TSCA NON-CONFIDENTIAL BUSINESS INFORMATION f

SDOCUMENT DESCRIPTION DOCUMENT CONTROL NUMBER DATE RECEIVED

IN 511 1000008 1 a 0-/011V:;

COMMENTS:

DOEXS NOT CONTAIN CBI
P11.81i NON-CBI SUBMISSION

Cover Letter

Dear PMN Staff, C NANN a

On behalf of K+S North America, I am submitting a Pre-Manufacture Notice for the substance 3,4-dimethyl-1 Hpyrazole (DMP) (Submission report number DMP i0qM60D7,7

This material will be imported to the US where it will be further reacted to produce 3,4-dimethyl-1 H-pyrazole

phosphate (DMPP). A PMN for the phosphate will also be submitted. Then the phosphate will be blended into a

fertilizer formulation.

The US site for these processes has not yet been determined. Therefore, we are unable to provide details about the

potential releases of this material. We will provide this information to the EPA as soon as possible after the site has

been determined.

The toxicological and ecological data shown on the MSDS for DMP is based on the testing of the phosphate. The

complete testing reports will be included with the PMN for DMPP. Study reports on toxicologicas and ecological

data for 3,4-dimethyl-1 H-pyrazole (DMP) are not available. Please refer to the respective study reports woth 3,4-

dimethyl-1 H-pyrazole phosphate (DMPP, submission report No. DMPP_1 01008686317360) DMPP is DMP in

presence of phosphoric acid (phosphoric acid (65%)is aaded in 3 tol 0 fold excess). DMP is imported in formulation

with phosphoric acid only (liquid formulation containing 72% DMP, 20% water and 8% phosphoric acid). Thus,

reports for DMPP data are considered applicable for DMP. The excess phosphoric acid was not considered to

significantly contribute to the resulting toxicological and ecological data.

Pleas let me know if you have any questions or comments regarding this submission.

Submitter contact address is:

K+S North America

President

Mr Jan Doege

201 East 42nd Street

New York, NY 10605

Tel. 212-593-5907

Jan.doege@ks-northamerica.com

Page 1
2.0 s-r'IM s

office of Pollution Prevention and Toxics

Document Control Office (7407M)

US EPA, 1200 Pennsylvania Ave NW

Washington, D.C. 20460

liii IN 1111111111 GREENDELL .NJ

PO.WL M IIIIII via111 AMOUNT

$56

*i30 26 110 00 2441492

I C

To: Document Control

Mailstop: 7407M

Department:

M ailcode:

PKG Condition

US POSTAL

03082690000124494792
C0\'rt "",08C1 3 /37-3

PMN21OPINON-CBI SUBMISSION

Form Approved. 0.MB. Nos. 2070-0012 and 2070-0038

U.S. ENVIRONMENTAL PROTECTION AGENCY AGENCY USE ONLY

Date of receipt.

K~~~) E P BI III 0l~l 0lli [1111 8UI~I ___ 51110000081 P-1 1-081

Dooic Submission Report Number

nfo o tatN merviebyclln 202-54-19040 or faig225450) if luetesbee a remtte for thsntcP4 FR704) niaent Ixe a bov hSerfe nubryuNaegnrae.RmmberuuereIDnmr TdnScto 

Part I - ~~~~GENERAL INSOMAIORTSTD TNSTERDT

Yu must provide the curently corqete Chica Asrcts (A) itesdt descrptio ofa known att to or reasonabty ascertainable raoblesits by you, dnt ifk hee ata dare Nae ou e cemlt ubs tne you everi ea "ntuiosMuafr claim the retae otehat n teIsrcin niomna Mna fet saalbefoh ntemanufacture, oxiusces priiain nitribon int

(sbi ceIclityinformation forjcmb 0-540, youIg our subiong25460) I no bser coete an thee rev iew wtill notegi untF70., EPAni at th boesbite fo rf indheoencetificato litberoae Cenerte temest ata f re I Enu ber mut ls aperonyor orepodig eereitace Fr alig ddes nforumaisees of da l t uctst e suted if the o otei h e ieaue o

receivesthi iforaion. Ah luretter inporre t fyourlsbscsion o r eurdt umt l etdt nyu ossio rcnrladt rvd should ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ rfrneyuTSuefeidnicainnme.Frll ~ ~dsrito s oul clal idetif ther data ts t o isow nh or usa acr ain onsnal anlog. Alo thedtr Saeftne5 Ntceia subsneo elecni) you mt emal omoonf the estedonmenal csoul bhe charuactred. Frollowing, airebtamples

submit anhenial idntice includain alfesoa;i you usbmedsiany at bf tsuttead or data. atae shoudientsumiteted Cordint te daareireentlsh ilnfomtio a confentil andh rninawil nitbiz cputal s be §2.0oEhPrAnuatr oiiainRue(0CRPr2)

Paulfrt HUA nc your TEPSUR ANDr ENfRNENA hudceryi et Tdniiainnme.Fol whtaheck da Below a iesbnce orn hi no .le) th

Iftereaesvrlmnfct ure, ssi proeesbm ng,(ppe or oi)us opertn to f test Eaanvironenta fate. Data bsumteaconothe Lhoul Dat eur e nt sb descridina i Partic incing andll tis ota;iyuclerduce §7050o -th rmnf eNtiaioRle(0C Pt72) theosections as cneded.al mus [an Healtna effectse date Risk Asesmet

Part 11I - LISTN OF ATTACH OSR EN OMNA etDt (hc eo n nlue ntioie

For paper submissions, attach additional sheets if there is not Environmental effects data Structure/activity relationships

enough space to answer a question fully. Label each continuation Physical/Chemical Properties (A physical and chemical properties worksheet is

sheet with the corresponding section heading. In Part 111, list these LJ located on the last page of this form.) attachments, any teat data or other data and any optional

information included in the notice. FxJ Test data not in the possession or control of the submitter

OPTIONAL IN FORMATION TYPE OF NOTICE (Check Only One) You may include any information that you want EPA to consider in Fevaluating the new substance. On page 11 of this form, space has LxJ PMN (Premanufacture Notice) been provided for you to describe pollution prevention and

recycling information you may have regarding the new substance. F NN(infcn e s oie

"Binding" boxes are included throughout this form for you to N (infctNeUsNoc)

indicate your willingness to be bound to certain statements you F MA(etMreigEepinApiain

make in this section, such as use, production volume, protective MA(etartigEmponplcto)

equipment ... The intention is to reduce delays that routinely

accompany the development of consent orders or Significant New [J LVE (Low Volume Exemption) @ 40 CFR 723.50(c)(1)

Use Rules. Checking a "binding" box in a PMN does not by itself

prohibit the submitter from later deviating from the informationLi L EX(oReas/wExsuexmpon@40CR730c)2 (except chemical identity) reported in the form; however, in the LRX(o ees/o xoueEepin 0CR735()2

case of exemption applications (such as TMEA, LyE, LOREX) ] LEMdfcto

certain information provided in such notifications is binding on the F L VE odiicaio

submitter when the Agency approves the exemption application , LOE-oifcto especially if the production volume "binding" box is chosen in a OE odfcto

LVE. F1 Mock Submission

CONFIDENTIALITY CLAIMS [] ()i edn etro upr You may claim any information in this notice as confidential. To Mark ()i edn etro upr

assert a claim on the form, mark (X) the confidential box next to

the information that you claim as confidential. To assert a claim in IS THIS A CONSOLIDATED PMN (Y/N)?

an attach ment, ciceo racket the information you claim as confidential, if yo li nformation in the notices as confidential. # of chemicals or polymers (Prenotice Communication # required, enter # on

you must also provide a sanitized version of the notice. (including p. 3).

attachments). For additional instructions on claiming information [ as confidential, read the Instructions Manual. LJ Mark (X) if any information in this notice is claimed as confidential.

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25

Page 2P1101
liii1111111 I IIIUIIINON-CBI SUBMISSION PMN2O1OP2 PMVN Page 2

The public reporting and recordkeeping burden for this collection of information is estimated to average 93 hours per response. Send

comments on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for

minimizing respondent burden, including through the use of automated collection techniques to the Director, Collection Strategies

Division, U.S. Environmental Protection Agency (2822T), 1200 Pennsylvania Ave., NW, Washington, D.C. 20460. Include the 0MB

control number in any correspondence. Do not send the completed EPA Form 7710-25 to this address.

CERTIFICATION -- A printed copy of this signature page, with original signature, must be submitted

with CD or paper submission.

I certify that to the best of my knowledge and belief:

1. The company named in Part 1, section A, subsection 1 a of this notice form intends to

manufacture, import or process for a commercial purpose, other than in small quantities solely for

research and development, the substance identified in Part I, Section B.

2. All information provided in this notice is complete and truthful as of the date of submission.

3. I am submitting with this notice all test data in my possession or control and a description of all

other data known to or reasonably ascertainable by me as required by §720.50 of the

Premanufacture Notification Rule.

Additional Certification Statements:

If you are submitting a PMN, Intermediate PMN, Consolidated PMN, or SNUN, check the following user fee

certification statement that applies:

FRI The Company named in Part 1, Section A has remitted the fee of $2500 specified in 40 CFR 700.45(b), or

D The Company named in Part 1, Section A has remitted the fee of $1000 for an Intermediate PMN (defined @ 40 CFR 700.43) in

accordance with 40 CFR 700.45(b), or

DThe Company named in Part I Section A is a small business concemn under 40 CFR 700.43 and has remitted a fee of $100 in

accordance with 40 CFR 700.45(b).

If you are submitting a Low Volume Exemption (LVE) application in accordance with 40 CFR 723.50(c)(1) or a

Low Release and Low Exposure Exemption (LoRex) application in accordance with 40 CFR 723.50(c)(2), check

the following certification statements:

DThe manufacturer submitting this notice intends to manufacture or import the new chemical substance for commercial purposes, El other than in small quantities solely for research and development, under the terms of 40 CFR 723.50.

ED The manufacturer is familiar with the terms of this section and will comply with those terms; and

DThe new chemical substance for which the notice is submitted meets all applicable exemption conditions.

D If this application is for an LVE in accordance with 40 CFR 723.50(c)(1), the manufacturer intends to commence manufacture of El the exempted substance for commercial purposes within 1 year of the date of the expiration of the 30 day review period.

The accuracy of the statements you make in this notice should reflect your best prediction of the

anticipated facts regarding the chemical substance described herein. Any knowing and willful Confidential

misrepresentation is subject to criminal penalty pursuant to 18 USC 1001.

Signature and title of

Authorized Official (Original Date 2 6- (6. ?z -l' Signature Required) P-2SZ) 17,

K+S North America Corp. 201 East 42nd Street

Suite 1808

EPA FORM 7710-25 (Rev. 6-09) New York, NY 10017 Replaces previous editions of EPA Form 7710-25

Page
II I IIHIIIIU II I I IINON-CBI SUBMISSION

PMN2OIOP3 PMN Page 3 Part -- G ~6 NR I LINO M TO

Section A - SUBMITTER IDENTIFICATION

Mark (X) the "Confidential" box next to any subsection you claim as confidential

Ia. IPerson Submitjng Noftce (in U.S.) Confidental

Name of Authorized Official (first) Jan (last) Doege

Position President

Company +S North America

Mailing Address (number & street) 1 201 East 42nd Street

city New York State NY Postal Code 10605

email jan.doege@ks-northamerica.com

b. Agent (if Applicable) Confidential

Name of Authorized Official (first) (last)

Position

Company__ _ _ _ _ _ _ _ __ _ _

Mailing Address (number & street)

citySttPotlCd

e-mail(icueaeco)

C. Joint Submitter'(If applicable), Confidential

If you are submitting this notice as part of a joint submission, mark (X) I

Name of Authorized Official (first) (last)

Position

Company E

Mailing Address (number & street)I

city State Postal Code

e-mail Telephone

(include area code)

2. Technical Contact (in U.S.) Cnieta

Name of Authorized Official (first) Jan (last) Doege

Position President

Company K+S North America

Mailing Address (number & street) 201 East 42nd Street

city New York IState NY IPostal Code 10605

e-mail ja~oege@ks-northamerica.com (inle areoe 212-593-5907

If you have had a prenotice communication (PC) conceming Mark ()if none Confidential

3. this notice and EPA assigned a PC Number to the notice,

enter the number. 1:1

If you previously submitted an exemption application for the Mark (X) if none Confidential

chemical substance covered by this notice, enter the

4. exemption number assigned by EPA. If you previously submitted a PMN for this substance enter the PMN number E1L

Iassigned by EPA (i.e. withdrawn or incomplete).

If you have submitted a notice of Bona fide intent to Mark (X) if none Confidential

5. manufacture or import for the chemical substance covered

by this notice, enter the notice number assigned by EPA.

6. -Type of Notice - Mark (X)

1 Manufacture Only 2.Import Only [. ot

Binding Option L2. Binding OptionLII

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25

Page 4
II I IIIIIIIN II I U IINON-OBI SUBMISSION

PMN201OP4 PMN Page 4

Par I - GEEA INO M TO*-.otne

Section B - CHEMICAL IDENTITY INFORMATION: You mus provide a currently correct Chemical Abstracts (CA) name of the substance based on'.current CA index nomenclature rules and conventions.

Mark (X) the "Confidential" box next to any item you claim as confidential

Complete either item 1 (Class 1 or 2 substances) or 2 (Polymers) as appropriate. Complete all other items.

If another person will submit chemical identity information for you (for either Item 1 or 2), mark (X) the box at the right. Identify

the name, company, and address of that person in a continuation sheet. L

1 . Class 1 or 2 chemical substances (for definitions of class 1 and class Class 1 Class 2 CBI

2 substances, see the Instructions Manual)

a. Class of substance - Mark (X) E D

b. Chemical name (Currently correct Chemical Abstracts (CA) Name that is consistent with TSCA Inventory listings for similar

substances. For Class 1 substances a CA Index Name must be provided. For Class 2 substances either a CA Index Name or CAD

Preferred Name must be provided, which ever is appropriate based on current CA index nomenclature rules and conventions).

3,4-dimethyl-I H-pyrazole

Ente Ataet fub iena Part me leayeit for subSctioaB,.c

d. Mleuar ieforul which2 mehdyuueDodvlpo banteseiidhr dniyifrainrpre nti oie cekoe

e.tFor a CAS Ibtnetr preicpete an correcfthemia stucue diarm.r aMls sbtnetpode a2 orc

represenativn eort pai chema d truue dASIagnram ascoplete ascnb(konOftnhabesnalserand x

See Attachment 001 (3,4-dimethyl-1 H-pyrazole.pdf)

Enter Attachment filename for Part 1, Section B, 1. e.34diehl1HproepdD

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25

Page 5
1II111 ifl II 11I1I11I1II 1111111111I111I1IIIOVI NON-CBI SUBMISSION

PMN201OP4A PMN Page 4a

For a class 2 substance - (1) List the immediate precursor substances with their respective CAS Registry Numbers. (2) Describe

the nature of the reaction or process. (3) Indicate the range of composition and the typical composition (where appropriate). Confidential

e. (1) List the immediate precursor substance names with their respective GAS Registry Numbers. l

Enter Attachment filename for Part 1, Section B, i. e. (1)D

e. (2) Descnibe the nature of the reaction or process. El

Enter Attachment filename for Part 1, Section B, 1. e. (2) E

e. (3) Indicate the range of composition and the typical composition (where appropriate). E

Enter Attachment filename for Part 1, Section B, i.ea. (3) E

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25

Page 6
liiiIIUl~l I I U II U ~llNON-OBI SUBMISSION

PMN2O1OP5 PMN Page 5

Part I -- GENERAL INFORMATION - Continued

Section B -- CHEMICAL IDENTITY INFORMATION -- Continued

2. Polymers (For a definition of polymer, see the Instructions Manual.) Confidential

a. Indicate the number-average weight of the lowest molecular weight composition of the polymer you intend to manufacture.

Indicate 

below 500 

maximum 

and below weight 1,000 percent absolute 

of low 

molecular 

molecular 

weight weight of that 

species composition. (not including residual monomers, reactants, or solvents) D

Describe the methods of measurement or the basis for your estimates:

GPC Other (Specify Below) D

Specify Other:

(i) lowest number average molecular (ii) maximum weight % below 500 molecular (iii) maximum weight % below 1000 molecular

weight: weight: weight:

Enter Attachment filename for Part 1, Section B, 2. a. T

b. You must make separate confidentiality claims for monomer or other reactant identity, composition information, and residual information Mark

(X) the "Confidential" box next to any item you claim as confidential

(1) -Provide the specific chemical name and CAS Registry Number (if a number exists) of each monomer or other reactant used in the

manufacture of the polymer.

(2) -Mark (X) this column if entry in column (1) is confidential.

(3) -Indicate the typical weight percent of each monomer or other reactant in the polymer. (4) -Choose "yes" from drop down menu if you want a monomer or other reactant used at two weight percent or less to be listed as part of

the polymer description on the TSCA Chemical Substance Inventory. (5) -Mark (X) this column if entries in columns (3) and (4) are confidential.

(6) -Indicate the maximum weight percent of each monomer or other reactant that may be present as a residual in the polymer as

manufactured for commercial purposes.

(7) -Mark (X) this column if entry in column (6) is confidential.

Monme seciiccheicl oroter eatan nmeTypical Include in Max

Monme eatan oroter seciiccheicl nmeCBI 1composition identity CBI residual CBI

(1)2) (3) () () () _

CAS Registry Number (1

CAS Registry Number (1)

CAS Registry Number (1)

CAS Registry Number (1)

CAS Registry Number (1)___ ____

Mark (X) this box if the data continues on the next page.D

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25

Page 7
liii11111111I IINON-CBI lii II SUBMISSION

PMN2O1OP5A PMN Page 5a

c. Please identify which method you used to develop or obtain the specified chemical identity information reported in this notice

(check one) B

Method I (CAS Inventory Expert Service

- a copy of the identification report obtained I-j ES Order Method 2

from GAS Inventory Expert Service must be Li Number (other source) submitted as an attachment to this notice)

Enter Attachment filename for Part 1, Section B, 2. c.

d. The currently correct Chemical Abstracts (CA) name for the polymer that is consistent with TSCA Inventory listings for similar

polymers.D

GAS Registry Number (if a number already exists for the substance)

e. Provide a correct representative or partial chemical structure diagram, as complete as can be known, if one can be reasonably ascertained.D

Enter Attachment filename for Part 1, Section B, 2. e.D

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25

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PMN2O1OP6 PMN Page 6

Part I -- GENERAL INFORMATION -- Continued

Section B -- CHEMICAL IDENTITY INFORMATION -- Continued

3. Impurities

(a) - Identify each impurity that may be reasonably anticipated to be present in the chemical substance as manufactured for commercial

purpose. Provide the CAS Registry Number if available. If there are unidentified impurities, enter "unidentified."

(b) - Estimate the maximum weight % of each impurity. If there are unidentified impurities, estimate their total weight 6.

CAS Registry Maximum Cni Impurity (a) Number Percent % denti-l (a) denba

3-ethyl-i H-pyrazole 13808-71-4 0.5

water 7732-18-5 5.9

methanol 67-56-1 1.0

hydrazine 302-01-2 0.02

Mark (X) this box if the data continu es on the next page.D

Enter Attachment filename for Part 1, Section B, 3.

4. Synonyms - Enter any chemical synonyms for the new chemical identified in subsection 1 or 2.

DMP E

Enter Attachment filename for Part 1, Section B, 4.D

5. Trade identification - List trade names for the new chemical substance identified in subsection 1 or 2.

DMP

Enter Attachment filename for Part 1, Section B, 5.D

6. Generic chemical name - If you claim chemical identify as confidential, you must provide a generic name for your substance that reveals the

specific chemical identity of the new chemical substance to the maximum extent possible. Refer to the TSCA Chemical

Substance Inventory, 1985 Edition, Appendix B for guidance on developing generic names.

Enter Attachment filename for Part 1, Section B, 6.

7 Byproducts - Describe any byproducts resulting from the manufacture, processing, use, or disposal of the new chemical substance. Provide the

GAS Registry Number if available.

Byproduct (1) CAS Registry Number Confi- (2) dential

NONE

Mark (X) this box if the data continues on the next page. i

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25

Page 9
fillII ll~ lll~I~llll~UlD l~l~ilfhlfhI~NON-OBI SUBMISSION

PMN2O1OP7 PMN Page 7

Part I -- GENERAL INFORMATION -- Continued

Section C -- PRODUCTION, IMPORT, AND USE INFORMATION:

The information on this page refers to consolidated chemical number(s): Dl 1 [12 E13 E1I4 7I5 [:16

Mark (X) the "Confidential" box next to any item you claim as confidential.

1. Production volume -- Estimate the maximum production volume during the first 12 months of production. Also estimate the maximum production volume for any consecutive 12-month period during the first three years of production. Estimates should be on 100% new chemical substance basis.

For a Low Volume Exemption application, if you choose to have your notice reviewed at a lower production volume than 10,000 kg/yr. specify the

volume and mark (x) in the binding box, If granted, you are bound to this volume.

Maximum first 12-month production (kg/yr) Maximum 12-month production (kg/yr) Confidential Binding Option (100% new chemical substance basis) (100% new chemical substance basis) { Mark (X)

4000 30000 EIlI

Enter Attachment filename for Part 1, Section C, 1. j BI

2. Use Information -- You must make separate confidentiality claims for the description of the category of use, the percent of production volume devoted

to each category, the formulation of the new substance, and other use information. Mark (X) the "Confidential" Box next to any item you claim as

confidential.

a. (1 ) --Describe each intended category of use of the new chemical substance by function and application. (2) --Mark (X) this column if entry column (1) is confidential business information (CBI). (3) --Indicate your willingness to have the information provided in column (1) binding. (4) --Estimate the percent of total production for the first three years devoted to each category of use.

(5) --Mark (X) this column if entry in column (4) is confidential business information (CBI).

(6) --Estimate the percent of the new substance as formulated in mixtures, suspensions, emulsions, solutions, or gels as manufactured for

commercial purposes at sites under your control associated with each category of use.

(7) --Mark (X) this column if entry in column (6) is confidential business information (CBI).

(B) --indicate % of product volume expected for the listed "use" sectors. Mark more than one box if appropriate. Mark (X) to indicate your willingness to have the use type provided in (8) binding. (9) -Mark (X) this column if entry(ies) in column (8) is (ae con~fidential business information (CBI).________________

Category of use (1) Binding Prod % in % of substance expected per use

(by function and application i.e. a dispersive dye for CBI Option uction CBI Form- CBI (8) CBI

finishing polyester fibers) Mark (X) % ulation site- con. _ con,. BSd,ng

(2) (3) (4) (5) (6) (7) linited nonmer rnen.,l opbw (9)

Intermediate to be used in the production of 1 H- 100 72 100 0 0 0

pyrazole, 3,4-dimethyl-, phosphate, a fertilizer

additive.

*If you have identified a "consumer" use, please provide on a continuation sheet a detailed description of the use(s) of this chemical substance in

consumer products. In addition include estimates of the concentration of the new chemical substance as expected in consumer products and describe

the chemical reactions by which this substance loses its identity in the consumer product.

Mark (X) this box if the data continues on the next page.LI

b. Generic use If you claim any category of use description in subsection 2a as confidential, enter a generic description of that category.

description Read the Instruction Manual for examples of generic use descriptions.

Enter Attachment filename for Part 1, Section C, 2. b. ICBI LI

3. Hazard Information -- Include in the notice a copy of reasonable facsimile of any hazard wamning statement, label, material safety data sheet, or other information which will be provided to any person who is reasonably likely to be exposed to this substance Binding Option regarding protective equipment or practices for the safe handing, transport, use, or disposal of the new substance. List in part III Mark (X)

hazard information you include.

Mark (X) this box if you attach hazard information. L

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25

Page 10
liiiIllIIII II I 111111NON-CBI SUBMISSION

PMN2O1OP8 PMN Page 8

Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE

Section A -- INDUSTRIAL SITES C~ONTROLLED BY THE SUBMITTER Mark (X) the "Confidential' box next to Iany item you claim as confidential

The information on pages 8 and 8a refer to consolidated chemical number(s): 0 1 0 2 Eil 3 L] 4 0 5 [16

Complete section A for each type of manufacture, processing, or use operation involving the new chemical substance at industrial sites

you control. Importers do not have to complete this section for operations outside the U.S.; however, you may still have reporting requirements if there are further industrial processing or use operations after import. You must describe these operations. See

instructions manual

1. Operation description Confia. Identity -- Enter the identity of the site at which the operation will occur. dential

Name K+S North America

Site address (number and

street) 201 East 42nd StreetD

City New York County New York

State NY ZIP code 110605 ____

If the same operation will occur at more than one site, enter the number of sites. Identify the additional

sites on a continuation sheet, and if any of the sites have significantly different production rates or El

operations, include all the information requested in this section for those sites as attachments. -

Mark (X) this box if the data continues on the next page. l

b. Type -- Manufacturing Fr1Prcssn F s Mark (X) LI s ELiPocsig 

c. Amount and Duration - Complete 1 or 2 as appropriate Cni

Maximum kg/batch

(100% new chemical Hours/batch Batches/year 1. Batch substance) ______

300 24 100

Maximum kg/day

2. Continuous (100% new chemical substance)Hor/aDyser

d. Process description hv orpoesdsrpinbnig

(1) Diagram the major unit operation steps and chemical conversions. Include interim storage and transport containers (specify- e.g. 5 gallon pails, 55 gallon drum, rail car, tank truck, etc.). (2) Provide the identity, the approximate weight (by kg/day or kg/batch on a 100% new chemical substance basis), and entry point of all starting materials and feedstocks (including reactants, solvents, catalysts, etc.), and of all products, recycle streams, and wastes, Include cleaning chemicals (note frequency if not used daily or per batch.). (3) Identify by number the points of release, including small or intermittent releases, to the environment of the new chemical substance. If

releasing to two media at the same step, assign a second release number for the second medium.

FI

The PMN substance will be further reacted with phosphoric acid (CAS# 7664-38-2) to form 1 H-pyrazole, 3,4-dimethyl-, phosphate- (CAS# 202842-98-

6)

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25

Page 11
II I~hI~hlII IIIIIDIIIDU I iii111111NON-OBI SUBMISSION

PMN201OP8A PMN Page 8a

Diagram of the major unit operation steps. Cnieta

Enter Attachment filename for Part 11, Section A, 1. d.D

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25

Page 12
I~ 111111111I1111I1111111111111i11111111 I NON-CBI SUBMISSION

PMN2O1OP9 PMN Page 9

Part II-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE - Continued

Section A -- INDUSTRIAL SITES CONTROLLED BY THE SUBMITTER - Continued

The information on pages 9 and 9a refer to consolidated chemical number(s): D[:1 D 2 3 4 5 6

2. Occupational Exposure -- You must make separate confidentiality claims for the description of worker activity, physical form of the new chemical

substance, number of workers exposed, and duration of activity. Mark (X) the 'Confidential" box next to any item you claim as confidential.

(1) -Describe the activities (i.e. bag dumping, tote filling, unloading drums, sampling, cleaning, etc.) in which workers may be exposed to the

substance.

(2) -- Mark (X) this column if entry in column (1) is confidential business information (CBI).

(3) -Describe any protective equipment and engineering controls used to protect workers.

(4) and (6) -- Indicate your willingness to have the information provided in column (3) or (5) binding. (5) -- Indicate the physical form(s) of the new chemical substance (e.g., solid: crystal, granule, powder, or dust) and % new chemical substance (if

part of a mixture) at the time of exposure. (7) -- Mark (X) this column if entries in columns (3) and (5) are confidential business information (CBI).

(8) -- Estimate the maximum number of workers involved in each activity for all sites combined.

(9) -- Mark (X) this column if entry in column (8) is confidential business information (CBI).

(10) and (11) -- Estimate the maximum duration of the activity for any worker in hours per day and days per year.

(12) - Mark (X) this column if entries in columns (10) and (11 )are confidential business informaion(CI).

Worker activity Protective Equipment( Binding Phsci Binding Maiu Duainf11

(I.e., bag dumping, filling CBI , ption form(s) Option CBI Workers CBi aiu urto a drums) Engineering Controls Mark (X & % new Mark (X) Exposed Hs,/a asr (2 (1) (2) (3) (4) substance (6) (7) (8) (9) Hs~y Dylr (2

blending rubber gloves, chemical liquid, 72% 3 24 100

splash goggles, rubber apron and shoes. Ventilated area

and vessel.

Mark (X) this box if the data continues on the next page. T - Enter Attachment filename for Part 11, Section A on the bottom of page 9a El

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Formn 7710-25

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PMN2O1OP9A PMN Page 9a

3. Environmental Release and Disposal -- You must make separate confidentiality claims for the release number and the amount of the new chemical

substance released and other release and disposal information. Mark (X) the "Confidential" box next to each item you claim as confidential.

(1) -- Enter the number of each release point identified in the process description, part iI, section A, subsection ld(3). (2) -- Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology (in kg/day or kg/batch).

(3)-- Mark (X) this column if entries in columns (1) and (2) are confidential business information (CBI).

(4) -- Identify the media (stack air, fugitive air (optional-see Instruction Manual), surface water, on-site or off-site land or incineration, POTW, or

other (specify)) to which the new substance will be released from that release point. (5) -a. Describe control technology, if any, and control efficiency that will be used to limit the release of the new substance to the environment.

For releases disposed of on land, characterize the disposal method and state whether it is approved for disposal of RCRA hazardous waste.

On a continuation sheet, for each site describe any additional disposal methods that will be used and whether the waste is subject to

secondary or tertiary on-site treatment. b. Estimate the amount released to the environment after control technology (in kg/day).

(6) - Mark (X) this column if entries in columns (4) and (5) are confidential business information (CBI). (7) - Identify the destination(s) of releases to water. Please supply NPDES (National Pollutant Discharge Elimination System) numbers for direct

discharges or NPDES numbers of the POTW (Publicly Owned Treatment Works). Mark (X) if the POTW name or NPDES # is confidential

business information (CB 1).________________________________________

Release Amount of New Medium of release Control technology and efficiency (you may wish to

Number Substance Released CIe.g. Stack air optionally attach efficiency data) CBI

Binding (1) (2a) (2b) (3) (4) (5a) Mark (5b) (6)

I <1 POTW unknown unknown

pound/batc h

Mark (X) this box if the data continues on the next page. I

(7) Mark (X) the destination(s) of releases to Water. NPDES# B

D namne(s)

Navigable waterwayE] - provide name(s)

D Other--SpecifyD

Enter Attachment filename for Part 11, Section A. El

EPA FORM 77 10-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25

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PMN201OP10 PMN Page 10

Part 11-- HUMAN EXPOSURE AND ENVIRONMENTAL RELEASE - Continued

Section B -- INDUSTRIAL SITES CONTROLLED BY OTHERS 3 The information on pages 10 and 10a refer to consolidated chemical number(s): Ell LI 2 L]3 [14 115 E16

Complete section B for typical processing or use operations involving the new chemical substance at sites you do not control. Importers do no hve to

complete this section for operations outside the U.S.; however, you must report any processing or use activities after import. See the Instructions Manual.

Complete a separate section B for each type of processing, or use operation involving the new chemical substance. If the same operation is performed at

-more than one site describe the typical operation common to these sites. Identif additional sites on a continuation sheet.

1(a). Operation Description -- To claim information in this section as confidential, bracket (e.g. {)) the specific information that you claim as

confidential.

(1) - Diagram the major unit operation steps and chemical conversions, including interim storage and transport containers (specify - e.g. 5 gallon

pails, 55 gallon dwums, rail cars, tank trucks, etc). On the diagram, identify by letter and briefly describe each worker activity. (2) -- Either in the diagram or in the text field 1 (b) below, provide the identity, the approximate weight (by kg/day or kg/batch, on an 100% new

chemical substance basis), and entry point of all feedstocks (including reactants, solvents and catalysts, etc) and all products, recycle

streams, and wastes. Include cleaning chemicals (note frequency if not used daily or per batch). (3) -- Either in the diagram or in the text field I1(b) below, identify by number the points of release, including small or intermittent releases, to the

environment of the new chemical substance.

(4 - Please enter the # of sites (remember to identif the locations of these sites on a continuation sheet):

1 (b). (Optional) This space is for a text description to clarify the diagram above. Confidential 1

Enter Attachment filename for Part 11, Section B on the bottom of page 10a. 1

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2. Worker Exposure/Env!iron mental Release

(1) -- From the diagram above, provide the letter for each worker activity. Complete 2-8 for each worker activity described.

(2) -- Estimate the number of workers exposed for all sites combined.

(4) -- Estimate the typical duration of exposure per worker in (a) hours per day and (b) days per year.

(6) -Describe physical form of exposure and % new chemical substance (if in mixture), and any protective equipment and engineering controls, if

any, used to protect workers.

(7) -Estimate the percent of the new substance as formulated when packaged or used as a final product. (9) -- From the process diagram above, enter the number of each release point. Complete 9-13 for each release point identified.

(10)-- Estimate the amount of the new substance released (a) directly to the environment or (b) into control technology to the environment (in kg/day or kg/batch). (12)-- Describe media of release i.e. stack air, fugitive air (optional-see Instructions Manual), surface water, on-site or off-site land or incineration,

P07W, or other (specify) and control technology, if any, that will be used to limit the release of the new substance to the environment.

(14)-- Identify byproducts which may result from the operation. (3), (5), (8), (11), (13) and (15) - Mark (X) this column if any of the proceeding entries are confidential business information (CB1).

Letter # Of Duration of CI Protective Equlpl/Elineerlng Controls/Physical % new % in Of Workers CBI Exposure C11Form substance Formulation CBI

Activity Exposed ____________________

(1) (2) (3) (4a) (4b) (5) (6) (6) (7)(p

Nuers Amount of New Substance Released CDI Media of Release & Control Technology CDIl

(9) (10a) (10b) (111) (12) (13)

Mark (X) this box if the data continues on the next page.

(14) Byproducts: 1 (1 5) CBI

Enter Attachment filename for Part 11, Section B.D

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25

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PMN201OP11 PMN Page 11

OPTIONAL POLLUTION PREVENTION INFORMATION

To claim information in the following section as confidential, bracket (e g. {)) the specific information that you claim as confidential.

In this section you may provide information not reported elsewhere in this form regarding your efforts to reduce or minimize potential risks

associated with activities surrounding manufacturing, processing, use and disposal of the PMVN substance. Please include new information

pertinent to pollution prevention, including source reduction, recycling activities and safer processes or products available due to the new chemical

substance. Source reduction includes the reduction in the amount or toxicity of chemical wastes by technological modification, process and

procedure modification, product reformulation, and/or raw materials substitution. Recycling refers to the reclamation of useful chemical components from wastes that would otherwise be treated or released as air emissions or water discharges, or land disposal. Quantitative or qualitative

descriptions of pollution prevention, source reduction and recycling should emphasize potential risk reduction in addition to compliance with existing regulatory requirements. The EPA is interested in the information to assess overall net reductions in toxicity or environmental releases and

exposures, not the shifting of risks to other media (e.g., air to water) or nonenvironmental areas (e.g., occupational or consumer exposure). To the

extent known, information about the technology being replaced will assist EPA in its relative risk determination. In addition, information on the

relative cost or performance characteristics of the PMN substance to potential altemnatives may be provided.

Describe the expected net benefits, such as

(1) an overall reduction in risk to human health or the environment;

(2) a reduction in the generation of waste materials through recycling, source reduction or other means;

(3) a reduction in the use of hazardous starting materials, reagents, or feedstocks;

(4) a reduction in potential toxicity, human exposure and/or environmental release; or

(5) the extent to which the new chemical substance may be a substitute for an existing substance that poses a greater overall risk to human

health or the environment.

Information provided in this section will be taken Into consideration during the review of this substance. See PMN Instructions Manual

and Pollution Prevention Guidance manual for guidance and examples.

The PMVN substance will be completely reacted in a closed system. There will be essentially no release to the environment.

Enter Attachment filename for Pollution Prevention Page 11.D

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25

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PMN201OP12 PMN Page 12

Part III -- LIST OF ATTACHMENTS

Attach continuation sheets for sections of the form, test data and other data (including physical/chemical properties and

structure/activity information), and optional information after this page. Clearly identify the attachment and the section of the form

to which it relates, if appropriate. Number consecutively the pages of any paper attachments. In the Number of Pages column

below, enter the inclusive page numbers of each attachment for paper submissions or enter the total number of pages for each

attachment for electronic submissions. Electronic attachments can be identified by filename.

Mark (X) the "Confidential" box next to any attachment name or filename you claim as confidential. Read the Instructions Manual

for guidance on how to claim any information in an attachment as confidential. You must include with the sanitized copy of the

notice form a sanitized version of any attachment in which you claim information as confidential.

NumberAssociated

#Attachment Name Attachment Filename Numbaer PMVN Section CBI

of PagesNumber

001 3,4-dimethyl-1 H-pyrazole 3,4-dimethyl-1 H-pyrazole.pdf 1 Pt.l, Sec. B, 1 a

002 US MSDS DMP 8

003 EPI Summary 3

004 DMP-CAS Client Services-CAS Number 2 Pt.l, Sec.B, 1c.

005 DMP process description 1 Pt.2, Sec.A, 1d.

Mark (X) this box if the data continues on the next page.D

EPA FORM 7710-25 (Rev. 6-09) Replaces previous editions of EPA Form 7710-25

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PMN201OP13 PMN Page 13

PHYSICAL AND CHEMICAL PROPERTIES WORKSHEET

The information on this page refers to chemical number(s): E] 1 [i]2 E:] 3 E] 4 LE] 5 L 6

To assist EPA's review of physical and chemical properties data, please complete the following worksheet for data you provide and include it in the

notice. Identify the property measured, the value of the property, the units in which the property is measured (as necessary), and whether or not the

property is claimed as confidential. Give the attachment number (found on page 12) in column (b). The physical state of the neat substance should be

provided. These measured properties should be for the neat (100% pure) chemical substance. Properties that are measured for mixtures or

formulations should be so noted (% PMN substance in _). You are not required to submit this worksheet; however, EPA strongly recommends that

you do so, as it will simplify the review and ensure that confidential information is properly protected. You should submit this worksheet as a

supplement to your submission of test data. This worksheet is not a substitute for submission of test data.

Prov ted cNmenVlu Measured CBI

(a)ert Unit Mark X If ANucmentVlu or Estimate Mark (X)

( a(P ro b lid)( (li u i ) (g a s)E( d

Physical state of neat substance Li (soid (lid (gas Measured

Temperature -c Eor

Density/relative density L~J1.05 g/cm3 Measured

Solubility

@ Temperature 0C Li gIL

Solvent

Solubility in Water @ 20 *Cmiscible Estimate

Temperature Li g/L

Melting Temperature _ _ _ _ _ _

Boiling / Sublimation 760 Tr El100 C Estimate

temperature @Tor L

Spectra L

Dissociation constant lI

1.26 Octanol / water partition coefficient LiMeasured

Henrys Law constant L

Volatilization from waterLi__ _ _ _ _

Volatilization from soil L

p@cnetain 704-6 Measured

Flammabiiity L

Explodability Li

Adsorption I Coefficient FLi

Particle Size Distribution L

Othe Vscoity20-30 - pecfy mPas

Measured

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