINER 

# ONDEO Natcct 

# ACTI-PLUS2818 STABILIZED 

# SODIUM HYPOCIILORITE ACTIVE INGREDIENT

Sodium Hypochlorite 8.34% 

### INERT INGREOTENTS- 1.66%

Total 100.00% Available Chlorine 7.9% 

# KEEP

# OUTOF

# REACHOF

# CHILDREN 

# DANGER

SEE SIDE 

### PANEL 

## FORADDITIONAL PRECAUTIONARY 

## STATEMENTS Ondec Nalco 

### Company

Ondeo Nalco Center Naperville IL 60563-1198 

# EMERGENCY PHONE

# NO800 424-9300 

# DIRECTIONS 

# FOR

# USE

It is violation of Federal 

### Law to use this product in manner inconsistent with itslabeling ACTI-PLUS 2818 is an effective agent for controlling algal bacterial and fisngal slime in condensing and cooling equipment in which recirculating water is used as the cooling medium and in reservoirs orponds which serve as the source of boiler feedwater or cooling water ACTI-PLUS 2818 can also be used to control bacterial and algal slime in decorative fountains and brewery pasteurizers 

## INDUSTRIAL 

# ANDCOMMERCIALRECIRCULATING 

# WATER COOLING 

# TOWER SYSTEMS ACTI-PLUS 2818 should be applied directly to the cooling water at any section of the system where sufficient mixing will occur ACTI-PLUS 2218 should be applied to the cooling water to provide

total chlorine level of2-4 

### ppm ACTI-PLUS 2818 at dosage of 1.25 fluid ounces per 1000 gallons of water gives dosage of approximately 

### ppm of total chlorine but several times that dosage may be required to provide total chlorine level of 

### ppm throughout the system The total chlorine level should be checked with teat kit and additional applied until reading of 2-4 

### ppm is obtained atthe bleed-off point Some systema 

### maybe maintained in satisfactory biological condition by applying this dosage once per day while others will respond better to dosages less than once per day 

## COOLING PONDS 

# AND RESERVOIRS ACTI-PLUS 2818 

### maybe applied at the reservoir orpond inlet or at location that permits complete diffUsion into the water at 

### maximum retention time before reaching the outleL Sufficient ACTI-PLUS 2818 should be fed to maintain total chlorine level of 2-4 

### ppm in all pasts of the reservoir orpond 1.25 fluid ounces per 1000 gallons ofwater yields 

### ppm total chlorine 

## DECORATIVE FOUNTAINS ACTI-PLUS 2818 may be applied tothe decorative fountain inlet or at point where sufficient mixingwill occur at level to maintain 2-



### ppm total chlorine in all pasts of the fountain 

# Do not use in fountains which contain fish orother aquatic fauna 

# BREWERY PASIEtJRIZERS For control ofbacteria and fungi inIrewerypasteurizers add 3.5-7.0 ounces ofACTI-PLUS 2818 per 1000 gallons of system water to achieve controL To maintain control add sufficient ACTI-PLUS 2818 to maintain 2-4 

### ppm total 

## cldffljPtPIU the syateni 1.25 fluid ouncea per 1000 galtoy 

### gjQ4g4sjsrt total chlorine 

## WIUl LAJLVflYWL n.e 

# EpALetteroate

Under the 

## Fed4aI insectiddet 

## hnatcidC afló RniefttlCidC 

### Actas 211t5.Alced fot tht 

### pesticide CORROSIVE 

## LIQUID BASIC INORGANIC N.O.S SODIUM IJYPOCHLORITBI 

## UN3261 

# vlr7I STORAGE AND DISPOSAL STORAGE Do not contaminate water food or feed by storage disposal orcleaning ofequipment PESTICIDE 

### DISPOSAL Pesticide wastes are acutely hszardout Improper disposal of excess pesticide spray mixture or rinaate ia violation of Federal 

### Law Ifthese wastes cannot be disposed of by use according to label instructions contact your State Pesticide or Environmental Control Agency or the Hazardous Waste repreaentstive at the nearest 

### EPA Regional Office for guidance 

## CONTAINER DISPOSAL METAL CONTAINERS Triple rinse

### or equivalent Then offer for recycling or reconditioning or puncture and dispose of in sanitary landfill or byother procedures approved by stale and local authorities 

### PLASTIC CONTAINERS Do not raise empty contsint Triple rinse

### or equivalent Then puncture and dispose of in sanitary landfill or ifallowed by state and local authorities by burning If burned stay out ofsmoke FIRST AID It awallowed Cell poison euntnA center or doctor immediately for treatment advice 

### DO NOTHIDUCE 

### VOMITING 

## Do not give asythingto think If In eyes Hold eye open asd nina slowly and gently with waterfor 15-20 minutes 

### Mer lent 15 minutes ofsinsing or after it asjudged that nearly all ofthe contamination has been removed Remove contact lenses ifpresent after the that minutes then eontinue sinsing Call poism control center or doctor imniedidely for treatment advice If eqs J4n ordelSing Take off contaninated clothing Pinse skin issunedheely with plenty of waterfor 15-20 minutes Call poison eontrol caster or doctor for treatnsent advice If Inhaled Move poison to fresh air Ifpesson is not breShing call 911 or an ambulance and then gin astificial respiration preferthly mouth-to-math ifpossibl Call poison eoolnl caster or doctor for ftssthertreatsnent advice 

### NOTE TOPHYSICIAN Aspiration maycane longdassago Probthle mucosal danage nsay contraindicate ISsue of gastric lavsge Have the 

### MSDS aa4 ifavailthl the product eastinser or lthel with you when calling poison control center or doctor orgoing fortreatmast 

### EPAEaLN0 1706-CA-lCR EPA Eat

## No 1706-WA.lVW 

# 3O 21X33



## Revised 3/11/2003

# MASTER LABEL Edit 

### Date P12/07 

# STABREXST70 STABREX ST 70 is an effective agent for controlling algal bacterial and fungal slime in condensing and cooling equipment in which recirculating water is used as the cooling 

### medium and in ponds which serve as the source of boiler feedwater or cooling water 

## STABRFX ST 70 can also he used to control bacterial fungal and algal slime in decorative fountains air washers pulp papermill influent water systems pulp and papermill process water systems and 

### food beverage and industrial process pastcurizers 

## ACTIVE INGREDIENTS Sodium hypochlorite 

### 6.36% Sodium bromide 

### 9.23% 

# OTHER INGREDIENTS 

# 84l% Total 100.00% Total Available Bromine approximately 

### 14% expressed as chlorine approximately 

### 6.4% 

# KEEP

# OUTOF

# REACHOFCHILDREN 

# DANGER

FIRST AID
Ifswallowed Call poison control center or doctor immediately for treatment advice 

## DONOT INDUCE VOMiTING Do not give anything to dnnk If In eyes Hold eye open and rinse slowly and gently with water for 15-20 minutes Afterat least IS minutes of rinsing or after it isjudged that nearly all ofthe contamination has been removed Remove contact lenses if present after the first minutes then continue nnsing Call noison control center or doctor immediately for treatment advice ifon skin orclothing Take off contaminated clothing Rinse skin immediately with plenty of water for tS-20 minutes Call poison control center oradoctor for treatment advice Ifinhaled Move person to fresh air If person is not breathing call 911 oran ambulance and then give artificial respiration preferably mouth-to- mouth ifpossible Call poison control center or doctor for further treatment advice 

## NOTE TO PHYSICIAN Aspiration may cause lung damage Probable mucosal damage may contraindicate the use of gastric lavage Have the 

### MSDS and ifavailable the product container or label with youwhen calling poison cootml center or doctor or going for treatment 

## SEE SIDE 

## PANEL FORADDITIONAL 

# PRECAUTiONARYSTATEMENTS

Nalco 

## Company 1601 

## West BleEd 

### Road Naperville IL 60563-1198 

# EMERGENCY PHONE

# NO800 424-9300 

## NET 

# CONTENTS 

# SHOWN ELSEWHERE ONCONTAINER EPA REG 

# NO 1706-179 

### EPA Est 

## No 

# ACCEPTED 

# Q5

IJedarlbe FSoral lnseclftkme Fungicide and Rodentride Act as amended tot the



## crantvIjnder

# 31Fq

PRECAUTIONARV 

# STATEMENTS HAZARDS TO HUMANS AND 

# DOMESTICANIMALS 

# DANGER CORROSIVE CAUSES SEVERE EYE 

# AND SKIN 

## INJURY 

# HARMFUL IF

# INHALED HARMFUL IF

# SWALLOWED Do not get in eyes on skin oron clothing 

### Wear goggles or face shield and rubber gloves 

### when handling 

### Remove and wash contaminated clothing before reuse 

### Wash thoroughly after handling 

# ENVIRONMENTAL HAZARDS This pesticide is toxic to fishand aquatic organisms 

### Do not discharge effluent containing thisproduct into lakes streams 

### ponds estuaries oceans or public waters unless in accordance with the requirements of National Pollution Discharge Elimination System

# NPDES permit and the permitting authority has been notified in writing prior to discharge 

### Do not discharge effluent containing this product to sewer systems withoffi previously notifying the sewage treatment plant authority Forguidance contact your State Water Board or Regional Office of

## EPA Apply thispesticide only as speeitied on the label 

# DIRECTIONSFORUSE

It is violation of Federal 

### Law to use this product in manner inconsistent with its labeling 

# COOLING PONDS NOTE THIS USE 

### NOT CURRENTLY AUTHORIZED IN

### NEW 

## YORK STABRFX ST 70 

### may be applied at the pond inlet or at location that permits complete diffusion into the water at

### maximum retention time before reaching the outlet Sufficient 

## STABREX ST 70 should be fed to maintain total bromine level of4.5-9.0 

### ppm in all parts of the pond 

### two fluid ounces per 1000 gallons ofwater yields 2.2 

### ppm total 

### bromine 

## DECORATIVE FOUNTAINS STABREX ST 70 

### may be applied at the fountain inlet or at location that permits complete diffusion into the water at 

### maximum retention time before reaching the outlet Sufficient 

## STABREX ST 70 should be fed to maintain total bromine level of4.5-9.0 

### ppm in all parts of the reservoir 

### two fluid ounces per 1000 gallons ofwater yields 2.2 

### ppm total 

### bromine 

## INDUSTRIAL 

# ANDCOMMERCIAL RECIRCULATING 

# COOLINGWATER SYSTEMS STABREX ST 70 should be applied directly to the cooling water at any section of the system where sufficient mixing will occur 

## STABREX ST 70 should be applied to the cooling water toprovide total bromine level of 4.5-9.0 

## ppm STABREX ST 70 at dosage of two fluid ounces per 1000 gallons of water gives dosage of approximately 2.2 

### ppm of total 

### bromine but several times that dosage 

### may be required to provide total bromine level of 2.2 

### ppm throughout the system 

### The total bromine level should be checked with test kit and additional product applied until reading of4.5-9.0 

### ppm is obtained at the bleed-off point 

### Some systems 

### may he maintained in satisfactory biological condition by applying this dosage once per day while others will respond better to dosages less than once per

### day 

## INDUSTRIAL PASTEURIZERS Such as 

### food beverage and industrial process pasteurizers For control of bacteria and fungi in industrial pasteurizers add 3.5 -7.0 ounces of

## STABREX ST 70 per 1000 gallons ofsystem water to achieve control 

### To maintain control add sufficient 

## STABREX ST 70 to matntain 4.5-9.0 

### ppm total bromine throughout the system 

# Two fluid ounces per 1000 gallons ofwater yields 2.2 

### ppm total 

### bromine 

## SHELL 

# EGG PASTEURIZER 

# WATER SYSTEMS NOTE THIS USE 

### NOT CURRENTLY AUTHORIZED IN

### CALIFORNIA For control of bacteria fungi and associated slime in shell egg pasteurizer water systems add 3.5-7.0 ounces of

# STABRST 70 per1Q00 gallons ofsystem water to achieve control 

### To maintain control add sufficient 

## STABREX ST 70 to maintain 4.5-9.0 

### ppm total bromine throughout the system 

# Two fluid ounces per 1000 gallons ofwater yields 2.2 

### ppm total 

### bromine
AIR 

# WASHERS This product 

### may be used only ia industrial air washers 

### and air washer systems which have mist-eliminoling 

### components For control ofmicroorganisms in industrial air washer systems add sufficient 

## STABREX ST 70 to the 

### arw..sher 

### sump or chill water to provide total bromine level of 4.5-9.0 

## ppm Badly fouled systems must be cleaned bernie treatment is 

### begun 

## STABREX ST 70 at dosage oftwo fluid ounces per 1000 gallons of water gives dosage ofapproximately 2.2 

## çpm of total bromine but several times that dosage 

### may be required to provide total bromine level of 2.2 

### ppm throughout the system 

### The total bromine level should be checked with test kit and additional product applied until reading of 4.5 9.0 

### ppm is ontdined at the bleed-off point 

### Some systems 

### may he maintained in satisfactory biological condition by applying this dosage Once perdaywhile others will respond better todosages lessthan once per 

### day 

# HEAT TRANSFER SYSTEMS Such as Evaporative 

### Condensers Hydrostatic Sterilliers and Retorts Dairy Ssseetwater 

### Systems and Once-Through Cooling 

### Water Systems 

## STABREX ST 70 should be used at the same application rates and in the same manner as described 

### above It should he added to the system at point of uniform mixing such as basin area 

### somp area or other reservoir or collecting area from which the treated water wilt be circulated uniformly throughout the system 

## FOR PULP PAPER MILL INFLUENT 

# WATER SYSTEMS



# OTL THIS LSL MIT 

### CURRINTLY AUTItRI/.Ffl IN 

### ALIFORNIAI 

## STABREX ST 70 should be applied to the raw water intake prior to lie litter house ceunomtier or process water Feed at dosage sufficient to provide total bromine leel of 4.5 9.0 

## ppm STABREX ST it at dosage of two fluid ounces per 1110 gallons ofwater gives dosage of approximately 2.2 

### ppm of total bromcne hut several times that dosage 

### may be required to provide total bromine level of 2.2 

### ppm throughout the system 

### The total bromine level should be checked with test kit and additional product applied until reading of 4.5 9.0 

### ppm is obtained 

### Some systems 

### may he maintained in satisfactory biological condition by applying thisdosage intermittently while others 

# ma require continuous application 

## STABREX ST 70 

### may he used in pulp and paper influent water systems where the manufactured paper or paperboard 

### may be used forfood contact purposes 

## FOR PULP PAPER MILE 

## PROCESS 

# WATER SYSTEMS T5oTh THIS 

### NOT CURRENTLY AUTJORI7.ED IN CAtJFORN 

### IA 

## STABREX ST 70 should headded to paper making system at point of uniform mixing such as the beaters broke chest 

## pump save-all tank or whitewater tank Feed at dosage sufficient toprovide total bromine level of 4.5 9.0 

## ppm STABREX ST 70 at dosage oftwo fluid ounces per lt00 gallons ofwater gives dosage ofapproximately 2.2 

### ppm of total 

### bromine but several times that dosage 

### may he required to provide total bromine level of 2.2 

### ppm throughout the system 

### The total bromine level should be checked with test kit and additional product applied until reading of 4.5 9.0 

### ppm is obtained 

### Some systems 

### may be maintained in satisfactory hiotngical condition by applying thisdosage intermittently while others 

### may require continuous application 

## STABREX ST 70 

### may he used in pulp and paper mill process water systems where the manufactured paper or paperhoard 

### may be used forfood contact purposes 

## INDUSTR1AL 

# WASTE WATER IMPOUNDMENT 

# WATER TREATMENT MiTt TillStsF NOT

# CIRRFN AtmltRI7.En tI.IFORNIA Fur control ofmicroorganisms in wastewater treatment system add sufficient 

## STAUREX ST 7t to provide total bromine level of 0.2-0.5 

## ppm Badly fouled systems must he cleaned before treatment is begun 

## STABREX ST 70 at dosage oftwo fluid ounces per 

### 10000 gallons ofwater gives dosage ofapproximately 0.2 

### ppm of total bromine but several times that dosage 

### may he required toprovide total bromine level of 11.2 

### ppm throughout the system The total bromine level should he checked with test kit and additional product applied until reading of t.2-tt.5 

### ppm is obtained at the bleed-off point 

# NOTE Halogen dosages listed in the various applications are expressed as bromine Since most field test kits for oxidizing halogens give values in terms ofchlorine simply multiply the reading from the test kit 

### as chlorine by 2.25 in nrder to obtain the bromine equivalency listed in these directinns 

## STORAGE 

# AND DISPOSAL 

# STORAGE Do not contaminate water food orfeed bystorage disposal or cleaning ofequipment 

### PESTICIDE 

## DISPOSAL Pesticide wastes are acutely 

### haardous Improper disposal of excess pesticide spray mixture or rinsate is violation of Federal 

### law If these wastes cannot he disposed ofby use according to label instructions contact your State Pesticide or Environmental Control 

### Agency orthe Hazardous Waste representative at the nearest 

### EPA Regional Office for guidance 

## CONTAINER DISPOSAL 

# METAL CONTAINERS Triple rinse 

### or equivalent Then offer for recycling or reconditioning or puncture and dispose of in

sanitary landfill or by other procedures approved by State and Local authorities 

### PLASTIC 

# CONTAINERS Do not reuse empty container riple rinse 

### or equivalent Then puncture and dispose of in sanitary landfill or ifallowed by State and Local authorities by burning If burned stay out of

### smoke

## AUG 3.0 2007 

# 1NALCO

MICROJRGANISMCONTROL CHEMICAL 

# .r EMERGENCY P1-lONE 

## NO 800 424-9300 

### DIRECTIONS 

## FOR USE coiitinued from left side panel PULP 

### AND PAPERM ILL PROCESS 

### WATER SYSTEMS SLUG FEED 

### METHOD Initial Dose When the system is noticeably fouled add appropriaie amowitof NALCON 60735 per lO.000gallons of water in the system to obtaimifroni to 10 ppm available chlorine Repeat until control is achieved Badly fouled systems nsust be cleaned before treatnseiit is beguit Subsequent Dose When microbial control is evideimi add appropriate amount of NALCON 60735 per 10000 gallons of water is the system daily or as needed to maintain control and keep the chlorine residual at ppm INTERJ4II1ENT FEEb 

### METHOD Initial Dose When the system is noticeably fouled add appropriate amount NALCON 60735 per 10000 gallons of water in the system to obtain to tO ppm available chlorine Apply halfor 1/3 1/4 or 1/5 of this itiltial dose when half or 1/3 1/4 1/5 of the water in the system has been lost by blowdowe Badly fouled nysrema must be cleaned before treatnseiit isbegun Substqueise Dose When microbial control isevideist add appropriate amdunt of NALCON 60735 per 10000 gallons ofwater in the syatem to obtain ppns residual Apply half or 1/3 1/4 or 1/5 of this initial dose when half or 1/3 1/4 1/5 of the water in the systemsi has been host by btowdown 

### CONTINUOUS FEED 

### METHOD Imiital Dose When the system is noticeably fouled add apprbpriate amount of NALCON 60735 per 10000 gallons iii the system to obtain to hO ppm available chlorine Badly fouled systems must be cleaned before treatment is begun Subsequent Dose Maintain this treatmeni level by starting continuous feed of

oz of NALCON 60735 per 1.000 gallons .of water lost by blowdown to maintain 1.0 ppm residual

TI

### PRECAUTIONARY STATEMENTS HAZARDS TO 

### HUMANS AND DOMESTIC ANIMALS 

# PE.COROS1VR Nalcon60735 after 

# ble

ENVIONMENTAL HAZARDS This pesticide is toxic to fish and aquatic organisim Do not discharge effluent ACTIVE INGREDIENT contaming this product into Iake streams ponds estuaries oceaus or oilier Sodium hypoclilorite Ii 6% waters unless in accordance with the requirements of National Pollutant INERT INGREDIENTS 88 4% Discharge Eliitnnaiioii System

# NPD permit and the pnnittiitg authority has TOTAl 100.0% been notified to writing prior to discharge Do not discharge effluent containing ..... treatment plant authority For guidance contact your State Water Board or this product to sewer systems without previously notifying the local sewage EPA Reg 

### No

# I706- Regional Office of the EPA EPA Est

### No l706 IL-I 

# BP EPA st

### No 1706- 

### PA-rEL PHYSICAL 

### AND CHEMICALHAZARDS TRONG OXIDIZING AGENT Mix otily with water according to label .rectiots Mixitig this product with grosa filth such as feces urine etc. or Letter in that matches first letter ri batch number identifies the wjth ammonia acids detergents or other chensiesis will release hazardous gases entabljshme number

initatlttg toeyes lutigs and mucous membranes 

### STORAGE AND DISPOSAL Il AGEstoreiiiacootdrYplsceawnyrndctsunliglitIiicaseofaj Do not conlansinate water food or feed by storage ordisposal 

### 9t3tD 

# KEEPOUTOFREACH OF

# CHILDREN spill flood area will1 large quantities of water PESTICIDE DISPOSAL Product or rinsate that cannot be used should be diluted with water and disposed of in sanitary sewer.Wastes resultimtg from the 

# DST All facility use of this product may be disposed ofon site or at au approved waste disposal IF IN

### EYES Hold eyes open and rinse slowly and gently with and either return empty container to manufacturer or bury in an approved 

### CONTAINER DISPOSAL Rinse empty container thoroughly with water water for 15-20 minutes Remove contact lensea if present after the first minutes then continue rinsing Call poison control tadfill
IF 

## SWALLOWED Call poison control center or doctor center or doctor for treatment advice immediataly for treatment advice Have pernon sip glass of 

# DCTIONS FORUSE ter if able to swallow Do not induce vomiting unless told by It isa violation of Federal Law to use this product in manlier incOnsistent with poison control center or doctor us labeling 

# 9pmM-c IF 

### ON SKIN Take off Contaminated clothing Rinse skin 

# NO with 

### age Use chlorine test kit aiid increase immediately with plen of water for 15-20 minutes Call dosage as necessary to obtaiii the required level ofavailable chlorine poison control center or doctor for treatment advice IF INHALED Move person to freah air If pemon is not or the control bacteria algae and fisigi add this sodium Itypoclilorite solution breathing call 911 or ambulances then give artificial to tower basin distribution box orsome other point in the system tomaaore respiration preferably mouth-to-mouth if possible Call uniform mixing 

# ere poison control center or doctor for treatment advice DIRECTIONS FOR USE CONTINUED 

### ON RI 

### NOTE TO

### PHYSICIN Probable mucosal danage may PANEL contraindicate the use of gastric lavage Measures againt circulatory th shock reapiratoiy depression and convulsion maybe needed Have the 

### MSDS with you when calling poison control center or doctor 

# ppetrDaci orgoing fortreatment

SEE LEFT SIDE PANEL FORADDITIONAL PRECAUTIONARY STATEMENTS Nalco Company 1601 West Diehi Road Naperville IL 60563-1198 Hypochlorjte solution 

## UN1 791 

# PG II 

# ndrti-cC1IT

_s 60735 Wnte 

# s29

LQ SHOWN ELSEWHERE ONCONTAINER

### PRECAUTIONARY 

## STATEMENTS IIA7.ARDS 

### TO 

## HUMANS AND DOMESTIC ANIMALS 

## DANGER CORROSIVE 

## MAY CAUSE SEVERE SKIN IRRITATION 

## OR CHEMICAL BURNS TO 

## BROKEN SKIN CAUSES EYE 

# DAMAGE Do not get in eyes on skin or on clothing Wear goggles or face shield and rubber gloves 

### PVC or Nitsile when handling this product Wash after handling Avoid breathing vapors Vacate poorly ventilated areas as soon as possible Do not return until odors have dissipated 

## ENVIRONMENTAL HAZARDS This pesticide is toxic to fish and aquatic organisms Do not discharge effluent containing this product into laices streams ponds estuaries oceans or other waters unless in accordance with the requirements of National Pollutant Discharge Elimination System 

## NPDES permit and the permitting authority has been notified in writing prior to discharge Do not discharge effluent containing this product to sewrr systems without previously notifying the local sewage treatment plant authority For guidance contact your State Water Board or Regional Office ofthe 

### EPA PHYSICAL 

## AND CHEMICALHAZARDS STRONG OXIDIZING 

### AGENT Mix only with water according to label directions Mixing this product with gsoss filth such as feces urine etc or with 

### ammoni acids detergents or other chemicals will release hazanlous gases irritating toeyes lungs and mucous membranes



# DIRECTIONS 

# FORUSE

It is violation of Frderal Law to use this product ins manner inconsistent with
its labeling 

### NOTE This product degrades with age Use chlonne test kit and increase dosage as necessary to obtain the required level of available chlorine For the control hastens algae and fungi add thissodium hypochlorite solution to tower basin distnhution box or some other point in the system to insure uniform mixing DIRECTIONS FOR USE CONTINUED 034 RIGHT SIDE PANEL 

### NFl ONTENTS SHOWN F.1.SEWFIERE 

### ON CONTAINER 

# ONDEO Nako 

# Nalco7341 MICROORGANISM CONTROL CHEMICAL ACTIVE INGREDIENr

Sodium hwochlorite 115% INERT INGREDIENTS S73%

TOTAL 100.0% EPA Repstration 

### No 70620001 EPA Establishment 

### No 1744-NH-i 00550-GA-tb 

# KEEP

# OUTOF

# REACHOF

# CHILDREN 

# DANGER

SEE LEFT SIDE 

### PANEL FOR ADDITIONAl PRECAITDONARV 

### STATEMENTS 

## ONDEO Nalco Company Ondeo Nalcn Center Napcrville IL 611563.1195 F.MF.RGENCY 

### PHONE 

# NO500 424-9300 

## DIRECTIONS FOR USE continued from left side panel 

### COOLING 

## TOWER EVAPORATIVE 

## CONDENSER WATER AND PULP 

## AND PAPERMIIL 

## WATER SYSTEMS SLUG FEED 

## METHOD

Initial Dose When the system is noticeably fouled add appropnatc amount of 

### NALCO 7341 per 10000 gallons of water in the systemto obtain from to 10 ppm availtrle chlorine Repeat until control is achieved Badly fouled systmss must be cleated before treatment is begun Subsequent Dose When microbial control is evident add appropriate amount of 

### NALCO 7341 per 10000 gallons ofwater in the system daily or sic needed to maintain control endkeep the chlorine residual at ppm 

### INTERMITIENT FEED 

## METHOD

Initial Dose When the system is noticeably fouled add appropriate amount of 

### NALCO 7341 per 10000 gallons ofwater in the system to obtains to 10ppm available chlorine Apply half or 1/3 114 or 1/5 of this initial dose when half or 1/3 1/4 1/5 ofthe water in the system has been lost by blowdown Badly fouled systems must be cleaned before treatment is begun Subsequent Dose When microbial control is evident add appmpnate amount of 

### NALCO 7341 per 10000 gallons of water in the system to obtain ppm residual Apply half or 1/3 1/4 or 1/5 ofthis initial dosc when half or 1/3 1/4 1/5 of the water in the system has been lostby hlowdown 

### CONTINUOUS FEED 

## METHOD

Initial Done When the system is noticeably fouled arId appropnate amount of 

### NALCO 7341 per 10000 gallons in the system to obtain to 10ppm available chlorine Badly fouled systems must be cleaned before trealnsent in begun Subsequent Dose Maintain this treatment level by starting continuous feed of oxofNALCO 7341 per 1000 gallons ofwater lostby blowdown to maintain 1.0 ppm residual 

### METhOD Ounces 

### NALCO 7341/10000 Gallons_Water Slug Feed to obtain 5.10ppm Subsequent Dose to maintain ppm residual 52-104 Ii

Intermittent Feed to obtain 5.10ppm Suhseqoast Dose to masntain ppm residual 52.104
11 ContinuousFeedtoohtain5-loppm Subsequent Dose per 1000 galluns to maintain ppm residual 52-104 

### STORAGE 

## AND DISPOSAL Store in cool dry srea away from direct sunlight In case of spill flood area with large quantities ofwater Rinse empty container thoroughly with water and either retum empty container thoroughly with water and either return empty container to manufacturer or bury in an rproved landfill Product or nnsate that cannot be used should be diluted with water asd disposed of in ii sasitary sewer Wastes resulting from the use ofthis product maybe disposed ofon site or at an approved waste disposal facility Do not contsminste water food or feed by storage or disposal 

## FIRST AID IF IN 

## EYES Hold eyes open and rinse slowly and gently with water for 15-20 minutes Remove contact lenses ifpresent after the first minutes then continue rinsing Call poison control center ordoctor for treatment advice IF 

## SWALLOWED Call poison control center or doctor immediately for treatment advice Have person sip glass of water ifable toswallow 

### Do not induce vomiting unless told by

poison control center ordoctor IF 

## ON SKIN Take off contaminated clothing Rinse skin immediately with plenty of water for 15-20 minutes Call poison control center tsr doctor for treatment advice IF

## INHALED Move person to fresh air If person is not breathing call 911 or ambulances then give artificial respiration preferably mouth-to-mouth if possible Call poison control center ordoctor for treatment advice 

### NOTE TO PHYSICIAN Probable mucosal damage may contraindicate the use of gastric lavage Measures against circulatory shock respiratory depression and convulsion may be needed Have the 

### MSDS with youwhen cslling poison control center or doctor
or going for treatment 

### TREAThENT LEVEL 

### CHART



# JUNS 2fib 

# UUdtheFSSkiRm ldI 

# lpSSed.b Rev 3/2of2uo 

# -e

# PRECAUTiONARYSTATEMENTS HAZARDS TO HUMANS ANDDOMESTIC ANIMALS DANGER CORROSIVE 

# MAY CAUSE SEVERE SKiN 

# AND EYE IRRITATION 

# OR CHEMICAL BURNS TO 

# BROKEN SKIN CAUSES EYE 

# DAMAGE Do not get in eyes on skin or on clothing 

### Wear goggles or face shield and rubber gloves 

# PVC or Nitrile 

### when handling this produet 

### Wash after handling Avoid breathing vapors Vacate poorly ventilated areas as soon as possible fin not return until odors have dissipated 

# ENVIRONMENTAL HAZARDS This pesticide is toxic to fish and aquatic organisms 

## Do not discharge effluent containing this product into lakes streams 

### ponds estuaries oceans or other waters unless in accordance with the requirements of National Pollutant Discharge Elimination System 

# NPDES permit and the permitting authority has been notified in writing prior to discharge 

### Do not discharge effluent containing this product to sewer systems without previously notifying the local sewage treatment plant authority For guidance contact your State Water Hoard or Regional Office ofthe 

# EPA PHYSICAL 

# AND CI-IEMICAL 

# HAZARDS OXIDIZING

# AGENT Mix onlywith water according to label directions Mixing this product with gross filth such as feces ut-the etc or with 

### ammonia acids detergents or other chemicals will release hazardous gases irritating to eyes lungs and 

### mucous membranes 

# otONDEO Nako



# 92WT004
ACTIVE INGREDIENT

Sodium hypochlorite 100/ 

### INERT 

## INGREDtENTS 90%



## TOTAL 100% 

# KEEP

# OUTOF

# REACHOF

# CHILDREN 

# DANGER

SEE SIDE 

## PANEL FORADDITIONAL PRECAUTIONARY 

# STATEMENTS EPA

# REG

# NO 1706-20002 

## EPA EST

# NO 8576-GA-i 

# ONDEO Nalco 

### Company



# ONDEO Nalco Center Naperville IL 60563 

# EMERGENCY PHONE 

# NO 800 424-9300 

# DIRECTIONS 

# FOR

# USE

It is violation of Federal to use this product in manner inconsistent with its labeling 

### COOLING

# TOWER EVAPORATIVE 

## CONDENSER WATER SLIJG 

### FEED 

## METhOD Initial 

### Dose When the system is noticeably fouled add appropriate amount of 

### 92WT004 per 10000 gallons of water in the system In obtain from to 10ppm available chlorine Repeat until control us achieved 

# la Subsequent Dose 

### When mianhial control is evident add appropriate amount of 

### 92WT004 per 10000 gallons of waler in the system daily oras needed to maintain control and keep the chlorine residual at 

### ppm Badly fouled systems mustbe cleaned before treatment isbegun 

### INTERMIYIENT FEED 

## METhOD Initial 

### Dose When the system is noticeably fouled add appropriate amount of

### 92WT004 per 10000 gallons of water in the system to obtain from tn 10 

### ppmavailable chlorine Apply half

### or 1/3 1/4 or 1/5 ofthis initial dose when half

### or 1/3 1/4 or 1/5 ofthe water in the system has been lost byhlowdown Subsequent Dose 

### When niicrohial control is evident add appropriate amount of 

### 92WT004 per 10000 gallons of water in the system to oblain 

### ppm residual Apply halfor 1/3 114 or 1/5 ofthis initial dose when half

### or 1/3 1/4 or 1/5 ofthe water in the system has heen lost byhlowdown Badly fouled systems must he cleaned before trealment is begun 

### CONTINUOUS FEED 

## METhOD Initial 

### Dose When the system is noticeably fouled add appropriate amount of 

### 92WT004 per 10000 gallons ofwater in the system to obtain from to 10

### ppmavailable chlorine Subsequent Dose Maintain this treatment level by starting continuous feed oft or of 

### 92WT004 per 1000 gallons water lost by blowdown tomaintain 1.1 

### ppm residual Badly fouled systems must he cleaned before treatment is begun 

# FiRSTAID
IF IN 

## EYES Hold eyes open and rinse slowly and gently with water for 15-20 minutes 

### Remove contact lenses if present after the first mInutes then continue rinsing Call

poison control center ordoctor for treatment advice IF 

## SWALLOWED Call poison control center or doctor immediately for treatment advice Have person sip glass ofwater If able to swallow 

### Do not induce vomiting unless told by poison control center ordoctor IF 

## ON SKIN Take off contaminated clothing Rinse skin immediately with plenty of water for 15-20 minutes Call poison control center ordoctor for treatment advice IF 

### INHALED Move person to fresh air If person is not breathing call 911 or ambulances then give artificial respiration preferably mouth-to-mouth if possible Call poison control center ordoctor for treatment advice 

## NOTE TO PHYSICIAN Probable mucosal 

### damage may contraindicate Ihe use of gastric lavage Measures against circulatory shock respiratory depression and convulsion 

### may be needed Have the

## MSDS with you

### when calling poison control center or doctor orgoing for treatment 

## SrORAGE 

# AND DISPOSAL Store this product in cool dryarea 

### away from direct sunlight and heat to avoid deterioration In case of spill flood area with large quantities of water Rinse empty container thoroughly with water and either return empty container tomanufacturer or bury in an approved landfill Product or rinsate that cannot be used should he diluted with water and disposed of in sanitary 

### cever Wastes resulting from the use of this product 

### may he disposed of on site or at an approved waste disposal facility 

### Do notcontaminate water food orfeed 

### bystorage ordisposal 

### NET CONTENTS 

## SHOWN ELSEWHERE ONCONTAINER 

## ONLY FORSALE

# TOUSE 

## OR STO LAGE 

# BYSERVICE 

## PERSONSORINDuSTRIAL 

## USER JUN 2003

Under the Federal lnsecticide Fungicide aid Rodenticpde Act as amended forthe pestIcide registered under Rev 3/20/2001 EPA fleg 

### No COOLING 

## TOWER EVAPoRATIVE 

### CONDENSER WATER TREATMENT CHART Ounce 

### 92Wf004 per 

## METHOD 10.000 Gallons Water 68-135 Slug Feed to obtain 5-10 ppm Subsequent Dose 13 Maintain 

### ppm residual 68-135 Intermittent Feed to obtain 5-10 ppm Subsequent Dose 13 Maintain 

### ppm residual 68-135 Continuous Feed To obtain 5-10 

### ppm Subsequent Dose per 1000 gallons 1.5 Maintain 

### ppm residual



### rEsnrsmnNrnNTAm4s sirlrst rrvnnctr 

### ORrTE 1114 

### 1791 ITT

# EXHIBIT

# JNNYSOL 150 ac1Wt INOSOIENT 

# NOMINAL CONCENTEATION.....d 

## SODIUM HVPOCHLOEITE 250t6 INERT 

## INGREDIENTS S7.Oi 

# NVSQL T0YP.L 100-005 

# KEEPOUTOFREACH OFCHILDREN 

# DANGER Soc first 

### aid 

# on side

# panel DIRECTIONS FOR USE If IS 

## VIOLATION OF FEDERAL 

# LAW ía usc fl-ItS 

# PRODUCT IN 

# MANNER INCONSISTENT WITH ITS 

## LABELING NOTE This product 

### degrades with 

### age Use chlorine test kit 

### and increase 

### dosage as 

### necessary to obtain the required level of available chlorine 

## SWIMMING 

# POOLWATER DISINFECTION For 

## new pool or spring start-up superchlorlnate with 

### 52 to 

### 404 oz of product for 

### each 10 

### 000 gallons of water to yield

to 10 

## ppm available chlorine by weight 

### Check the level of available chlorine with test kit Adjust 

### and maintain pool water 

### pH to 

### between tn Adjust 

### and maintain the alkalinity of the pool to 

### between 50 to 100 

## ppm To maintain the pool 

### add manually or by feeder device 11 07 ut this product foreacti 

## 10000 gallons ol

## wate to yield an available chlorine residual 

### betWeen to 

## ppm by weight Stabilized pools should maintain resIdual ot to 

## ppm available chlorine Test the

# pH available chlorine residual 

### and alkalinity of the water frequently with appropriate test kits 

### Frequency of water treatment will

### depend upon temperature 

### and number of swrnlniers Every 

### days or as 

### necessary superchlorinate the pool with 

### 52 to 104 oz of product for

### each 

## ioooo gallons ot water to yield to 10 

## ppm available chlorine byweight 

### Check the level of available chlorIne with tesi kit 

### Do not reenter pool until the chlorine residual is 

### between to 

## ppm At the 

### end of the

### swimming pool

### season or

## when water is to 

### be drained from the 

### pool chlorine 

### must be allowed to dissipate from treated pool water before discharge 

## Do not chlorinate the pool within 7l hours prior io discharge jlrjt 

### HIFING 

# pOOLS vvhile waler IS still clear c-lean apply 07 ol product rei 11110 callure- while liii

## iic urn 11111 to obtain 

## ppm aariable chlorine residual as 

### determined by suitable test kit Cover pool prepare healoi hIlL-I 

### and neater 

### components tarwinter by following 

### manutacturers instructions 

### DISINFECTION 

## OF DRINKING 

# WATER PUBLIC 

## SYSTSh1a Mix ratio of oz of this product to 100 gallons of water Begin teeding this solutIon with nypochlorinator until tree available chlorine residual or at least 

## ppm rind 

### no rnnrr than 

## ppm attairirci lliroughoul the distribLilion systenn 

### Check water irrcltloritly with .i hI rruurr le-l kit in lii irRiJic..ri -.i iripliun liii .1 çurolucted at liequerrcy rio less than that prescribed by tIre National lriteuiili Ieiiuui Ininknrg liVatii l-rquI.ilirri Contact your local Health 

### Department tor further details 

# SEWAGE WASTEWATER EFFLUENT 

# TREATMENT The disinrection of

### sewage effluent 

### mustbe evaluated bydetermining the total 

### number 01 colitorm bacteria and/or tecal coliform bacteria as deteririlned by the 

### Most Probable 

### Number 

# MPN procedure orthe chlorinated effluent 

### has been reduced tO or

### below the 

## maximumpermitted by the controlling regulatory jurisdiction 

## On the 

### average satisfactory disinfection of 

### secondary wastewater effluent 

### can be obtained 

## when the chlorine residual ic 

## ppm after is minutes contact Although the chlorine residual isthe critical factor in disinfection the importance of correlating chlorine residual with bacterial kill 

### must beemphasized The 

# MPN of the erfluent 

### which is directly related to the water quality standards requirements should 

### be the final 

### and primary standard 

### and the chlorine residual should 

### be considered an operating standard valid only to the extent verified bythe coliform quality of the etfluent 

### The rollowing are critical factors affecting 

### wastewater disinfection Mixing It is imperaiive that the product 

### and the

### wastewater he inrrtanlanecrtisly arch rrrrnpletnly llzis ii iriixrrl Icr .iAsrii reaction with every crremrcally active soluble 

### and particulate 

### component ot the war.icwaloi Contacting 

### Upon flash 

### mixing the flow through the 

### systemmust be maintained 

### Dosage/Residual Control Successful disinfection is extremely 

### dependent on response to fluctuating chlorine 

## demand tO maintain 

### predetermined desirable chlorine level 

### Secondary effluent should contain to 

## ppm chlorine residual after 15 to 

### 30 minute contact time resonable average of residual chlorine is pprrr aFter rnrrrules contact tune 

## lease contact your local JCI 

### Jones Cnemrcals Iruc ottice for additional directions trio use 

### Net Contents Gallons 

# Rev 1/01 iervlew 

## Ml MerrInlack 

## NH Cliarlolte 

## NC Ft Lauderdale 

### FL Jackwiiville 

### FL Beech Grove 

### IN MIltord 

## VA Tacouia 

# WA Torrance CA



# uJ

### FIRST AID IF

# ON SKIN 

# ORCLOTF-IINC Take oil 

### contaminated clothing Rinse skin immediately with plenty of water for 15-20 

### minutes Call poison control center or doctor fortreatment advice IF IN 

# EYES Hold 

### eye open and rinse slowly 

### and gently with water for 15 

### 20 minutes 

## Remove contact lenses

if

### present after the first 

### minutesthen continue rinsing 

### eye Call poison control center or doctor treatment advice IF

# SWALLOWED Call poison control center
or doctor immediately for treatment advice 

### Have person sip glass of water if able to swallow 

## Do not induce vomiting unless told to

### do so by the poison control center
or doctor 

## Do not give anything by

### mouth to

### an unconscious person IF

## INHALED Move personto tresh air It person is not Sn eattiii ig call 91 on 

### an ambulance then give artificial respiration preterably 

### by mouth to.-rriouth if possible Call poison control center or doctor for further treatment advice 

### Have the product container or label with 

### you

## when calling poison control center or

# dodd or going fortreatment 

# NOTE TO PHYStCIAN probable rnucosal 

## damage may contraindicate the use of gastric lavage 

# PRECAUTIONARYSTATEMENTS HAZARDS TO HUMANS AND DOMESTIC ANIMALS 

# DANGER Corrosive 

## May cause severe skin irritation or chemical burns to 

### broken skin 

### Causes eye

## damage Do not gel iii 

### eyes on skin or 

### on clothing Vvear goggles or face shield 

### and rubber gloves 

### when handling this product 

## Wash after handling Avoid breattiii vapoi 

### Vacal poorly ventilated areas as 

### soon as possible 

## Do not return until odors 

### have dissipated 

# ENVIRONMENTAL HAZARDS This pesticide is toxic to fish 

### and aquatic organisms 

## Do not dischartp effluent containing this product into 

### lakes sin tsi rn is pci iris sti sir iris

### oceans or public waters unless in acccirdaiict with 11FF requirements ot National Pollutant Discharge Elimination Sysicrn 

# NPDES permit 

### and the pciiiiittiiict iiiihuiily lii liecur irniiliitL iii wiiiuiiff prior to dischargE 

### Do ioi Elisci iii

### gr ciii iimiii cur it .iiiuniu ii ii us pi

### od oct to

### sewer systei tvithout previously notitying the

### sewage treatment plant authority

oi guidance contact your State 

### Water Board or regional office of 

## EPA PHYSICAL 

# ANDCHEMiCAL 

# HAZARDS id 

# STRONG OXIDIZING 

# AGENT Mix only with water according to label directions Mixing this producl with gross tultli 

### such as 

### feces urine etc or with 

### ammonia acids detergents on other chemicals 

## may release 

### hazardous gasses iii ilatung to eyes lungs uuiri unuiicous 

## membranes

JUl tb CC

## tJ 

# TORAGE AND DISPOSAL Storm iliis pncichuct in cool dry area 

### away

kid- 

# fpm direct sunlight 

### and heat to avoid cleteririr atieni in case of spill flood 

## leas with arçp quantities ci waiui Pr odiici ru insates that cannot 

### be 

# ed should 

### be diluted with wateu beioie disposal iii sanitary 

### sewer 

## Do rht reuse 

### emotv container but place in trash collection 

## Do not 

# T\L%4_OO0 contaminate toed orfeed by

### storagc disposal or cleaning of

### equipment

Corporate Ottice Sarasota 

### FL Branch Locations London 

## UK Caledonia 

## NY Warwick 

## NY Barberton 

## OH

cJJ 

### Manufactured By JCI

### Jones Chemicals inc 

# EPA Registration 

## Number 744-20001 

# EPA Establishment 

## Number Put an in 

### permanent ink next to the appropriate establishment 

### below 174-4-CA 144 FL-I /44 1744iN 1744-Mi 744-NC-2 1744-NH 1744-NY 114-4-NY 1144-OH 1744 VA-i 1144-WA 

# tr

IIIIRIIIlE

Hypochiorite Solutions 

## UN 1791 

## PC Ill 

# CAS7681 -52-9 

# RO 100 

### Pounds 

## 200

AN5I/NSF 61 nitikktNu WATN1I II6IAt MFIit Ailtiti tYKS 0N76

# DIRECTIONS

# FORUSE 

# SUNNY

# SOL 150
SWIMMING POOL \VATER DISINFECTION
For nea pool or spring start-up superchlorinate with 52 to 104 

### oz of product for each 10.000 gallons of water to yield to 10 

### ppm available chlorine weight Check the level of available chlorine with test kit Adjust and maintain pool water p14 to between 7.2 to 7.6 Adjust and maintain the alkalinity of the pooi tobetween 50 to IOU

## ppm To maintain the pool add manually or by feeder device ii 

### oz ofthis product foreach 

### 10000 gallons ofwater to yield an available chlorine residual between 0.6 to 1.0 

### ppm by weight Stabilized pools should maintain residual of 1.0 to 1.5 

### ppm available chlorine Test the

# pH available chlorine residual and alkalinity ofthe water frequently with appropriate test kits Frequency ofwater treatment willdepend upon temperature and number of swimmers Every days oras necessary superchlorinate the pool with 52 to 104

### oz ofproduct foreach 

### 10000 gallons ofwater to yield to 10 

### ppm available chlorine byweight Check the level ofavailable chlorine with test kit 

### Do not reenter pool until the chlorine residual is between 1.0 to 3.0

## ppm
At the end of the ssimming pool season or

### when water is to be drained from the pool chlorine mustbe allowed to dissipate from treated poolwater before discharge 

### Do not chlorinate the pool within 24 hours prior to discharge 

### WINTERIZING 

## POOLS While water is still clear clean apply 

### oz ofproduct per 1000 gallons while filter is running to obtain 

### ppm available chlorine residual as determined by suitable test kit Cover pool prepare heater filter and heater components for winter byfollowing manufacturers instructions 

## SPAS hOT-TUBS IMMERSION 

# TANKS ETC SPAS/lCD -1 

## UBS Apply 

### cc of product per 

### WOO gallons ol water to obtain free available chlorine concentration of5

## ppm as determined by suitable chlorine test kit Adjust and maintain pool water p1-I tobetween 7.2 and 7.8

### Some oils lotions fragrances cleaners etc 

### may cause foaming

orcloud water as well as reduce the efficiency of the product 

### To maintain the water apply oz ofproduct per 1000 gallons ofwater over the surface to maintain chlorine concentration of 

## ppm
After each use shock treat ith oz of this product per 500 gallons of water to control odor and algae During c\unded periods ofdisuse ado 

### oz of product daily per 1000 gallons of ater to maintain 

### ppm chlorine concentration

II.IBBARD 

# AND l\tMERSION 

## TANKS Add ozofthisproduct per 200 gatlons ofwater before patient use in obtain chlorine residual of 25 

## ppm as determined suitable test kit Adjust and maintain the sater p1-1 to between 7.2 and 7.6 After each use drain the tank 

### Add oz to bucket of water and circulate this solution throughout the agitator of the tank for 15 minutes and then rinse out the solution Clean tank thoroughly and dry and clean cloths

Not appo\ cd for thisuse in the State of California 

### ItYDRO 

# ERAPY TANKS Add oi ci this product per 1000 gallonsof water to obtain chlorine residual of 

## ppm as dctemnned by suitable chlorine test kit Pool should not be entered until the chlorine residual isbelow 

## ppm Adjust and maintain the water pFT to hetwcen 7.2 and 7.6 Operate pnoi 10cr 

### continuouy Dra.ii pool weekly and clean hefare jefillino

# \V COMI4IElTS inFALctterDat2d 

# MAR 2001
fur tOic o.cai in ecuctde 

### ._iciw.incit.cueAOtas 44



### dod nr the pestietl 

### rcd UIIdLI 

### LiA

# Re No

JCI Jones Chemicals Inc Sunny Sol 150- 

## EPA

# REG

# NQ 1744-20001 

### .444

# $7

SANITIZATION 

## OF NONPOROUS FOOD CONTACT SURFACES RINSE 

# METHOD solution of100 

### ppm available chlorine 

### may be used in the sanitizing solution if chlorine test kit is available Solutions containing an initial concentration of 100

### ppm available chlorine mustbe tested and adjusted periodically to insure that the available chlorine does not drop below 50

## ppm Prepare 100

### ppm sanitizing solution bythoroughly mixing 

### ozofthisproduct with 10 gallons ofwater Ifno test kit is available prepare sanitizing solution bythoroughly mixing 

### oz of this product with 10 gallons ofwater to provide approximately 200 

### ppm available chlorine bs weight Clean equipment surfaces in the normal 

### manner Prior touse rinse all surfaces thoroughly with the sanitizing solution maintaining contact with the sanitizer for at least minutes Ifsolution contains less than 50 

### ppm available chlorine as determined by suitable test kit either discard the solution oradd sufficient product to reestablish 200 

### ppm residual 

### Do not rinse equipment with water after treatment and do not soak equipment overnight
Sanitizers used in automated systems 

### may be used for general cleaning but 

### may not be re-used for sanitizing purposes 

## IMMERSION 

# METHOD solution of 100 

### ppm available chlorine 

### may be used in the sanitizing solution if chlorine test kit is available solutions containing an initial concentration of 100 

### ppm available chlorine must be tested and adjusted periodically to insure that the available chlorine does not drop below 50

## ppm Prepare 100

### ppm sanitizing solution bythoroughly mixing 

### oz ofthis product with 10 gallons ofwater If no test kit is available prepare sanitizing solution bythoroughly mixing 

### oz ofthis product with 10 gallons of water to provide approximately200 

### ppm available chlorine by weight Clean equipment in the normal 

### manner Prior to use immerse equipment in the sanitizino solution for at least minutes and allow the sanitizer to drain If solution contains less than 50 

### ppm available chlorine as determined by suitable test kit either discard the solution oradd sufficient product to reestablish 200 

### ppm residual 

### Do not rinse equipment with water after treaunent
Sanitizers used in automated systems 

### may be used for general cleaning but 

### may not be re-used for sanitizing purposes 

## FLOW/PRESSURE 

# METHOD Disassemble equipment and thoroughly clean after use Assemble equipment in operating position priorto use Prepare volume of 200 

### ppm available chlorine sanitizing solution equal to 

### 110%ofvolume capacity ofthe equipment mixing the product in ratio of 

### oz product with 10 gallons ofwater 

### Pump solution through the system urtil full flow is obtained at all extremities the system completely filled with the sanitizer and all air isremoved from the system Close drain valves and holdunder pressure forat least niinutesto insure contact with all internal surfaces 

### Remove some cleaning solution fromdrain valve and test with chlorine test kit Repeat entire cleaning/sanitizing process if effluent contains less than 50 

### ppm available chlorine 

## CLEAN-IN-PLACE

# METHOD Thoroughly clean equipment after use Prepare volume of 200 

### ppm available chlorine sanitizing solution equal to 

### 110% ofvolume capacity oftheequipment by mixing the product in ratioof 

### oz product ss ith 10 gallons ofwater 

### Pump solution through the system until full flow isobtained at all extremities the system is completely filled with the sanitizer and all air is removed from the 

### sstem Clnse drain valve and hold under pressure for at least 10 minutes to insure contact ss ith all internal surfaces 

### Remove some cleaning solution from drain valve and test with chlorine test kit Repeat entire cleaning/sanitizing process ifeffluent contains less than 50 

### ppm available chlorine 

## SPRAY/FOG 

# METhOD Preclean all surfaces after use Use 200 

### ppm available chlorine solution to control bacteria mold orlungi and 600 

### ppm solution to control bacteriophage Prepare 200 

### ppm sanitizing solution of sufficient sizebythoroughly mixing the product in ratioof 

### oz product with 10 gal Ions ofwater Prepare 600 

### ppm solution bythoroughly mixing the product in ratioof 

### oz product sith 10 gal Ions ofwater Use spray orfogging equipment which can resist hypochiorite solutions AIss ays empty and rinse spray/fog equipment ith potable water after use Thoroughly spras orfog all surfaces until 

### wet allowing excess sanitizer to drain Vacate area for at least hours Prior tousing equipment rinse all surfaces treated with 600 

### ppm solution with 200 

### ppm solution

ISS Ii 

## 55551
IC

JCIJones Chemicals Inc Sunny Sol 150- 

## EPA

# REG

# NO 1744-20001

### SANITJZATION 

## OF POROUS FOOD CONTACT SURFACES RINSE 

# METHOD Prepare 600 

### ppm solution bythoroughly mixing 

### oz of this product with 10 gallons ofwater Clean surfaces in the normal 

### manner Rinse all surfaces thoroughly with the 600 

### ppm solution maintaining contact forat least minutes Prepare 200 

### ppm sanitizing solution bythoroughly mixing 

### oz of this product with 10 gallons ofwater Prior to using equipment rinse all surfaces with 200 

### ppm available chlorine solution 

### Do not rinse and do not soak equipment overnight 

## IMMERSION 

# METHOD Prepare 600 

### ppm solution bythoroughly mixing in an immersion tank 

### oz of this product with 10 gallons ofwater Clean equipment in the normal 

### manner Immerse equipment in the 600

### ppm solution for at least minutes Prepare 200

### ppm sanitizing solution thoroughly mixing 

### oz of this product with 10 gallons ofwater Prior to using equipment immerse all surfaces in 200 

### ppm available chlorine solution 

### Do not rinse and do not soak equipment overnight 

## SPRAY/FOG 

# METHOD Preclean all surfaces after use Prepare 600 

### ppm available chlorine sanitizing solution of sufficient size bythoroughly mixing the product in ratioof 

### oz product with 10 gallons ofwater Use spray orfoggingequipment which can resist hypochlorite solutions Always empty and rinse spray/fog eqoipment with potable water after use Thoroughly spray orfog all surfaces until

### wet allowing excess sanitizer todrain Vacate area for at least hours Prior io using equipmeni rinse all surfaces with 200 

### ppm available chlorine solution Prepare 200 

### ppm sanitizing solution bythoroughly mixing oz of thisproduct with 10 gallons ofwater 

## SANITIZATION 

## OF NONPOROUS NON-FOOD CONTACT SURFACES RINSE 

# METHOD Prepare sanitizing solution bythoroughly mixing 

### oz of this product with 10 gallons ofvaterto provide approximately 200 

### ppm available chlorine by weight Clean equipment surfaces in the normal 

### manner Prior touse rinse all surfaces thoroughly with the sanitizing colution maintaining contact with the sanitizer for at least minutes 

### Do not rinse equipment with water after treatment and do not soak equipment overnight 

### IN1MERSION 

# METHOD Prepare sanitizing solution bythoroughly mixing in an immersion tank 

### ozof this product with 10 gallons ofwater to provide approximately 200 

### ppm available chlorine by weight Clean equipment in the normal 

### manner Prior to use immerse equipment in the sanitizing solution for at least minutes and allo the sanitizer to drain 

### Do not rinse equipment with water after treatment 

## SPRAY/FOG 

# METHOD Prcclean all surfaces after usc Prepare 200 

### ppm available chlorine sanitizing solution of sufficient size thoroughly mixing the product in ratio of 

### oz product with 10 gallons ofwater Use spray orfogging equipment which can resist hvpochlorite solutions Prior to using equipment thoroughly spray or fog all surfaces until

### wet allowing excess sanitizer to drain Vacate area for at least hours 

### DISINFECTION 

## OF NONPOROUS NON-FOOD CONTACT SURFACES IUNSE 

# METHOD Prepare disinfectino solution bythoroughly mixing 

### ozof this product ith 10 gallons ofwaterto provide approximately 600 

### ppm available chlorine weight Clean cquinmer.t surfaces in the normal 

### manner Prior to use rinse all surfaces thoroughi with the disinfccting solution maintaining contact with the solution for at least 10 minutes do not rinse equipment with water after treatment and do not soak equipment o\ ernight 

## IMMERSION 

# METHOD- Prepare disinfectino solution bythoroughly mixing in an immersion tank 

### ozof this product with 10 gallons ofwater toprovide approximately 600 

### ppm available chlorine by weight Clean equipment in the disinfecting solution for at least JO minutes and allow the sanitizer to drain 

### Do not rinse equipment with tater after treatment



# e.eI S. ft

JCIJonesChemicals Inc Sunny Sol 150- 

## EPA

# REG

# NO 1744-20001

# 3/

SANIT1ZATION 

## OF POROUS NON-FOOD CONTACT SURFACES RINSE 

# METHOD Prepare sanitizing solution bythoroughly mixing 

### ozof this product with 10 gallons of water toprovide approximately 600 

### ppm available chlorine by weight Clean surfaces in the normal 

### manner Prior touse rinse all surfaces thoroughly with the sanitizing solution maintaining contact with the sanitizer forat least minutes 

## Do not rinse equipment with water after treatment and do not soak equipment overnight 

## IMMERSION 

# METHOD Prepare sanitizing solution bythoroughly mixing in an immersion tank oz ofthis product with 10 gallonsofwaterto provide approximately 600 

### ppm availahle chlorine by weight Clean equipment in the normal 

### manner Prior to use immerse equipment in the sanitizing solution for at least minutes and allow the sanitizer todrain 

### Do not rinse equipment with water after treatment 

## SPRAY/FOG 

# METHOD After cleaning sanitize non-food contact surfaces with 600 

### ppm available chlorine by thoroughly mixing the product in ratioof 

### oz ofthisproduct with 10 gallons ofwater Use spray orfoggingequipment which can resist hpochlorite solutions Always empty and rinse spray/fog equipment with potable water after use Prior to using equipment thoroughly spray or fog all surfaces until 

### wet allowing excess sanitizer to drain Vacate area for at least hours 

# SEWAGE WASTEWATER EFFLUENTTREATMENT
The disinfection ofsewage effluent must be evaluated bydetermining the total number of coliform bacteria and/or fecal coliform bacteria as determined by the Most Probable 

### Number

# MPNprocedure of the chlorinated effluent has been reduced to orbelow the

### maximum permitted by the controlling regulatory jurisdiction 

### On the average satisfactory disinfection of secondary wastewater effluent can be obtained then the chlorine residual is0.5 

### ppm after 15 minutes contact Although the chlorine residual is the critical factor in disinfection the importance of correlating chlorine residual with bacterial kill must be emphasized The

# MPN of the effluent which is directly related tothe water quality standards requirements should be the final and primarystandard and the chlorine residual should be considered an operating standard valid only to the extent verified by the coliform quality of the effluent The following are critical factors affecting wastewater disinfection 

### Mixing It is imperative that the product and the wastewater be instantaneousl and completely flash mixed to assure reaction with 

### even ehemicall actie soluble and particulate component of the 

### 1e\vater Contacting 

### Upon flash mixing the flow through the system must be maintained Dosage/Residual Control Successful disinfection is extremely dependent on response to fluctuating chlorine 

### demand to maintain predetermined desirable chlorine level Secondary effluent should contain to 1.0 

### ppm chlorine residual after iS to 30 minute contact time reasonable average of residual chlorine is 0.5 

### ppm after IS minutes contact time 

## SEWAGE 

# AND WASTEWATER TREATMENT EFFLUENT SLIME 

## CONTROL Apply 100 to 1000 

### ppm ailabie chlorine solution at oction vhich vill allo\ complete mixing Prepare this solution by mixing lOto 100 

### or of this product with 100 gallons ofwater Once control isevident appl 15 

### ppm available chlorine solution Prepare this solution by mixing 1.5 

### oz of thisproduct with 100 gallons ofwater 

### FILTER 

## BEDS SL1ME 

# CONTROL Remove filter fromservice drain to depth of ft abate filter sand and add 

### 8Ooi ofproduct per 20 sq/f etenlv over the surface Wait 30 minutes before draining water to level that is et en tb the top of the filter Wait for to hours before completely draining and backwashing filter



## sets. III 

# tlIt

CC 

## CCI JCI Jones Chemicals Inc Sunny 

# Sol 150- 

## EPA

# REG

# NO 1744-20001

# 1/3

DISINFECTION 

## OFDRINKING 

# WATER EMERGENCY/PUBLJC/INDIVIDUAL 

# SYSTEMS PUBLIC 

# SYSTEMS Mix ratio of 

### oi of thisproduct to 100 gallons ofwater Begin feeding this solution with hypochiorinator until free available chlorine residual of at least 0.2 

### ppm and no more than 0.6 

### ppm is attained throughout the distribution system Check water frequently with

chlorine test kit Bacteriological sampling must beconducted at frequency no lessthan that prescribed bythe National interim Primary Drinking Water Regulations Contact 

### our local Health Department for further details 

### INDIVIDUAL 

## SYSTEMS DUG WELLS Upon completion ofthe casing lining wash thc interior ofthe casing lining with 100

### ppm available chlorine solution using stiff brush This solution can be

### made bythoroughly mixing 

### or of this product into 10 gallons ofwater After covering the well pour the sanitizing solution into the well through both the pipe sleeve opening and the pipeline 

### Wash the exterior ofthe

### pump cylinder also with the sanitizing solution Start

### pump and

### pump water until strong odor of chlorine in water isnoted Stop 

### pump and wait at least 24hours After 24 hours flush well until all traces of chlorine have been removed from the water Consultyour local Health Department for further details 

### INDIVIDUAL 

# WATERSYSTEMS DRILLED DRIVEN BORED WELLS -Run pump until water is as free from turbidity as possible Pour 100

### ppm available chlorine sanitizing solution into the well This solution can be 

### made bythoroughly mixing 

### oz ofthis product into 10 gallons of water 

### Add to 10 gallons ofclean chlorinated water to the well in order to force the sanitizer into the rock formation \Vash the exterior of

### pump cylinder with the sanitizer 

## Dro pipeline intowell start

### pump and 

### pump water until strong odor of chlorine in water is noted Stop

### pump and wait
at least 24 hours After 24 hours flush well until all traces of chlorine have been removed from the water Deep wells with high water levels 

### may necessitate the use of special methods for introduction of the sanitizer into the well Consult your local Health Department for further details 

### INDIVIDUAL \VATER 

## SYSTEMS FLOWING ARTESIAN WELLS Artesian wells generally do not require disinfection fanalyses indicate persistent contantination the well should be disinfected Consult your local Iealth Department for further details 

# EMERGENCY DISINFECTION When boiling ofwater for minute is not practical water can be made potable by using this product Prior to addition of the sanitizer remove all suspended material by filtration or by allowing it to settle to the bottom Decant the cla.cjFed contaminated water to clean container and add drop of this product to

### 20 gallons ofwater Allow the treated water to stand for30 minutes Properly treated water should have slight chlorine odor ifnot repeat dosage and allow the water to stand and additional 15 minutes The treated water can then be 

### made palatable pouring it between clean containers for several times 

### PUBLIC 

# WATER SYSTEMS RESERVOIRS ALGAE 

# CONTROL l-lvpochlorinate streams feeding the reservoir Suitable feeding points should he selected on each stream at least 50 yards upstream from the points of entry into the reservoir 

## MAINS Thoroughly flush seetton to be sanitized discharging from hydrants Permit water flow of at least 2.5 feet per minute to eoniinue under pressure while injecting this product bymeans ofahvpechlorinator Stopwater flow

### when chlorine residual test ofSO 

### ppm is obtained at the low pressure end of the 

### new matn section after 24 hour retention time 

### When chlorination is completed the system most be flushed free of all heavily chlorinated water 

# NEW TANKS BASINS ETC.- 

### Remove afi physical soil from surfaces. Place 20

### orof this product foreach cubic fee

# of orking capaeit 500 

### ppm available chlorine Fill to working capacity and allow to stand for at least hours Drain and flush with potable water and return tosurface 

# NEW FILTER 

## SAND Apply 

### SOor ofthis product foreach 150 to200 cubic feet ofsand The action of the product dissolving as the water passes through the bed will aid in sanitizing the 

### new sand 

# NEW \VELLS Flush the casin with 50 

### ppm available chloninc solution ofwater containing 

### or ofdnis product foreach lEO gallons ofwater The solution should be 

### pumped or fed gravity into the well after thorough mixing with agitation The well should stand for several hours or overnight under chlorination It 

## ay then he 

### pumped until representative raw water sample isobtained Bacterial examination of the 

### wite fl indicate hether further treatment is necessar. 

### EXISTING 

## EQUIPMENT Remove equipment from service thoroughly clean surfaces of all

## ph steal soil Sanitize placing 20 oz. cf this product foreach cubic feet capacity approximately 500 

### ppm available chlorine Fill toworking capacity and let stand at least hours Drainand place in service Ifthe previous treatment isnot practical surfaces 

### may besprayed with solution containing 

### 01 of this produe foreach 

### SgaM.n9 ofwater approximately 1000 

### ppm available chlorine Afterdrying flush with water and return to service

JCIJones Chemicals Inc Sunny Sol 150- 

## EPA

# REG

# NO 1744-20001

# EMERGENCY DISINFECTION 

## AFTER FLOODS WELLS Thoroughly flush contaminated casing with 500 

### ppm available chlorine solution Prepare thissolution bymixing 

### OL of this product with 10 gallons ofwater Backwash the well to increase yield and reduce turbidity adding sufficient chlorinating solution to the backwash to produce 10 

### ppm available chlorine residual as determined by chlorine test kit After the turbidity has been reduced and the casing has been treated add sufficient chlorinating solution toproduce 50 

### ppm available chlorine residual Agitate the well water for several hours and take representative water sample Retreat well if water samples are biologically unacceptable 

## RESERVOIRS In case ofcontamination byoverflowing streams establish hypochiorinating stations upstream of the reservoir Chlorinate the inlet water until the entire reservoir obtains 0.2 

### ppm available chlorine residual as determined by suitable chlorine test kit In case ofcontamination from surface drainage applysufficient product directly to the reservoir to obtain 0.2 

### ppm available chlorine residual in all parts of the reservoir 

## BASINS 

# TANKS FLUMES ETC Thoroughly clean all equipment then apply20

### ozofproduct per 

### cu ftofwater to obtain 500 

### ppm available chlorine residual as determined by suitable test kit After 24 hoursdrain flush and return to service Ifthe previous method isnot suitable spray orflush the equipment with solution containing 

### ozofthisproduct foreach gallons ofwater 

### 1000 ppm available chlorine Allow to stand for

to hours flush and return to service 

### FILTERS When the sand filter needs replaeemenL apply80

### oz ofthisproduct for each 150 to200 cubic feetofsand 

### When the filter is severely contaminated additional product should be distributed over the surface at the rate ofSO

### oz per 20

### sq ft. Water should stand at depth of foot above the surface ofthe filter bed for to24 hours 

### When filter beds can be backwashed of

### mud and siltapply80

### oz ofthis product per each 50

### sq ft. allowing the water to stand at depth of foot above the filter sand After 30 minutes drain water to the level of the filter .After to hours drain and proceed with normal backwashing 

### DISTRIBUTION 

## SYSTEM flush repaired orreplaced section with water Establish hypochlorinattng station and apply sufficient product until consistent available chlorine residual of at least 10 

### ppm remains after 24 hour retention time Use chlorine test kit 

# EMERGENCY DISINFECTION 

## AFTER FIRES 

## CROSS CONNECTIONS OR

# EMERGENCY CONNECTIONS Hypochlorination or gravit feed equipment should beset up near the intake of the untreated ater supply Apply sufficient product to give achlorine residual ofat least 0.1 to 0.2 

### ppm at the point wlier the untreated supplyenteN the regular distribution system Use chlorine test kit 

## EMERGENCY DISINFECTION 

## AFTER DROUGHTS SUPPLEMENTARY 

# WATERSUPPLIES Gravity ormechanical hypochlorite feeders should be set up on supplementary line to dose the water to



### minimum chlorine residual of0.2 

### ppm after 20 minute contact time Use chlorine test kit \V.ATER 

### SHIPPED IN

## BY

# TANKS TANK 

# CARS TRUCKS ETC Thoroughly clean all containers and equipment Spray 500 

### ppm available chlorine solution and rinse with potable water after minutes This solution is

### made by mixing oz of this product for each 10 gallons ofwater During the filling ofthe containers dose with sufficient amounts ofthis product to provide at least 0.2 

### ppm chlorine residual t.se chlorine test kit 

# EMERGENCY DtSINFECTION 

## AFTER MAIN BREAKS MAINS Before assembly of the repaired section flush out 

### mud and soil Permit water flow of at least 2.5 feet per minute to continue under pressure while injecting this product bymeans ofa hypoehiorinator Stop water flowwhen chlorine residual test of 5ii

### ppm isobtained at the low pressure end ofthe 

### new main section after 24 hour retentiontime 

### When chlorination is completed the system must be flushed freeof all heavily chlorinated water



## SSStt 

# 4q S.... 

# 44.

44 itt JCIJones Chemicals Inc Sunny Sol 150- 

## EPA

# REG

# NO 1744-20001

## COOLING TOWER/EVAPORATIVE CONDENSER 

# WATER SLUG FEED 

# METHOD Initial 

### Dose When system is noticeably fouled apply52 to 104 

### oz ofthis product per 

### 10000 gallons ofwater in the system to obtain from to 10 

### ppm available chlorine Repeat until control is achieved Suhsequent 

### Dose When microbial control is evident add 11 

### oz of thisproduct per 

### 10000 gallons ofwater in the system daily or as needed to maintain control and keep the chlorine residual at 

## ppm Badly fouled systems must be cleaned before treatment is

### begun 

## INTERMITTENT FEED 

# METHOD Initial 

### Dose When system is noticeably fouled apply 52 to 104 

### oz of thisproduct per 10.000 gallons of water in the system to obtain to 10 

### ppm available chlorine Apply halfor 1/3 1/4 nr 1/5 of this initial dose 

### when half 

### or 1/3 1/4 or 1/5 of the water in the system has been lost by 

### blowdown Subsequent 

### Dose When microbial control isevident add 11 

### oz ofthis product per 

### 10000 gallons ofwater in the system to obtain 

### ppm residual Apply half 

### or 1/3 1/4 or 1/5 ofthis initial dose 

### when half 

### or 1/3 1/4 or 1/5 of thewater in the system hasbeen lost by

### blowdown Badly fouled systems must be cleaned before treatment is

### begun 

## CONTINUOUS FEED 

# METHOD Initial 

### Dose When system is noticeably fouled apply52 to 104 

### oz of this product per 10.000 gallons ofwater
in the systent to obtain to 10 

### ppm available chlorine Subsequent 

### Dose Maintain thistreatment level by starting continuous feed of 

### oz of this product per 1.000 gallons ofwater lost byblowdown to maintain 

### ppm residual Badly fouled systems must be cleaned before treatment is

### begun 

## BRIQUETTES ORTABLETS Initially slug dose the system with 52 

### oz of this product per 10.000 gallons ofwater in the system Badly fouled systems must he cleaned before treatment is begun Subsequent 

### Dose When microbial control is evident add II 

### oz of this product per 

### 10000 gallons ofwater in the system daily or as needed to maintain control and keep the chlorine residual at 

## ppm Badly fouled systems must be cleaned before treatment is

### begun 

## HOUSEHOLD LAUNDRY SANITIZERS
IN

## SOAK1NG SUDS Thoroughly mix 

### oz of this product to 10 gallons ofwash water to provide 200 

### ppm available chlorine 

### WaitS minutes then add soap ordetergent Immerse laundry for at least Il minutes prior to starting the wash/rinse cycle IN

## WASHING SUDS Thoroughly mix 

### ozof this product to 10 gallons ofwash water containing clothes to provide 200 

### ppm available chlorine Wait minutes then add soap or detergent and start the wash/rinse cycle 

# COMMERCIALLAUNDRY SANITIZERS Wet fabrics or clothes should he spun dry priorto sanitization Thoroughly mix 

### oz of this product with 10 gallons ofwater to yield 200 ppoi available chlorine Promptly after fluxing the sanitizer add the solution into the prewash priorto washing fabrics/clothes in the regular wash cycle with good detergent Test the level ofavailable chlorine ifsolution has been allowed tostand 

### Add moreof this product ifthe available chlorine level has dropped below 200 

## ppm 

# FARM PREMISES Remove all animals poultry and teed from premises vehicles and enclosures 

### Remove all litter and manure from floors walls and surfaces of barns pens stalls chutes and other facilities occupied or transverse by animals orpoultry Empty all troughs racks and other feeding and watering appliances Thoroughly clean all surfaces with soap ordetergent and rinse with water 

### To disinfect saturate all surfaces with solution of at least 1000 

### ppm available chlorine for period of 10 minutes 1000 

### ppm solution can he made bythoroughi mixing 11 

### ox

## oths rtroduct with 10 gallons ofwater Immerse all halters ropes and other types ofequipment used in handlingand restraining animalsor

### poultrt tvjtl as the cleaned forks shovels and scrapers used forremoving litter and 

### manure Ventilate buildings earsboats and other closed spaces 

### Do not house livestock or poultry oremploy equipment until chlorine has been dissipated All treated feed racks mangers troughs automatic feeders fountains and waterers must be rinsed with potable water before reuse flU .5 

# 444

JCI Jones Chemicals Inc Sunny 

## So 150- 

## EPA 

# REG

# NO 1744-20001 

### 55$5 

# SS.S

## PULP

# AND PAPER MILL 

## PROCESS 

# WATER SYSTEMS SLUG FEED 

# METHOD Initial 

### Dose When system isnoticeably fouled apply52 to 104 of this product per 10.000 gallons ofwater in the system to obtain from to 10 

### ppm available chlorine Repeat until control is achieved Subsequent 

### Dose 

## When microbial control is evident add 11 or.of this product per 10.000 gallons ofwater in the system daily oras needed to maintain control and keep the chlorine residual at 

## ppm Badly fouled systems must be cteaned before treatment is

### begun 

## INTERMITTENT FEED 

# METHOD initial 

### Dose When system is noticeably fouled apply 5210 104 

### or of this product per 10.000 gallons of water in the system to obtain to 10 

### ppm available chlorine Apply halfor 1/3 1/4 or2/5 of this initial dose when half 

### or 1/3 

## 14 or 1/5 ofthe water in the system has been lost by

### blowdown Subsequent 

### Dose When microbial control isevident add 11 or. of this product per 10.000 gallons ofwater in the system to obtain 

### ppm residual Apply halfor 1/3 1/4 or 1/5 of this initial dose 

### when halfor 1/3 1/4 or 1/5 ofthe water in the system has been lost by

### blowdown Badly fouled systems must be cleaned before treatment is

### begun 

## CONTINUOUS FEED

# METHOD Initial 

### Dose When system is noticeably fouled apply 52 to 104

### oz of this product per 10.000 gaflons of water in the system to obtain to 10 

### ppm available chlorine Subsequent 

### Dose Maintain this treatment level by starting continuous feed of 

### oz of this product per 1.000 gallons ofwater lost byblowdown to maintain 

### ppm residual Badly fouled systems must be cleaned before treatment is begun 

## BRIQUETTES 

# ORTABLETS Initially slug dose the system with 52 or. of this product per 10.000 gallons ofwater in the system Badly fouled systems must be cleaned before treatment is begun Subsequent 

### Dose When microbial control is evident add II oz- of this product per 

### 10000 gallons ofwater in the system daily oras needed to maintain control and keep the chlorine residual at 

## ppm Badly fouled systems must be cleaned before treatment is

### begun 

## AGRICULTURAL USES 

## POST-HARVEST PROTECTION Potatoes can be sanitized after cleaning and priorto storage by spraying with sanitizing solution at level oil gallon of sanitizing solution per tons of potatoes Thoroughly mix or.of this product to gallons ofwater to obtain 500 

### ppm available chlorine

Disinfect lcafcutting bee cells and bee boards by immersion in solution containing 

### ppm available chlorine 

### for minutes 

### Allo cells to drain for

minutes and dry for to hours or until no chlorine odor can be detected This solution is

### made bythoroughly mixing tsp ofthis product to 100 gallons ofwater The bee domicile is disinfected by spraying with 0.1 

### ppm solution until all surfaces are thoroughly

### wet A1lo the domicile to dry until all chlorine odor has dissipated 

## FOOL EGG SANITIZATION Thoroughly clean all eggs Thoroughly mix 

### orof thisproduct with 10 gallons of

### warm water to 

### roduce 200 

### ppm available chlorine solution The sanitizer temperature should not exceed 

## 130F Spray the 

### warm sanitizer so that the eggs are thuroughl wetted Allow the eggs tothoroughly dry before casing orbreaking 

### Do not apply potable water rinse The solution should 

## no be re-used to sanitize eggs 

### FRUIT 

## VEGETABLE WASHING Thoroughly clean all fruits and vegetables in wash tank Thoroughly mix 

### or of this product in 200 gallons ofwater to

### make sanitizing solution of25 

### ppm available chlorine After draining thetank submerge fruit orvegetables for

# wominutes in

second wash tank containing the recirculating sanitizing solution Spray rinse vegetables with the sanitizing sotution pnor to 

### pacreing Rinse fruit with potable water only prior topackaging



## Isic.

JCIJones Chemicals Inc Sunny Sol 150 

## EPA 

# REG

# NO 1744-2000 

## ttt

## AQUACULTIJRAL USES FISH 

## PONDS Remove fish fromponds prior to treatment Thoroughly 

### mix 104 

### ozof this product to 

### 10000 gallons ofwater to obtain 10

## ppm available chlorine 

### Add more product to the water if the available chlorine level is below 

### ppm alterS minutes Return fish to pond ficr the available chlorine level reaches zero 

### FISH 

## POND EQUIPMENT Thoroughly clean all equipment prior to treatment Thoroughly mix 

### oz of thisproduct to 10 gallons ofwater to obtain 200 

### ppm available chlorine Porous equipment should soak forone hour 

## MAINE LOBSTER PONDS Remove lobsters seaweed etc from ponds prior to treatment Drain the 

### pond Thoroughly 

### mix6200 oz of this product to 

### 10000 gallons ofwater to obtain at least600 

### ppm available chlorine Apply so that all barrows gates rock and 

### dam are treated with product Permithigh tide to fill the pond and then close gates Allow water to stand for to days until the available chlorine level reaches zero 

### Open gates and allow tidal cycles to flush the pond before returning lobsters to

### pond 

## CONDITIONJNG LIVE

## OYSTERS Thoroughly mix 

### oz ofthis product to 

### 10000 gallons ofwater at50 to

## 70F to obtain 0.5 

### ppm available chlorine Expose oysters to thissolution for at least 15 minutes monitoring the available chlorine level so that it does not fall below 0.05 

## ppm Repeat entire process ifthe available chlorine level drops below 0.05 

### ppm orthe temperature falls below

# 50F

Not approved for this use in the State ofCalifornia 

## CONTROL OF SCAVENGERS IN 

### FISH 

## HATCHERY PONDS Prepare solution containing 200 

### ppm of available chlorine by mixing 

### ozof pruduct with 10 gallons of water Pour into drained pond potholes Repeat ifnecessary 

### Do not put desirable fish back into refilled ponds until chlorine residual has dropped to 

## ppm as determined by test kit 

### SANITIZATION OF DIALYSIS 

## MACHINES
Flushequipment thoroughly with water priorto using this product Thoroughly mix 

### ozof thisproductto lOgallons ofwaterto obtain at least 600 

### ppm available chlorine Immediately use this product in the hemodialysate system allowing for 

### minimum contact time of 15 minutes of

# 20C Drainsystem ufthe sanitizing solution and thoroughly rinse with water Discard and

# DONOT reuse the spent samtizer Rinsate must hemonitored with suitable test kit to insure that no available chlorine remains in the system This product isrecommended fordecontaminating single and multi-patient hemodialysate systems Thisproduct hasbeen 

### shown to be an effective disinfectant virucide fungicide bactericide pseudomonicide 

### when tested by

# AOAC and

## EPA test methods This product 

### may not totally eliminate

all vegetative microorganisms in hemodialysate delivery systems due to their construction and/or assembly but can be relied upon toreduce the number of microorganisms to acceptable levels 

### when used as directed This product should be used in disinfectant program which includes bacteriological monitoring of the hemodialysate delivery system This product is

# NOTrecommended foruse in hemodialysate orreverse osmosis 

# ROmembranes Consultthe guidelines for hemodialysate systems which are available from the Hepatitis Laboratories 

# CDC Phoenix 

## AR85021

Please note This product is not to be used as terminal sterilant/high level disinfectant on any surface or instrument that is introduced directly into the 

### human body either into or incontact with the bloodstream ornormally sterile areas of the 

### body or contacts
intact mucous membranes but which does not ordinarily penetrate the blood barrier orotherwise enter normally sterile areas of he 

### body This product 

### may be used to preclean ordecontaminate critical or semi-critical medical devices priorto sterilization or high level disinfection 

## ASPHALT 

# ORWOOD ROOFS

# AND SIDINGS

fo control funsus and 

### mildew first remove all physical soil by brushing and hosing with clean water and apply 5000 

### ppr ailahle chlorine solution 

### Mix oz of this product per gallon ofwater and brush orspray roof orsiding After 30 minutes rinse by hosirt\lLl/ .lean water

Ifq 

### I1111 SI

JCI Jones Chemicals Inc Sunny Sol 150- 

## EPA

# REG

# NO 1744-20001 LI Itt

# 13/3

BOAT BOITOMS To control slime on boat bottoms sling plastic tarp under boat retaining enough water to cover the fouled bottom area but not allowing water to enter enclosed area Thisenvelope should contain approximately500 gallons ofwater for 14 foot boat 

### Add 18

### ozof this product to this water to obtain 35 

### ppm available chorine concentration Leave immersed for to 12 hours Repeat ifnecessary 

### Do not discharge the solution until the free chlorine level has dropped to 

## ppm as determined by 

### swimming pool test kit .ARTIF1CIAL 

## SAND BEACHES To sanitize the sand spray 500 

### ppm available chlorine solution containing 

### oz of this product per 10 gal ofwater at frequent intervals Small areas can be sprinkled with watering can



# fltt sq tul 

### 555555


# Lit JCIJonesChemicals Inc Sunny Sol 150- 

## EPA

# REG

# NO 1744-20001 10 

# CS

# EXHIBIT

# UNITED STATES ENVIRONMENTAL PROTECTION 

# AGENCY WASHINGTON D.C 20460



# FEB 

# 2O8 OF PREVENTIO ESTICIDES 

### AND TOXIC 

### STANCES 

# Mr Seth 

## Goldberg Steptoe 

## Johnson 

# LLP 1330 Connecticut 

# Avenue 

# NW Washington 

# DC 20036 Subject Nalco Petition 

## Dear

# MrGoldberg This letter 

### will 

## acknowledge receipt 

## ofyour

# December 2007 e-mail 

# mess on behalfofNalco requesting that

# EPAreconsider its 

### registrationfor

## two 

# ammonia pri icts 

## used in 

## connection with chlorine to treat 

## water 

# We aretreating this 

## communiCatiol petition 

## under the Administrative 

## Procedures Act and intend to 

## respond to it in tir 

# manner in 

### collaboration 

## with ourOffice 

## ofGeneral Counsel 

# The petition raises 

### several questions that 

### the

# Agency will

## need to 

### further investigate before 

## any decision 

## can bereached During its 

### investigation the 

# Agenc expects to 

## announce receipt 

# ofand invite 

### public 

# comment 

# on the petition since 

# EP decision 

# mayimpact other

## companies and

# mayraise 

### additional issues
Until 

# EPAmakes decision 

## onthe petition the Office 

## ofPesticide Prograi 

# would regard 

# Nalcos sale 

## and distribution 

## of

# ammonia and 

# ammonia products for in 

## connection with chlorine to treat 

## water to 

### require registration

## under

# FIFRA Section only if

## Nalco 

# makes pesticidal 

## claim for

## such products Please 

## do not hesitate to 

### contact 

# me if

## you have any questions

Sanders Director Antimicrobials Division 

# 751

# OP Office 

## ofPesticide 

## Programs

Internet Address 

## URL http//wwwepa.gOV RecyclewRecyClable Printed with Vegetable Oil Based Inks on 100% Postconsumer Process Chlorine Free RecycI 9aper