## Cover Letter

1. Part II, Section A, Use Decription: The amount of NCS in the Use operation is less than the first 12-month manufactured amount. The surplus (less than one Use batch) will be used in the next year. 2. Section C, 2a, Use information: % in formulation may also be at {XXX}. 3. Physical and chemical properties worksheet: Used the recent update of ECOSAR (1.11) from June 2012 4. Attachments: We do not have health effects studies for the NCS but we have attached HET-CAM and Acute Oral Toxicity studies on 3 analog structures (a methyl, ethyl and dimethyl analog). These will be sent in as Support Documents due to their length. 5. Confidentiality claims for non-diclosure of COMPANY NAME ONLY in health effects studies: A. The substances are monomers used to make an R&D polymer. If a competitor knew the company name associated with the monomers, they would know we are developing a new polymer in our very narrow set of applications. This is unlike a large chemical company which has many technical fields. We are in a special niche field where our name and certain chemical identities go hand in hand. Such a disclosure is intolerable. B. The company identity should be held confidential but we will review the utility of the claim in 2020. C. Yes, our company name appears in patents(s). However, the substance is only one of many substances that have been disclosed categorically. No licenses under the existing patent have been granted to others without a nondisclosure agreement. The agreements restrict the disclosure of our company name and the fact that the other party has a confidentiality agreement with us D. Yes, the identity of the chemical substance has been held strictly confidential such that no competitor is aware the specific substance is manufactured by the company. E. No, the fact that this chemical substance have been manufactured in the United States by our company is not publicly ascertainable. F. Our company has guarded the specific identity of the substance so that its commercial utility cannot be discovered by others by having all employees sign a confidentiality agreement. As a small organization access to the chemical substance’s MSDS is allowed because a small number of research groups/workers work on multiple projects. G. Our company has disclosed the identity of the substances to outside legal counsel but under terms of confidentiality. H. The form of the substance that may leave the site of manufacture is in an R&D polymer (reacted form) or in the form of a waste solution which may be commingled with other wastes. The polymers are still in the R&D phase and therefore is not in wide distribution. The substance would be difficult to analyze in the final polymer. I. If allowed to be confidential, the company name cannot be determined by competitors. J. The substances in the studies have been use in the manufacture of an R&D polymer. K. No Federal agency or court has ruled on the confidentiality of the company name for these substances. L. The questions in 720.90(b)(2): The studies do not reveal processes or mixture information. The company name is the only part of the study not being disclosed and so the interpretation of the study is not hindered in any way. (We will re-substantiate at the time of the NOC.) Page 1 SANITIZED SUBMISSIONPage 2 SANITIZED SUBMISSION

### 2579QD28 BEEX120730792748440 CV75E2

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## X 302683 CAS IES report confidential version.pdf 

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## X See Attachment 001 (structure NCS sanitized.pdf)

structure NCS sanitized.pdf Page 6 SANITIZED SUBMISSIONPage 7 SANITIZED SUBMISSIONPage 8 SANITIZED SUBMISSIONPage 9 SANITIZED SUBMISSIONXXX

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Alkyl maleimide substituted bicyclic olefin entire page is confidential.pdf 

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1. The entire process is conducted in a dedicated pilot unit which includes rapid air exchange (10 turnovers/hour) to minimize airborne VOC concentration. 2. A dedicated spot ventilation system is used to capture fugitive emissions during drumming operations. Capture velocity is designed for 100 ft/minute. 3. Except for drum transfer operations, all liquid transfers between process units are performed in a closed manner via nitrogen pressure. 4. Except for drum handling operations, the entire process is contained within ASME pressure-rated vessels. Operating pressure varies between deep vacuum and elevated pressure using nitrogen blanketing in all cases. 5. Where NCS is present in a process stream to be drummed, the personal protective equipment used includes an approved organic cartridge respirator. 6. Drum transfers are made using a dip tube insertion through the closed drum bung port, and drums are filled bottom-up to minimize the risk of splashing and vapor entrainment. Spot ventilation is used at drum open bung ports to capture VOC’s. 7. All process vent emissions are piped to a dedicated scrubbing column equipped with countercurrent liquid contact at sub-ambient temperatures. Scrubbing efficiency is expected to exceed 95% for the new compound. Vent scrubber fluid is synthetic hydrocarbon oil; spent fluid is drummed as hazardous waste and disposed offsite via incineration. 8. Process cleaning solvents, process wastes, and empty drums are processed for offsite disposal by a hazardous waste incineration facility. Empty drums are not cleaned or recycled. 9. All process vessels and operations are located within a containment area to prevent inadvertent contact with soil or groundwater, in the event of a liquid spill. 10. A computer control system is used for monitoring, controlling, and alarming of all critical process parameters. XXX XXX XXX XXX XXX 

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Page 12 SANITIZED SUBMISSIONSee Attachment 004 (Process diagram manufacture of NCS sanitized version.pdf)

Process diagram manufacture of NCS sanitized version.pdf Page 13 SANITIZED SUBMISSIONEquipment-engineering controls Section A.2.page 9 sanitized version.pdf

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1. The entire process is conducted in a dedicated pilot unit which includes rapid air exchange (10 turnovers/hour) to minimize airborne VOC concentration. 2. A dedicated spot ventilation system is used to capture fugitive emissions during drumming operations. Capture velocity is designed for 100 ft/minute. 3. Except for drum transfer operations, all liquid transfers between process units is performed in a closed manner via nitrogen pressure. 4. Except for drum handling operations, the entire process is contained within ASME pressure-rated vessels. Operating pressure varies between deep vacuum and elevated pressure using nitrogen blanketing in all cases. 5. Drum transfers are made using a dip tube insertion through the closed drum bung port, and drums are filled bottom-up to minimize the risk of splashing and vapor entrainment. Spot ventilation is used at drum open bung ports to capture VOC’s. 6. Process cleaning solvents, process wastes, and empty drums are processed for offsite disposal by a hazardous waste incineration facility. Empty drums are not cleaned or recycled. 7. All process vessels and operations are located within a containment area to prevent inadvertent contact with soil or groundwater, in the event of a liquid spill. 8. A computer control system is used for monitoring, controlling, and alarming of all critical process parameters. XXX XXX XXX XXX XXX 

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Page 16 SANITIZED SUBMISSIONSee Attachment 014 (Process diagram use of NCS sanitized version.pdf)

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Page 20 SANITIZED SUBMISSIONPage 21 SANITIZED SUBMISSIONOptional Pollution Prevention Information

1. Process optimization studies are underway to maximize process conversion efficiencies and thus minimize subsequent waste handling via drums. 2. All generated waste water is processed for offsite disposal by a hazardous waste incineration facility. 3. The process containment systems prevent release to the environment through either groundwater or waste water streams. 4. Empty drums are processed by an offsite licensed waste treatment facility.

Page 22 SANITIZED SUBMISSION001 structure of NCS sanitized structure NCS sanitized.pdf Pt.I, Sec.B, 1e. 1 002 Entire page is confidential entire page is confidential.pdf Pt.I, Sec.B, 3. 1 003 CAS IES report sanitized CAS IES report confidential version.pdf Pt.I, Sec.B, 1c. 1 004 Process diagram NCS manufacture sanitized Process diagram manufacture of NCS sanitized version.pdf Pt.2, Sec.A, 1d. 1 005 Engineering controls sanitized Equipment-engineering controls Section A.2.page 9 sanitized Pt.2, Sec.A, End 1 006 SDS sanitized SDS NA GHS 7-17-2012 SANITIZED.pdf 5 007 1H NMR NCS Sanitized 1 H NMR Sanitized.pdf 1 008 13C NMR NCS sanitized 13 C NMR Sanitized.pdf 1 009 gas chromatogram sanitized GC chromatogram sanitized.pdf 1 014 Process diagram USE Process diagram use of NCS sanitized version.pdf Pt.2, Sec.A, 1d. (#2) 1 015 Letter from EPA on FYI 8(e) on HET study sanitized Letter from EPA on HET study SANITIZED.pdf 1

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## X Measured 6.6 E-009 Estimate 25 0.99 Measured completely soluble Estimate 25 THF, toluene 0.00079 (WSKOW) Estimate 25
130 Measured 0.2 XXX XXX 

## X LOg Kow = 5.1 Estimate 9.9 E-008 Estimate t1/2 400 days (river) Estimate

196 oC Measured

Clear, colorless to pale yellow liquid Measured Appearance
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## X Note: estimated data are from EPI suite or, if noted, from EPI suite 4.10, ECOSAR 1.11 Estimate ECOSAR Class Imides Estimate ECOSAR (imides) Fish 96-hr LC50 0.41 mg/L Estimate ECOSAR (imides) Daphnid 48-hr LC50 0.33 mg/L Estimate ECOSAR (imides) Green Algae 96-hr EC50 0.04 mg/L Estimate

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## ATTACHMENT HEADER SHEET Attachment Number 001 Attachment Name structure of NCS sanitized 

## Associated PMN Section Number

Pt.I, Sec.B, 1e. Does not contain CBI 

## Report Number BEEX120730792748440

## ATTACHMENT HEADER SHEET Attachment Number 002 Attachment Name Entire page is confidential 

## Associated PMN Section Number

Pt.I, Sec.B, 3. Does not contain CBI 

## Report Number BEEX120730792748440

## ATTACHMENT HEADER SHEET Attachment Number 003 Attachment Name CAS IES report sanitized 

## Associated PMN Section Number

Pt.I, Sec.B, 1c. Does not contain CBI 

## Report Number BEEX120730792748440

## ATTACHMENT HEADER SHEET Attachment Number 004 Attachment Name Process diagram NCS manufacture sanitized 

## Associated PMN Section Number

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

## Report Number BEEX120730792748440

## ATTACHMENT HEADER SHEET Attachment Number 005 Attachment Name Engineering controls sanitized 

## Associated PMN Section Number

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

## Report Number BEEX120730792748440

## ATTACHMENT HEADER SHEET Attachment Number 006 Attachment Name SDS sanitized 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number BEEX120730792748440

## ATTACHMENT HEADER SHEET Attachment Number 007 Attachment Name 1H NMR NCS Sanitized 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number BEEX120730792748440

## ATTACHMENT HEADER SHEET Attachment Number 008 Attachment Name 13C NMR NCS sanitized 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number BEEX120730792748440

## ATTACHMENT HEADER SHEET Attachment Number 009 Attachment Name gas chromatogram sanitized 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number BEEX120730792748440

## ATTACHMENT HEADER SHEET Attachment Number 014 Attachment Name Process diagram USE 

## Associated PMN Section Number

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

## Report Number BEEX120730792748440

## ATTACHMENT HEADER SHEET Attachment Number 015 Attachment Name Letter from EPA on FYI 8(e) on HET study sanitized 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number BEEX120730792748440