## Cover Letter

The chemical {XXX} in this PMN request is used to produce a final product {XXX}. We currently have a TME for this final product and the testing is going extremely well. To commercialize it, we would need to import {XXX}, hence our desire to include it {XXX} in the TSCA inventory. Once the starch market testing is completed, we will submit a PMN for the final product {XXX}.

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### 25JCSGIU QUAT150119757075068 011915

X X

X Page 2 SANITIZED SUBMISSION

### X



## X Page 3 SANITIZED SUBMISSIONBrian Johnson Research Director Industrial Speciality Chemicals 16880 S. Lathrop Ave. Harvey IL 60426 bjohnson@iscwater.com

Brian Johnson Research Director ISC 16880 S. Lathrop Ave. Harvey IL 60426 bjohnson@iscwater.com 708-261-0033 

## X X X XXX 

## X Page 4 SANITIZED SUBMISSION

## X

XXX 

## X
XXX 

## X XXX 

## X See Attachment 001 (Sanitized Picasso Starch.pptx)

Sanitized Picasso Starch.pptx Page 5 SANITIZED SUBMISSIONXXX

quaternization reaction

Mole ratio is 1:1 to 1:1.1 

## X

Page 6 SANITIZED SUBMISSIONPage 7 SANITIZED SUBMISSIONPage 8 SANITIZED SUBMISSIONXXX

Halogenated Alkylaminium Sanitized Picasso Starch.pptx 

## X XXX XXX XXX 

### X XXX XXX XXX 

### X diethyl ether 60-29-7 0.1

XXX XXX 

### X
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### XXX XXX 

## X

X Cationization of starch XXX 

### X XXX 

### X XXX 

### X XXX XXX XXX XXX 

### X

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## X XXX XXX XXX 

## X 1

XXX 

## X ISC Harvey 16880 S. Lathrop Ave. Harvey Cook IL 60426

Page 11 SANITIZED SUBMISSIONSee Attachment 003 (Batch Production Process.pptx)

Batch Production Process.pptx Page 12 SANITIZED SUBMISSIONDumping Material Full face Respirator Disposible suit with hood Latex gloves and Chemical resistant PVC gloves 100% Solid 1 0.5 100

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## X Calumet WRP IL0028061

Bag disposal 0.0004 Kg Other: Garbage - Landfill

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### 0

This material is imported from overseas and specific manufacturing details are unknown. We have been verbally informed that the material is “easy to make” and is a pharmaceutical intermediate. The attachment "General Synthesis.pdf" provides a lab method that may have been scaled up by the overseas suppliers.

Page 15 SANITIZED SUBMISSIONXXX 

## X General Procedure for the Synthesis of Quat.pdf Page 16 SANITIZED SUBMISSIONThis chemical is as an intermediate for a final product that is purity sensitive. The material is hydroscopic and produced by precipitation in a dry

solvent that is likely recycled on a campaign basis. Material is received in 25 Kg fibre drums and batches are designed to use an integer number of bags with each batch. This eliminates waste and eases production. Partially due to the chemical being in flake form, residuals in the bags is almost not noticable with an estimated 0.1 grams residual in each bag. In order to eliminate this 0.0001 Kg/bag discharge, we are looking into using a water solution. The solubility is between approximately 60-65% (w/w) and depending on shipping logistics and safety, we may request the material delivered as a neutralized aqueous solution. This would eliminate the respirator requirement, reduce safety issues (i.e. moving 25Kg containers) and plastic bag disposal. We are currently researching the efficacy (long term stability, product activity, etc.) of a ca. 65% solution. Additionally, dedicated equipment is being considered as part of a waste minimization plan to ensure purity and almost eliminate discharges to a POTW.

Page 17 SANITIZED SUBMISSION001 Generic structure Sanitized Picasso Starch.pptx Pt.I, Sec.B, 1e. | Pt.I, Sec.B, 3. 1 002 Nuclear Separation Agents General Procedure for the Synthesis of Quat.pdf Pt.2, Sec.B, End 2 003 Batch Process Batch Production Process.pptx Pt.2, Sec.A, 1d. 1 004 PDF of NMR Scan Sanitized NMR.pdf 1 005 Worker safety equipment details Personal Safety Equipment for using Quat.docx 1 006 LogP information Santized Starch Modifier Information.docx 3

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## X Measured

650 Estimate 25 XXX XXX 

## X XXX XXX 

## X

XXX 

## X XXX

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## ATTACHMENT HEADER SHEET Attachment Number 001 Attachment Name Generic structure 

## Associated PMN Section Number Pt.I, Sec.B, 1e. | Pt.I, Sec.B, 3. Does not contain CBI 

## Report Number QUAT150119757075068

## ATTACHMENT HEADER SHEET Attachment Number 002 Attachment Name Nuclear Separation Agents 

## Associated PMN Section Number

Pt.2, Sec.B, End Does not contain CBI 

## Report Number QUAT150119757075068

## ATTACHMENT HEADER SHEET Attachment Number 003 Attachment Name Batch Process 

## Associated PMN Section Number

Pt.2, Sec.A, 1d. Does not contain CBI 

## Report Number QUAT150119757075068

## ATTACHMENT HEADER SHEET Attachment Number 004 Attachment Name PDF of NMR Scan 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number QUAT150119757075068

## ATTACHMENT HEADER SHEET Attachment Number 005 Attachment Name Worker safety equipment details 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number QUAT150119757075068

## ATTACHMENT HEADER SHEET Attachment Number 006 Attachment Name LogP information 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number QUAT150119757075068