## Support Documents for Significant New Use Rule (SNUR) on Premanufacture Notice (PMN) P-11-63

EPA Docket EPA-HQ-OPPT-2012-0450

## Index A-001 Structure Activity Team (SAT) Report for PMN P-11-63 A-002 Initial Review Engineering Report for PMN P-11-63 A-003 Initial Review Exposure Report for PMN P-11-63 A-004 TSCA Section 5(e) Consent Order and Determinations Supporting Consent Order for PMN P-11-63

## A-001 Structure Activity Team (SAT) Report for PMN P-11-63

### SAT Report PMN Number: P-11-0063 SAT Date: 11/19/2010

Print Date: 3/2/2012

Related cases : Health related cases: Ecotox related cases : Analogs:

Concern levels : Type of Concern: Health Eco Comments Level of Concern: 1-2 1 Health: PMN ; Eco: p arent substance 2 3 Health: Incineration/degradation product ; Eco: toxicity of oncomplete incineration products to terrestrial organisms Persistence Bioaccum Toxicity Comments 3 1 1 PMN 3 2 2

Exposure Based Review : Health: Yes Exposure based testing (health): Inhalation only Ecotox: N o Routes of exposure : Health: Inhalation Ecotox: N o releases to water Fate: ; Keywords : Keywords: LUNG Summary of Assessment : Fate : Fate Summary: P-11-0063 FATE: MW = Solid S = N egl. VP < 1.0E-6 torr at 25 C (E) BP > 400 C (E) H < 1.00E-8 (E) POTW removal (%) = 90 via sorption Time for complete ultimate aerobic biodeg > moSorption to soils/sediments = v.strong PBT Potential: PMN *CEB FATE: Migration to ground water = negl

Health : Health Summary: Absorption is nil all routes based on physical/chemical p roperties. There is concern for lung overload and waterproofing of the lungs if respirable p articles are inhaled based on the high molecular weight of the PMN compound (MW = and its use as a stain repellent with a side chains. Low moderate concern. For the potential incomplete incineration product, based on test data for the analogue acid concerns are liver toxicity, blood toxicity, and male reproductive toxicity [rat 28-day oral NOAEL = 50 mg/kg, LOAEL = 150 mg/kg with liver toxicity; rat 90-day oral LOAEL = 10 mg/kg based on decreased body weight in males at all doses and liver toxicity and anemia at 200 mg/kg; there were toxic effects on the testes in 2 males in the 90-day oral study that were judged by the reviewer to be indicative of the potential for male reproductive toxicity. There is also concern for immunosuppression and oncogenicity based on data for and

Test Data: negative in Salmonella and E coli acute oral study in rats - no deaths or signs of toxicity at 2000 mg/kg not a skin irritant not an eye irritant Ecotox : Test Organism Test Type Test End Point Predicted Measured Comments

fish 96-h LC50 * daphnid 48-h LC50 * green algal 96-h EC50 * fish

_ chronic value * daphnid

_ chronic value * algal

_ chronic value * Sewage Sludge 3-h EC50

_ Sewage Sludge

_ Chronic Value _

Ecotox Values Comments: Predictions are based on SARs for ; SAR chemical class = ; MW solid with unknown mp (P); S < 0.001 mg/L at 25 C (P); p H7; effective concentrations based on 100% active ingredients and nominal concentrations; hardness <150.0 mg/L as CaCO3; and TOC <2.0 mg/L;high concern for the : to wild mammals and birds based on mammalian test data for mammals for

. Factors Values Comments Assessment Factor 10 Concentration of Concern ( p pb) *

SARs SAR Class new chemicals category: none Ecotox Category Ecotox Factors Comments: SAT Chair: Becky Jones

## A-002 Initial Review Engineering Report for PMN P-11-63file:///J|/INITENG/P11%20cases/p110063.eng.txt[3/2/2012 8:23:18 AM] INITIAL REVIEW ENGINEERING REPORT PMN: 11-0063 Focus Ready Draft 12/9/2010 ENGINEER: Avcin \ BCS \ DGR \ CLM PV (kg/yr): Revision Notes / Assessment Overview:

SUBMITTER: USE:

OTHER USES:

CRSS :file:///J|/INITENG/P11%20cases/p110063.eng.txt[3/2/2012 8:23:18 AM] Consumer Use: SAT (concerns) (11/19/2010): Related Cases and Related Cases and Misc SAT Info: Ecotox: Analogs: Migration to groundwater: Negligible PBT rating: P3B2T2 PMN: P3B1T1; incineration/degr product: P3B2T2 Health: 2 Inhalation, XB Testing (Testing desired) Eco: 3 No releases to Water, XB Testing (No Testing desired) OCCUPATIONAL EXPOSURE RATING: 1-2C NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER.file:///J|/INITENG/P11%20cases/p110063.eng.txt[3/2/2012 8:23:18 AM] POLLUTION PREVENTION CONSIDERATIONS: P2 Claims:

EXPOSURE-BASED REVIEW: Yes (1 criteria met) 1) # of workers exposed: 450 >1000? No 2) >100 workers with >10 mg/day inhalation exposure: No 3) (a) >100 workers w/1-10 mg/day inh. exp. & >100 days/yr: No (b) Routine Dermal Cont: >250 workers & >100 days/yr: Yes INITIAL REVIEW ENGINEERING REPORT PMN: 11-0063 USE: Number of Sites/ Location: 15 unknown sites Days/yr: 250 Basis:

Process Description:

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY IRER Note:file:///J|/INITENG/P11%20cases/p110063.eng.txt[3/2/2012 8:23:18 AM] Water Output 2: 5.8E+0 kg/site-day over 250 days/yr from 15 sites

Water or Incineration or Landfill Output 2: 4.8E+0 kg/site-day over 250 days/yr from 15 sites

Incineration High End: 1.9E+0 kg/site-day over 192 days/yr from 15 sites

RELEASE TOTAL 4.5E+4 kg/yr - all sites

7file:///J|/INITENG/P11%20cases/p110063.eng.txt[3/2/2012 8:23:18 AM] OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 450 Basis:

Inhalation: Exposure to Particulate (Class I) Low End of Range: 2.9E-2 mg/day over 250 days/yr High End of Range: 1.9E-1 mg/day over 250 days/yr Number of workers (all sites) with inhalation exposure: Basis: Roll Coating; EPA/OPPT UV Roll Coating Inhalation

NOTE: The respirator class is: I. Particulate (including solid or liquid droplets). INHALATION MONITORING DATA REVIEW 1) Uncertainty (estimate based on model, regulatory limit or data not specific to industry): Yes 2)a) Exposure level > 1 mg/day? No OR b) Hazard Rating for health of 2 or greater? 2 Yes Inhalation Monitoring Data Desired? Yes (both criteria met) Dermal:

Exposure to Liquid at 30.00% concentration High End: 5.3E+2 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 450 Basis:

## A-003 Initial Review Exposure Report for PMN P-11-6312/8/2010 Page 1 of 12

INITIAL REVIEW EXPOSURE REPORT (IRExR) Chemical ID: P-11-0063 Reviewer: Kwon/SD

Results Table: Dose, Concentration, and Days Exceeded Results Summary

Exposure Scenario 1 Water Landfill Stack Air Fugitive Air

Drinking Water Fish Ingestion ADR LADD ADR LADD 7Q10 4 CC = 1000 PDM Days Exceede d LADD ADR LADD ADR LADD

Release activity(ies) 2 ; exposure calculation(s) 3 mg/kg/day mg/kg/day mg/kg/day mg/kg/day μg/l # Days mg/kg/day mg/kg/day mg/kg/day mg/kg/day mg/kg/day

Use: Max ADR: max acute eco 6.33E-03 --- --- --- 1 .30E+02 --- --- 8.29E-03 --- --- ---

Use: PDM1 --- --- --- --- 1.30E+02 --- --- --- --- --- Use: Max LADD --- 1 .06E-04 --- --- --- --- --- --- 4.25E-04 --- ---

1 Exposure scenario titles consist of release activity followed by exposure calculation abbreviation. 2 Release activities are from engineering report's Manufact uring (Mfg), Processing (Proc) and Use release activity labels. Multiple release activities are combined in one exposu re scenario if their releases occur at same location. 3 Exposure calculations are Acute Dose Rate (ADR), Lifetime Average Daily Dose (LADD), and Probabilistic Dilution Model (PDM). There may be one, two, or all th ree exposure calculations per exposure scenario. CC is the aquatic concentration of concern. 4 This column displays concentration values for the 7Q10 streamflow, which is defined as the average daily streamflow of the seven consecutive days of lowest flow within a ten year period. Remarks: Results Table: Exposure Based (X B)/Persistent (P2B2) Criteria

Parameter Exp Based Persistent Exceedance Value Drinking (Surface) Wate r Dose (mg/kg/day) Yes Yes 6.33E-03 Fish Ingestion Dose (mg/kg/day) No No Inhalation Dose (mg/kg/day) Yes Yes 8.29E-03 Groundwater Dose (mg/kg/day) No No Surface Water Release After Treatment (kg/yr) Total Release After Treatment (kg/yr) Consumer Use? Fate test recommendations?: (default is NA)12/8/2010 Page 2 of 12

INITIAL REVIEW EXPOSURE REPORT

Chemical ID: P-11-0063 Assessor: Kwon/SD ENVIRONMENTAL RELEASES Scenario#:1 Number of Release Sites: Release Activity: Use: Max ADR Release Description: WATER LANDFILL Non-sludge/Sludge STACK FUGITIVE

Total Releases: (kg/yr) (kg/yr) (kg/yr) (kg/yr)

Non-sludge/Sludge Release Days/yr: Per Site Release: (kg/site/day) (kg/site/day) (kg/site/day) (kg/site/day)

Remarks:12/8/2010 Page 3 of 12

INITIAL REVIEW EX POSURE REPORT
Chemical ID: P-11-0063
SIC-CODE BASED HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES SCENARIO #: 1 Number of Sites: RELEASE ACTIVITY:Use: Max ADR SIC-CODE DESCRIPTION: SIC-CODE (S): EXPOSED POPULATION: Adult

WWT REMOVAL (%) RELEASE DAYS PRETREATMENT RELEASE (kg/site/day) POSTTREATMENT RELEASE (kg/site/day) DWT (%) BCF (L/kg) 0.00 0.00

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER PLANT TYPE % ILE FACILITY STREAM FLOW (MLD) STREAM CONC. ( μ g/l)

Harmonic

Mean 30Q5 7Q10 1Q10 Harmonic Mean 30Q5 7Q10 1Q10 ALL 50 6.00 14.09 22.71 27.50 ALL 10 19.84 75.77 129.58 154.97

DRINKING WATER AND FISH IN GESTION EXPOSURE ESTIMATES

Exposure Units Drinking Water Results Drinking Water Units Fish Ingestion Results Fish Ingestion

Units 50% 10% 50% 10% Cancer LADD pot 3.21E-05 1.06E-04 mg/kg/day 0.00 0.00 mg/kg/day LADC pot 1.65E-03 5.44E-03 mg/L 0.00 0.00 mg/kg Acute ADR pot 1.18E-03 6.33E-03 mg/kg/day 0.00 0.00 mg/kg/day

SIC Code Comments:12/8/2010 Page 4 of 12

INITIAL REVIEW EX POSURE REPORT Chemical ID: P-11-0063 INHALATION EXPOSURE ESTIMATES (POST-TREATMENT) SCENARIO #: 1 RELEASE ACTIVITY:Use: Max ADR RELEASE DESCRIPTION: METHOD OF CALCULATION: Screen3 EXPOSED POPULATION: Adult

Number of Sites: Per Site Fugitive Release: kg/site/day Fugitive Release Days per Year: days % Removal via Fugitive Release: % Total Fugitive Release: kg/yr Max Annual Average Air Concentration (Fugitive): 0.00 μg/m 3

Max 24 Hour Average Air Concentration(Fugitive): 0.00 μg/m 3

Per Site Stack Release: kg/site/day Stack Release Days per Year: days % Removal via Stack Release: % Total Stack Release: kg/yr Max Annual Average Air Con centration (Stack): 4.75 μg/m 3 Max 24 Hour Average Air Concentration (Stack): 45.10 μg/m 3

ASSUMPTIONS Exposure Units Results (Stack) Results (Fugitive) ED (years) AT (years) BW (kg) Inh. Rate (m 3 /hr) Cancer LADD pot (mg/kg/day) 3.49E-04 N/A 30.00 75.00 71.80 0.55 LADC pot (mg/m 3 ) 1.90E-03 N/A 30.00 75.00 NA NA Acute ADR pot

(mg/kg/day) 8.29E-03 N/A NA 1 day 71.80 0.55

Inhalation Comments:12/8/2010 Page 5 of 12

Stack Parameter Data Fugitive Parameter Data Stack Height 10.00 m Release Height: N/A Inside Stack Diameter: 0.10 m Length of Release Opening: N/A

Stack Gas Exit Velocity: 0.10 m/sec Width of Release Opening: N/A

Stack Gas Temperature: 293.00 K

Meteorological and Terrain Information: Surrounding Land Use: Rural Terrain Height: 0.00 m Distance to Residence of Interest: 100.00 m Meteorological Class: Full Stability Class: NA Wind Speed: NA

Downwash Information: Facility Length: NA m Facility Width: NA m Facility Height: NA m12/8/2010 Page 6 of 12

INITIAL REVIEW EXPOSURE REPORT

Chemical ID: P-11-0063 Assessor: Kwon/SD ENVIRONMENTAL RELEASES Scenario#:2 Number of Release Sites: Release Activity: Use: PDM1 Release Description: WATER LANDFILL Non-sludge/Sludge STACK FUGITIVE

Total Releases: (kg/yr) (kg/yr) (kg/yr) (kg/yr)

Non-sludge/Sludge Release Days/yr: Per Site Release: (kg/site/day) (kg/site/day) (kg/site/day) (kg/site/day)

Remarks:12/8/2010 Page 7 of 12

INITIAL REVIEW EX POSURE REPORT
Chemical ID: P-11-0063
SIC-CODE BASED HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES SCENARIO #: 2 Number of Site s: RELEASE ACTIVITY:Use: PDM1 SIC-CODE DESCRIPTION: SIC-CODE (S): EXPOSED POPULATION: Adult

WWT REMOVAL (%) RELEASE DAYS PRETREATMENT RELEASE (kg/site/day) POSTTREATMENT RELEASE (kg/site/day) DWT (%) BCF (L/kg) 0.00 0.00

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER PLANT TYPE % ILE FACILITY STREAM FLOW (MLD) STREAM CONC. ( μ g/l)

Harmonic

Mean 30Q5 7Q10 1Q10 Harmonic Mean 30Q5 7Q10 1Q10 ALL 50 6.00 14.09 22.71 27.50 ALL 10 19.84 75.77 129.58 154.97

DRINKING WATER AND FISH IN GESTION EXPOSURE ESTIMATES

Exposure Units Drinking Water Results Drinking Water Units Fish Ingestion Results Fish Ingestion

Units 50% 10% 50% 10% Cancer LADD pot 3.21E-05 1.06E-04 mg/kg/day 0.00 0.00 mg/kg/day LADC pot 1.65E-03 5.44E-03 mg/L 0.00 0.00 mg/kg Acute ADR pot 1.18E-03 6.33E-03 mg/kg/day 0.00 0.00 mg/kg/day

SIC Code Comments:12/8/2010 Page 8 of 12

INITIAL REVIEW EX POSURE REPORT
Chemical ID: P-11-0063

SIC CODE EXPOSURES TO SURFACE WATER RELEASES SCENARIO #: 2 RELEASE ACTIVITY: Use: PDM1 SIC CODE DESCRIPT ION: ASSOCIATED SIC CODES: SIC CODE RESULTS

COC ( μ g/L) Percent of Year COC Exceeded Number of Days COC Exceeded Release days/year Loading (kg/site/day) Waste Water Treatment (%) High/Avg Analysis

1000.00 High12/8/2010 Page 9 of 12

INITIAL REVIEW EXPOSURE REPORT

Chemical ID: P-11-0063 Assessor: Kwon/SD ENVIRONMENTAL RELEASES Scenario#:3 Number of Release Sites: Release Activity: Use: Max LADD Release Description: WATER LANDFILL Non-sludge/Sludge STACK FUGITIVE

Total Releases: (kg/yr) (kg/yr) (kg/yr) (kg/yr)

Non-sludge/Sludge Release Days/yr: Per Site Release: (kg/site/day) (kg/site/day) (kg/site/day) (kg/site/day)

Remarks:12/8/2010 Page 10 of 12

INITIAL REVIEW EX POSURE REPORT
Chemical ID: P-11-0063
SIC-CODE BASED HUMAN AND AQUATIC EXPOSURES TO SURFACE WATER RELEASES SCENARIO #: 3 Number of Sites: RELEASE ACTIVITY:Use: Max LADD SIC-CODE DESCRIPTION: SIC-CODE (S): EXPOSED POPULATION: Adult

WWT REMOVAL (%) RELEASE DAYS PRETREATMENT RELEASE (kg/site/day) POSTTREATMENT RELEASE (kg/site/day) DWT (%) BCF (L/kg) 0.00 0.00

AQUATIC EXPOSURE ESTIMATES - SURFACE WATER PLANT TYPE % ILE FACILITY STREAM FLOW (MLD) STREAM CONC. ( μ g/l)

Harmonic

Mean 30Q5 7Q10 1Q10 Harmonic Mean 30Q5 7Q10 1Q10 ALL 50 N/A N/A N/A N/A ALL 10 N/A N/A N/A N/A

DRINKING WATER AND FISH IN GESTION EXPOSURE ESTIMATES

Exposure Units Drinking Water Results Drinking Water Units Fish Ingestion Results Fish Ingestion

Units 50% 10% 50% 10% Cancer LADD pot 3.21E-05 1.06E-04 mg/kg/day 0.00 0.00 mg/kg/day LADC pot 1.65E-03 5.44E-03 mg/L 0.00 0.00 mg/kg Acute ADR pot N/A N/A mg/kg/day N/A N/A mg/kg/day

SIC Code Comments:12/8/2010 Page 11 of 12

INITIAL REVIEW EX POSURE REPORT Chemical ID: P-11-0063 INHALATION EXPOSURE ESTIMATES (POST-TREATMENT) SCENARIO #: 3 RELEASE ACTIVITY:Use: Max LADD RELEASE DESCRIPTION: METHOD OF CALCULATION: Screen3 EXPOSED POPULATION: Adult

Number of Sites: Per Site Fugitive Release: kg/site/day Fugitive Release Days per Year: days % Removal via Fugitive Release: % Total Fugitive Release: kg/yr Max Annual Average Air Concentration (Fugitive): 0.00 μg/m 3

Max 24 Hour Average Air Concentration(Fugitive): N/A μg/m 3

Per Site Stack Release: kg/site/day Stack Release Days per Year: days % Removal via Stack Release: % Total Stack Release: kg/yr Max Annual Average Air Con centration (Stack): 5.78 μg/m 3 Max 24 Hour Average Air Concentration (Stack): N/A μg/m 3

ASSUMPTIONS Exposure Units Results (Stack) Results (Fugitive) ED (years) AT (years) BW (kg) Inh. Rate (m 3 /hr) Cancer LADD pot (mg/kg/day) 4.25E-04 N/A 30.00 75.00 71.80 0.55 LADC pot (mg/m 3 ) 2.31E-03 N/A 30.00 75.00 NA NA Acute ADR pot

(mg/kg/day) N/A N/A NA 1 day 71.80 0.55

Inhalation Comments:12/8/2010 Page 12 of 12

Stack Parameter Data Fugitive Parameter Data Stack Height 10.00 m Release Height: N/A Inside Stack Diameter: 0.10 m Length of Release Opening: N/A

Stack Gas Exit Velocity: 0.10 m/sec Width of Release Opening: N/A

Stack Gas Temperature: 293.00 K

Meteorological and Terrain Information: Surrounding Land Use: Rural Terrain Height: 0.00 m Distance to Residence of Interest: 100.00 m Meteorological Class: Full Stability Class: NA Wind Speed: NA

Downwash Information: Facility Length: NA m Facility Width: NA m Facility Height: NA m

## A-004 TSCA Section 5(e) Consent Order and Determinations Supporting Consent Order for PMN P-11-63UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF POLLUTION PREVENTION AND TOXICS

REGULATION OF NEW CHEMICAL SUBSTANCES
PENDING DEVELOPMENT OF INFORMATION

In the matter of: ) Premanufacture Notice Number:

) ) ) ) ) [ ] ) P-11-0063 ) ) ) ) )

_________________________________________________________________ Consent Order and Determinations Supporting Consent Order

_________________________________________________________________ii
TABLE OF CONTENTS Preamble I. Introduction II. Summary of Terms of the Order III. Contents of PMN IV. EPA’s Assessment of Exposure and Risk V. EPA’s Conclusions of Law VI. Information Required to Evaluate Hu man Health and Environmental Effects

Consent Order I. Scope of Applicability and Exemptions II. Terms of Manufacture, Impor t, Processing, Distribution in Commerce, Use, and Disposal Pending Submission and Evaluation of Information III. Recordkeeping IV. Requests for Pre-Inspection Information V. Successor Liability Upon Transfer of Consent Order VI. Modification and Revocation of Consent Order VII. Effect of Consent Order Attachment A - Definitions Attachment B - Notice of Transfer of Consent Orderiii 

## PREAMBLE

I. INTRODUCTION Under the authority of § 5(e) of the Toxic Substances Control Act (“TSCA”) (15 U.S.C. 2604(e)), the Environmental Protection Agency (“EP A” or “the Agency”) issues the attached Order, regarding premanufacture notice (“PM N”) P-11-0063 for the chemical substance [

(“the PMN substance”) submitted by [ ] (“ the Company”), to take effect upon expiration of the PMN review period. The Company submitted the PMN to EPA pursuant to § 5(a)(1) of TSCA and 40 CFR Part 720.

Under § 15 of TSCA, it is unlawful for any person to fail or refuse to comply with any provision of § 5 or any order issu ed under § 5. Violators may be subject to various penalties and to both criminal and civil liabil ity pursuant to § 16, and to specific enforcement and seizure pursuant to § 17. In addition, chemical substanc es subject to an Order issued under § 5 of TSCA, such as this one, are subject to the § 12(b) export notice requirement.

II. SUMMARY OF TERMS OF THE ORDER The Consent Order for the PMN substance requires the Company to: (a) analyze and report [ ] impurities from the ]; (b) not exceed certain maximum established levels of [ impurities;iv (c) submit to EPA certain fate and product properties testing at least 14 weeks before manufacturing or importing a total of [ of the PMN substance; (d) not use the PMN substance in consum er products with spray applications; and (e) maintain certain records.v III. CONTENTS OF PMN By signing this Order, the Company represen ts that it has carefully reviewed this document and agrees that all info rmation herein that is claime d as confidential by the Company is correctly identified within brackets and that any information that is not bracketed is not claimed as confidential. To make this docum ent available for public viewing, EPA will remove only the information contai ned within the brackets.

Confidential Business Information Claims (Bracketed in the Preamble and Order) : Company identity; technical contact; chemical identity ; impurities; synonyms; trade identification; byproducts; production volume; operation descri ptions, including exposure and release estimates; pollution prevention; physical/c hemical properties; and test data.

Chemical Identity: Specific: [ Generic: Perfluoroa lkyl acrylate copolymer

Use: Specific: Coating material for uses in textiles and/or paper Maximum 12-Month Production Volume: [ ] kg/yr Test Data Submitted with PMN: health effects, physical/chemi cal properties, structure/activity relationshipsvi IV. EPA’S ASSESSMENT OF EXPOSURE AND RISK The following are EPA’s predictions regard ing the probable toxicity, human exposure and environmental release of the PMN substance, based on the information currently available to the Agency.

Human Health Effects Summary: EPA has concerns about potent ial fluorinated incineration or other decomposition products of the PMN substa nce. EPA also has concerns that the PMN substance under some conditions of use--particu larly non-industrial, commercial, or consumer use--could cause lung effects, based on limite d data on some perfluorinated compounds. An acute inhalation study in rats, with dose levels of 0.61 and 5.9 mg/L over a 4 hour exposure period, was received on a close analog. The approximat e lethal concentration was estimated to be greater than 5.9 mg/L, which is consistent with a low concern for acute inhalation toxicity. EPA expects that the PMN substance will degrade, based on data on ]. The PMN subs tance may degrade to [ ]. Based on available information, EPA has dete rmined that the PMN substance may have [ ] impurities. The Company has arranged for the raw material supplier to annually test the [ starting raw materi al for [ ] impurities and impurities and report those results to the Company in a Certificate of Analysis. Further, the raw material supplie r will annually test thevii [ ] starting raw ma terial for [ ], including establishing calibration curves where the level of quantification desired is [

. EPA is concerned that these perfluorinated products may be released to the environment from incomplete incineration of the PMN substa nce at low temperatures. EPA has preliminary evidence, including data on other [ ], suggesting that the PMN substance could degrade in the environment, under some conditions. Based on data on chemicals analogous to potential degradants of the PMN substance, including PF OA and [ ], EPA has concerns that potential degradation products from this PMN substance will persist in the environment, could bioaccumulate or biomagnify, and could be toxic to people, wild mammals, and birds (“PBT”). The presumed perfluorinated degradants for the PMN substance include ]. There is limited toxicological data in animals on [ ] or precursors, which is summarized below. EPA has some indication that a minor photolytic pathway could yield [ EPA does not have toxicity data on [ ]. PFOA is expected to persist for years in th e environment. Biodegradation and photolysis tests of analogous substances indicate little or no biodegradation or photol ysis of perfluoroalkyl compounds. Bioaccumulation concerns are base d on the measured presence of certain perfluoroalkyl compounds, includ ing PFOA, in wildlife and in hum an blood samples. Toxicity studies on PFOA indicate developmental, reproductiv e and systemic toxicity in various species, as well as possible cancer concerns. These factor s, taken together, raise concerns for potential adverse chronic effects in humans and wildlife. For additional information about PFOA, consult the EPA regulatory docket at OPPT-2003-0012. A dditional information about PFOA, [ ], and other perfluorinated substa nces may also be found in the Administrative Record for PFOS,viii PFOA, and Telomers and Related Chemicals (AR-226). Administrative Record (AR-226) is not currently available online, but c opies can be requested on CD-ROM from the EPA Docket office by calling (202) 566-0280 or sendi ng an email request to oppt.ncic@epa.gov

. Limited toxicological, ecological, and fate data now exist on [ ] and some of the ]-derived polymers and ot her substances; see the PMN docket for data for these specific PMNs. EPA previously received a pharmac okinetics study on [ ] and, for comparison, perfluorobutane sulfonate (“PFBS”) in the Cynom olgus Monkey. This study indicates that the serum half-life of [ is less than 24 hours in these monkey s. In comparison, the serum half-life of PFOA has been shown to be 20.9 da ys in female monkeys and 32.6 days in male monkeys. In addition, the serum half-life of PFOA in humans is approximately 3.8 years. Another pharmacokinetics study on [ ] in rats showed a serum half-life of one hour or less. These data support the assessment of re duced bioaccumulation of [ ] relative to
PFOA. In 2007, EPA received a 90-day study with a reproduction screen on [ ] with dose levels of 0, 20, 100, and 500 mg/kg/day. EPA’s review of this study concluded that a no-observed adve rse effect level (“NOAEL”) was not established in this study for systemic effects. Nasal tissue, liver, and thyroid effects were observed at 100 and 500 mg/kg/day; while body weight, re d blood cell system, clotting and kidney effects were observed at 500 mg/kg/day. The EPA reviewer conclude d that, although not clearly dose related, the elevation of two markers for liver toxicity across all trea ted groups of males in clinical chemistry and focal necrosis in the liver, acr oss all treated groups of males, as well as in treated recovery males, and the absence of this result in the c ontrols, leads to the conclusion that no NOAEL was achieved.ix For the one-generation reproductive toxicity component of this study, the reproductive toxicity NOAEL is 500 mg/kg/day (the highest dose tested). The systemic toxicity NOAEL for P1 rats was 20 mg/kg/day based on decreased body weights/body weight gains at 100 and 500 mg/kg/day. The systemic toxicity for F1 adults is 100 mg/kg/day based on reduced body weights/body weight gains and reduced f ood consumption at 500 mg/kg/day. The developmental toxicity NOAEL for F1 pups was 100 mg/kg/day based on decreased pup weights at 500 mg/kg/day. The rats (P1 generation; 20/se x/group) were administered gavage doses of 0, 20, 100 or 500 mg/kg/day for 70 days pre-mating, a nd then mated for a maximum of 2 weeks to produce 1 litter. Dosing was continued during mating, gestation, and lactation. In 2005, a Combined Repeated-Dose Toxic ity Study with Reproduction/Developmental Screening Test (OECD 422) in rats was conduc ted on ]. The EPA review of these subchronic and reproductive da ta on [ ] concluded that for [ ], no reproductive effects were seen at 50, 150, and 450/300 mg/kg/ day (450 was reduced to 300 in the study on day 4 because of toxicity) dose levels; however, sy stemic effects--primar ily liver effects--were seen. EPA review places the NOAEL for [ at 50 mg/kg/day. In 2006, another 90-day oral repeated dos e toxicity study (OECD 408) was submitted with dose levels of 0 (vehicle control), 10, 50, or 200 mg/kg/day, based on the previous Combined Study (OECD 422). EPA review sets the Lowest-Observed Effect Level (“LOEL”) or LOAEL at 10 mg/kg/day, based on the lower body we ight gains in all treated groups of males. There was treatment-related toxicity in the liver and the red blood cell system (anemia) in males, as well as increased peroxisomal beta oxidation activity at 200 mg /kg/day. Hepatotoxicity and peroxisomal beta oxidation activity have been observed in studies on PFOA.x The significance of the finding of a benign br ain tumor (astrocytoma) in one male rat in the high dose group is not clear. The tumor is not the type normally associated with PFOA-type compounds, is not rare, and may be incidental. Abnormal histopathology observations in the testes of 2 males and epididymides of 1 male at the 200 mg/kg/day dose level are a sign of male reproductive toxicity. Further st udies should investigate male re productive effects. From this study, the potential for immunotoxic effects is lo w, in contrast to some studies showing immunotoxic effects from PFOA. Any investigation of immunot oxic effects should await the corroborative studies now being conducted by EPA’ s Office of Research and Development. There were no clinical signs of neurotoxicity and there were no treatment-related effects in the functional observation battery or motor behavior. Another 90-day study on [ ] concluded that blood and liver effects were seen at the highest dose, with doses comparab le to those in other studies. A one-generation reproduction/developmenta l toxicity study in mice on the [ ] was submitted to the Agency. In this study, pregnant mice were administered the test substance via gavage duri ng gestation days (GD) 6-18. Th e NOAEL for maternal toxicity was 175 mg/kg/day (the highest dose tested). Signs of developmental toxicity were observed at 175 mg/kg/day on postnatal day 1 an d consisted of increases in th e number of stillborn pups and pup deaths, reductions in the average pup body weight per litter, with tw o litters having one pup each with corneal opacity and microphthalmia, and one litter with a pup with lenticular opacity. The NOAEL for developmental toxicity is 35 mg/kg/day. These and other data indicate a different and less toxic profile for [ ], (a presumed environmental degradant of the PMN substance), than for PFOA. However, based on: (1) the persistence of [ ; (2) pot ential intermediate fate produ cts; and, (3) the possibility orxi likelihood that this substance may be used as a major substitute for some uses of PFOA, EPA believes that more information is needed on the toxicity of [ ] and possibly other environmental degradants, and the fate and physical/chemical properties of [ -derived or related polymers in the environment. EPA also believes that additional reproducti ve and long-term toxicological studies on [ ] in animals are warranted. EPA has received a 90-day Repeated Dose study with Reproductive Screening and a two year oral toxicity study conducted by other companies. Further, EPA expects that a modified repr oductive test (OECD 421) will be conducted by another company. The modifications for the repr oductive test include: (1) increase the parental sample size to 20, (2) the duration of the study sh ould be extended to until the pups have reached sexual maturation, (3) parental males should be dos ed for 10 weeks prior to mating, (4) dosing of the parental animals should be continued through lactation and then the pups should be directly dosed until they reach sexual maturation, (5) pup body weight should be recorded on lactation days 0, 4, 7, 14, and 21 and then at weekly interval s, (6) litter size can be standardized to 4 pups/litter on lactation day 4 (optional), (7) at weaning one pup/sex/ litter can be randomly selected to follow until sexual maturation, a nd (8) the time of sexual maturation should be recorded (i.e. vaginal opening and preputial separation). EPA also expects that a Combined Carcinogenicity/Chronic Toxi city test (OPPTS 870.4300 or OECD 453) and an avian reproduction test (OECD 206) in bobwhite quail will be conducted by another company. EPA may still seek an additional avian reproduction study (OECD 206) in mallard ducks; as well as comparative data. In addition, pharmacokine tics of [ and other perfluorinated substances will be developed in testing conduc ted by the National Technology Program in the so-called Perfluoro Class Study.xii EPA believes that characterization of the PMN substance would be valuable. Limited testing is triggered in this order to characterize the PMN substance.

Environmental Effects Summary: EPA expects the PMN substance or the degradants to be highly persistent. There is expected to be a low concern for e nvironmental risk to the intact PMN substance based on similar [ ]. There is concern fo r terrestrial species for the potential ultimate degradation product based on PFOA and PFOS. There is also high concern for possible environmental effects from the potentially persistent degradation product [ . As stat ed previously, an analog of [ , PFOA, is persistent in the environment, has a long bioreten tion time in various species, has been detected in a number of species of wildlife, including marine mammals, and is considered toxic to mammalian and other species. The toxicological properties and presence of PFOA in the environment continue to be i nvestigated. While EPA has limited acute ecotoxicological effects data on [ ] in fish, daphnia, and algae, ad ditional chronic data on [ ] is desired. EPA anticipates these te sts are being conducted by other companies.

Exposure and Environmental Release Summary: Thermal and simulated incineration testing exists on some related polymers. This testing in dicates that incomplete incineration products are formed at lower incineration temperatures. Modified Zahn-Wellens and Semi-Continuous Activated Sludge (“SCAS”) biodegr adation tests have been conducte d on some related polymers. EPA has determined that some related polymers degrade, while another did not show signs of degradation during the time frame of the test. EPA has received and reviewed test data showingxiii that certain polymers with perfl uoroalkyl substituents degrade to form perfluoroalkyl-containing intermediates and perfluoroalkyl-c ontaining organic acids. EPA expects that the PMN substance will degrade in this way.

Exposure and Release Summaries: 95% of the PMN substance will be imported in the formulated product, while 5% of the PMN substance will be processed domestically. The processing step of [ ] will take place at [ ]. Occupational exposures are . [

] All releases of the PMN substa nce to the environment during processing [ ] Use as [ . Occupational exposures expected include [ . [

]. [ . Environmental releases during use are [

].

V. EPA’S CONCLUSIONS OF LAW The following findings constitute th e basis of the Consent Order:xiv (a) EPA is unable to determine the potential fo r human health and environmental effects from exposure to the PMN substance and potential de gradation products. EPA therefore concludes, pursuant to § 5(e)(1)(A)(i) of TS CA, that the information availabl e to the Agency is insufficient to permit a reasoned evaluation of the human health and environmental effects of the PMN substance and potential degradation products.

(b) In light of the potential risk of human health and e nvironmental effects posed by the uncontrolled manufacture, import, pr ocessing, distribution in commerce, use, and disposal of the PMN substance, EPA has concluded, pursuant to § 5(e)(1)(A)(ii)(I) of TS CA, that uncontrolled manufacture, import, processing, distribution in commerce, use, and disposal of the PMN substance may present an unreasonable risk of in jury to human health and the environment.

(c) In light of the estimated production volume of, and human exposure to, the PMN substance and potential degradation products, EPA has further concluded, pursuant to § 5(e)(1)(A)(ii)(II) of TSCA, that the PMN substance will be produced in substantial quantities and may reasonably be anticipated to enter the environment in substant ial quantities, and there may be significant (or substantial) human exposure to the subs tance and potential degradation products.

VI. INFORMATION REQUIRED TO EVALUATE HUMAN HEALTH AND ENVIRONMENTAL EFFECTS Triggered Testing. The Order prohibits the Company from exceeding a specified production volume unless the Company submits the information described in the Testing section of this Order in accordance with the cond itions specified in the Testing section.xv Pended Testing. The Order does not require submission of the pended testing listed below at any specified time or production volume. However, the Order’s restrictions on manufacture, import, processing, distribution in commerce, use, and disposal of the PMN substance will remain in effect until the Or der is modified or revoked by EPA based on submission of that or other relevant informati on. EPA expects that protocols would be submitted prior to any additional testing. Due to the limite d water solubility of some of these substances and consequent analytical difficu lties, some modificat ion of the protocols may be necessary. These and other modifications will be agreed upon between EPA and the Company. The following tests on the PMN substance would be necessary to evaluate the environmental fate and tran sport and health effects:

Test Description Guideline Anaerobic Biodegradability of Organic Compounds in Digested Sludge OECD 311

Phototransformation of Chemicals on Soil Surfaces–2 soils Draft OECD Guideline Jan. 2002 Simulation Test-Aerobic Sewage Treatment (Activated Sludge Units) OECD 303A

Aerobic and Anaerobic Transformations in Aquatic Sediment Systems OECD 308

Reproduction/Developmental Toxicity Screening Test OPPTS 870.3550 modified for [ Combined Chronic Toxicity/C arcinogenicity OPPTS 870.4300

## CONSENT ORDER

I. SCOPE OF APPLICABILITY AND EXEMPTIONS (a) Scope . The requirements of this Order apply to all commercial manufacturing, processing, distribution in commerce, use and disposal of the chemical substance [

] (P -11-0063) (“the PMN substance”) in the United States by (“the Company”), except to the extent that those ac tivities are exempted by paragraph (b).

(b) Exemptions . Manufacturing, processing, distribution in commerce, use and disposal of the PMN substance is exempt from the requirements of this Order (except the requirements in the Recordkeeping and Successor Liability Upon Transf er Of Consent Order sections) only to the extent that (1) these activities are conducted in full compliance with all applicable requirements of the following exemptions, and (2) such complian ce is documented by appropr iate recordkeeping as required in the Recordkeepi ng section of this Order. (1) Export . Until the Company begins commercial manufacture of the PMN substance for use in the United States, the requirements of this Order do not apply to ma nufacture, processing or- 2 - distribution in commerce of the PMN substance solely for export in accordance with TSCA §12(a) and (b), 40 CFR 720.3(s) and 40 CFR Part 707. However, once the Company begins to manufacture the PMN substance for use in the United States, no further activity by the Company involving the PMN substance is ex empt as “solely for export” even if some amount of the PMN substance is later exported. At th at point, the requirements of this Order apply to all activities associated with the PMN substance while in the te rritory of the United States. Prior to leaving U.S. territory, even those quanti ties or batches of the PMN substa nce that are destined for export are subject to terms of the Order, and count towa rds any production volume test triggers in the Testing section of this Order. (2) Research & Development (“R&D”) . The requirements of this Order do not apply to manufacturing, processing, distribu tion in commerce, use and disposal of the PMN substance in small quantities solely for rese arch and development in accord ance with TSCA §5(h)(3), 40 CFR 720.3(cc), and 40 CFR 720.36. The requirements of this Order also do not a pply to manufacturing, processing, distribution in commer ce, use and disposal of the PM N substance when manufactured solely for non-commercial research and de velopment per 40 CFR 720.30(i) and TSCA §5(i). (3) Byproducts . The requirements of this Order do not apply to the PMN substance when they are produced, without separa te commercial intent, only as a “ byproduct” as defined at 40 CFR 720.3(d) and in compliance with 40 CFR 720.30(g). (4) No Separate Commercial Purpose . The requirements of this Order do not apply to the PMN substance when it is manufactured, pursuant to any of the exemptions in 40 CFR 720.30(h), with no commercial purpose separate from the substa nce, mixture, or article of which it is a part. (5) Imported Articles . The requirements of this Order do not apply to the PMN substance when it is imported as part of an “article” as defined at 40 CF R 720.3(c) and in compliance with 40- 3 - CFR 720.22(b)(1).

(c) Automatic Sunset . If the Company has obtained for the PMN substance a Test Market Exemption (“TME”) under TSCA §5(h)(1) and 40 CFR 720.38 or a Low Volume Exemption (“LVE”) or Low Release and Exposure Exemp tion (“LoREX”) under TSCA §5(h)(4) and 40 CFR 723.50(c)(1) and (2) respectively, any such exempti on is automatically re ndered null and void as of the effective date of this Consent Order.

II. TERMS OF MANUFACTURE, IMPORT, PROCESSING,

DISTRIBUTION IN COMMERCE, USE, AND DISPOSAL PENDING SUBMISSION AND EVALUATION OF INFORMATION

PROHIBITION The Company is prohibited from manufacturi ng the PMN substance in the United States, for any non-exempt commercial purpose, pending th e development of information necessary for a reasoned evaluation of the human health and envi ronmental effects of th e substance, and the completion of EPA’s review of, and regulatory action based on, that information, except in accordance with the conditions described in this Order.

CHEMICAL SYNTHESIS AND COMPOSITION (a) Restriction and testing. (1) The company shall not manufacture the PMN substance for non-exempt commercial purposes unless annual testing of the [ ] starting raw material, as supplied by the raw material supplier in the Certificate of Analysis, meets the established purity levels as specified in Table 1 of this Order.- 4 - (2) The company shall not manufacture the PMN substance for non-exempt commercial purposes unless annual testing of the [ ] starting raw material, as supplied by the raw material supplier in the Certificate of Analysis, meets the established purity levels as specified in Table 2 of this Order. (3) (i) If, within one year before the date of commencement of n on-exempt commercial manufacture of the PMN substance, a product that contained [ products was processed or manufactured in the same equipment at the facility where the PMN substance is to be made, the Company shall annually test the Initially Isolated Formulations Containing the PMN Substance for the analytes specified in Table 3 of this Order. This testing shall be conducted upon initial commencement of non-exempt manufacture or import of the PMN substance at each manufacturing facility and annuall y thereafter, until one (1) year after the date of the last manufacture or processing of a product that contai ns [ ] produc ts at that facility. Thereafter, no further testing of Initially Isolated Formulati ons Containing the PMN Substance shall be required provided that there is no s ubsequent or new manufacture or processing of a product that contains [ ] products in the same equipmen t at the facility where the PMN substance is to be made. (ii) If any new manufacturing facility is a dded or if the proce ss of manufacture of the PMN substance or any intermediate thereof is significantly altered, then the Initially Isolated Formulations Containing the PMN Substance must be tested at the commencement of these actions and annually thereafter (as shown in Table 3). (iii) The Company shall submit all test protocols to EPA fo r review prior to initiating testing of Initially Isolated Formulati ons Containing the PMN Subs tance as set forth in (3)(i) and (3)(ii) above.- 5 -

(b) Recordkeeping

. (1) The Company shall record the levels of impurities, tested in accordance with paragraph (a), associated with the PMN substance manufact ured by the Company, as specified in (2) - (4) below. (2) The Company shall record those analytes present in the [ at each manufacturing facility using this raw material (as shown in Table 1) as set forth in (a)(1) above. (3) The Company shall record the analyte [ present in the [ ] starting raw mate rial (as shown in Table 2) as set forth in (a)(2) above. (4) The Company shall record the analytes in th e Initially Isolated Formulations Containing the PMN Substance (as shown in Table 3) as set forth in (a)(3) above.

(c) Foreign Manufacture of the PMN Substance. If the PMN substance is imported, the Company shall obtain from the foreign manufacturer written documentation to certify that representative samples of the [ and Initially Isol ated Formulations Containing the PMN Substance have been tested consistent with the requirements of paragraph (a).

(d) Reporting. (1) The Company shall report the results of te sting under paragraph (a) to EPA at initial commencement of non-exempt manufacture or import and then a nnually thereafter. (2) In addition, the Company shall, for the [ ] starting ra w material, annually report the average values and range of values, including outlying data, obtained through annual testing in accordance with paragraph (a)(1).- 6 -

TABLE 1 : Chemicals to be Tested at Least A nnually in the [ ]

Analyte CAS Registry Number Maximum Limit [ ] [ )] [ [ ] [ [ [

[ [ [ [ [ [ [ [ [ [ [ ]

TABLE 2 : Chemicals to be Tested at Least A nnually in the [ ] Analyte CAS Registry Number Maximum Limit

[ [

TABLE 3 : Chemicals to be Annually Tested in the In itially Isolated Formul ations Containing the PMN Substance

Analyte CAS Registry Number Maximum Limit [ ] [ [ [ [ [ [- 7 - TESTING (a) Section 8(e) Reporting. Reports of information on th e PMN substance which reasonably supports the conclusion that the PMN substance presents a substantial risk of injury to health or the environment and which is required to be reporte d under TSCA section 8(e) shall reference the appropriate PMN identification number for this substance and contain a statement that the substance is subject to this Cons ent Order. Additional information regarding section 8(e) reporting requirements can be found at www.epa.gov/oppt/tsca8e.

(b) Notice of Study Scheduling. The Company shall notify, in writing, the EPA Monitoring Assistance and Media Programs Division (2227A ), Office of Enforcement and Compliance Assurance, U.S. Environmental Protecti on Agency, 1200 Pennsylvania Avenue, N.W., Washington, D.C. 20460, of the following inform ation within 10 days of scheduling any study required to be performed pursuant to this Order, or within 15 days after the effective date of this Order, whichever is later: (1) The date when the study is scheduled to commence; (2) The name and address of the labor atory which will conduct the study; (3) The name and telephone number of a pers on at the Company or the laboratory whom EPA may contact regarding the study; and, (4) The appropriate PMN identification number for each substance and a statement that the substance is subject to this Consent Order.

(c) Good Laboratory Practice St andards and Test Protocols. Each study required to be performed pursuant to this Order must be conducted accord ing to TSCA Good Laborat ory Practice Standards- 8 - at 40 CFR Part 792 and using me thodologies generally accepted in the relevant scientific community at the time the study is initiated. Before starting to conduc t any study, the Company must obtain approval of test protocols from EP A by submitting written protocols to EPA. EPA will respond to the Company within 4 weeks of r eceiving the written protocols. Published test guidelines specified in paragraph (d) provide genera l guidance for development of test protocols, but are not themselves acceptable protocols. EPA approval of a test protocol does not mean preacceptance of test results.

(d) Triggered Testing Requirements. The Company is prohibited from manufacturing or importing the PMN substance beyond the aggreg ate manufacture and import volume (“the production volume limit”) of 406,000 kilograms, unl ess the Company conducts the following three listed studies on the PMN substance and submits all final reports and underlying data in accordance with the conditions specif ied in this Testing section. 1) Combined Direct and Indi rect Photolysis with Hydrol ysis Study on the commercial dispersion without UV stabilizer: For the indire ct photolysis samples, use humic acid. To observe hydrolysis activit y, substitute dark controls in the indirect photol ysis test. The analytes will be:

Analyte CAS Registry Number [ ] [ [ [ [ [ [ ] [ ] [- 9 - If it is infeasible to quantitatively analyze [ ] (C AS Registry Number ) and [ (C AS Registry Number [ ]), then non-quantitative monitoring may be implemented instead. 2) Highly Modified OECD 302B Test: The test period will be 56 days or longer. Higher inoculum-to-substrate levels and periodic fresh feed of the inoculum will be used. The analytes will be:

Analyte CAS Registry Number [ ] [ [ [ [ ] [ [ ] [ [ ] [ [ [ [ [ [ ] [

3) Accelerated weathering for textiles with a water component: A pre-test will be done to verify that loading of the commercial disper sion without the UV stab ilizer on to the textile surface is sufficiently high and that the test sy stem performs properly. Irradiation of coated fabric would occur in a closed system usi ng a reverse-phase cartr idge for trapping the analytes. The starting material residuals will be characterized and the analytes to be quantified will be:

Analyte CAS Registry Number [ [ ] [ [ [- 10 - 4) Aerobic and Anaerobic Transformation in Soil (OECD 307): The Company is prohibited from manufacturing or importing the PMN substance beyond 3 years after commencement of non-exempt commercial manu facture, unless the Company conducts the Aerobic component of the Transforma tion in Soil (OECD 307) study on the PMN substance and submits all final reports a nd underlying data in accordance with the conditions specified in this Testing section. The Company is prohibited from manufacturing or importing the PMN substa nce beyond 6 years afte r commencement of non-exempt commercial manufacture, unl ess the Company conducts the Anaerobic component of the Transformation in Soil (OECD 307) study on the PMN substance and submits all final reports and underlying data in accordance with the cond itions specified in this Testing section. The analytes will be:

Analyte CAS Registry Number [ [ [ [ [ [ ] [ [ [ [ [ [

For these four degradation studies, full kinetic st udies will be conducted regardless of screening tests results.

(e) Test Reports. The Company shall: (1) conduct each study in good faith, with due care, and in a scientifically valid manner; (2) promptly furnis h to EPA the results of any interim phase of each study; and (3) submit (with an ad ditional sanitized copy, if confid ential business information is- 11 - involved), the final report of each study and all u nderlying data (“the report and data”) to EPA no later than 14 weeks prior to exceeding the production volume or time limit. The final report and data must be submitted as a support document for the PMN, using the procedures set out in 40 CFR 720.40. The final report shall contain the contents specified in 40 CFR 792.185. Underlying data shall be submitted to EPA in accordance with the applicable “Reporting,” “Data and Reporting,” and “Test Report” subp aragraphs in the applicable te st guidelines. However, for purposes of this Consent Order, the word “should” in those subparagraphs sh all be interpreted to mean “shall” to make clear that the submission of such information is mandatory. EPA will require the submission of raw data such as slid es and laboratory notebooks only if EPA finds, on the basis of professional judgment, that an adequate evaluation of the st udy cannot take place in the absence of these items.

(f) Testing Waivers. The Company is not required to conduc t a study specified in paragraph (d) of this Testing section if notifie d in writing by EPA that it is unnecessary to conduct that study.

(g) Equivocal Data. If EPA finds that the data generate d by a study are scientifically equivocal, the Company may continue to manufacture and import the PMN substance beyond the applicable production volume or time limit. To seek relief from any other restrictions of this Order, the Company may make a second attempt to obtai n unequivocal data by re conducting the study under the conditions specified in paragraphs (b), (c), an d (e)(1) and (2). The test ing requirements may be modified, as necessary to permit a reasoned evaluation of the risks presented by the PMN substance, only by mutual consent of EPA and the Company.- 12 - (h) EPA Determination of Invalid Data. (1) Except as described in subparagraph (h)(2) , if, within 6 weeks of EPA’s receipt of a test report and data, the Company receives written notice that EPA fi nds that the data generated by a study are scientifically invali d, the Company is prohibited from further manufacture and import of the PMN substance beyond the applicab le production volume or time limit. (2) The Company may continue to manufacture and import the PMN substance beyond the applicable production volume or time limit only if so notified, in writing, by EPA in response to the Company’s compliance with either of the following subparagraphs (h)(2)(i) or (h)(2)(ii). (i) The Company may reconduc t the study in compliance with paragraphs (b), (c), and (e)(1) and (2). If there is sufficient time to reconduct the study and submit the report and data to EPA at least 14 weeks before exceeding the production volume or time limits as required by subparagraph (e)(3), the Company shall comply with subparagr aph (e)(3). If there is insufficient time for the Company to comply with subpa ragraph (e)(3), the Company may exceed the production volume or time limit and shall submit th e report and data to EPA within a reasonable period of time, all as specified by EPA in the notice described in subparagraph (h)(1). EPA will respond to the Company, in writing, within 6 week s of receiving the Company’s report and data. (ii) The Company may, within 4 weeks of receiving from EPA the notice described in subparagraph (h)(1), submit to EPA a written report refuting EPA’s finding. EPA will respond to the Company, in writing, within 4 w eeks of receiving the Company’s report.

(i) Company Determination of Invalid Data. (1) Except as described in subparagraph (i )(2), if the Company becomes aware that circumstances clearly beyond the control of the Company or laboratory will prevent; or have- 13 - prevented, development of scientifically valid da ta under the conditions specified in paragraphs (c), (d), and (e); the Company remains prohibite d from further manufacture and import of the PMN substance beyond the applicable pr oduction volume or time limit. (2) The Company may submit to EPA, within 2 weeks of first becoming aware of such circumstances, a written statement explaining w hy circumstances clearly beyond the control of the Company or laboratory will cause or have caused de velopment of scientifically invalid data. EPA will notify the Company of its response, in writ ing, within 4 weeks of receiving the Company’s report. EPA’s written response may either: (i) allow the Company to continue to manufacture and import the PMN substance beyond the applicable production volume or time limit, or (ii) require the Company to continue to conduct, or to reconduct, the study in compliance with paragraphs (b), (c), and (e)(1) a nd (2). If there is sufficient time to conduct or reconduct the study and submit the report and data to EPA at least 14 weeks before exceeding the production volume or time limits, as required by subparagraph (e)(3), the Company shall comply with subparagraph (e)(3). If there is insu fficient time for the Company to comply with subparagraph (e)(3), the Company may exceed the production volume or time limit and shall submit the report and data to EPA within a reasonab le period of time, all as specified by EPA in the notice described in subparagraph (i)(2). EPA will respond to the Company, in writing, within 6 weeks of receiving the Company’s report and data, as to whether the Company may continue to manufacture and import beyond the appli cable production volume or time limit.

(j) Unreasonable Risk.- 14 - (1) EPA may notify the Company in writing that EPA finds that the data generated by a study are scientifically valid and un equivocal and indicate that, despite the terms of this Order, the PMN substance will or may present an unreasonable risk of injury to human health or the environment. EPA’s notice may specify that th e Company undertake certain actions concerning further testing, manufacture, import, processing, distribution, use and/or disposal of the PMN substance to mitigate exposures to or to be tter characterize the risks presented by the PMN substance. Within 2 weeks from receipt of such a notice, the Company must cease all manufacture, import, processing, distribution, us e and disposal of the PMN substance, unless either: (A) within 2 weeks from r eceipt of the notice described in subparagraph (j)(1), the Company complies with such requireme nts as EPA’s notice specifies; or (B) within 4 weeks from r eceipt of the notice described in subparagraph (j)(1), the Company submits to EPA a written report refuting EPA’s finding and/or the appropriateness of any additional requirements imposed by EPA. The Company may continue to manufacture, import, process, distribute, use and dispose of th e PMN substance in accord ance with the terms of this Order pending EPA’s response to the Compa ny’s written report. EPA will respond to the Company, in writing, within 4 weeks of receiving the Company’s report. Within 2 weeks of receipt of EPA’s written response, the Company sh all comply with any requirements imposed by EPA’s response or cease all manufacture, import, processing, distribution, us e and disposal of the PMN substance.

(k) Other Requirements. Regardless of the satisfaction of any other conditions in this Testing section, the Company must continue to obey all the terms of this Consent Order until otherwise- 15 - notified in writing by EPA. The Company may, based upon submitted test data or other relevant information, petition EPA to modify or revoke provi sions of this Consent Order pursuant to Part VI. of this Consent Order.

MANUFACTURING (a)(1) Prohibition. The Company shall not cause, encourage, or suggest the ma nufacture or import of the PMN substance by any other person. (2) Sunset Following SNUR. Subparagraph (a)(1) shall ex pire 75 days after promulgation of a final significant new use rule (“SNUR”) governing the PMN substan ce under section 5(a)(2) of TSCA unless the Company is notified on or befo re that day of an action in a Federal Court seeking judicial review of the SNUR. If the Company is so no tified, subparagraph (a)(1) shall not expire until EPA notifies the Company in writin g that all Federal Court actions involving the SNUR have been resolved and th e validity of the SNUR affirmed. (3) Notice of SNUR. When EPA promulgates a final SNUR for the PMN substance and subparagraph (a)(1) expires in accordance with su bparagraph (a)(2), the Company shall notify each person whom it causes, encourages or suggests to manufacture or import the PMN substance of the existence of the SNUR. Such no tification must be in writing a nd must specifically include all limitations contained in the SNUR which are defined as signifi cant new uses, and which would invoke significant new use notification to EPA fo r the PMN substance. Such notice must also reference the publication of the SNUR for the PMN s ubstance in either the Fe deral Register or the Code of Federal Regulations.

USE- 16 - The Company shall not use the PMN substance in consumer products with spray applications.

DISTRIBUTION Export Notice Requirement . No later than the date of dist ribution, the Company shall notify in writing any person to whom it dist ributes the PMN substance that, due to the issuance of this Consent Order under section 5(e) of TSCA, the PMN substance is subject to the export notification requirements of TSCA section 12(b) and 40 CFR Part 707 Subpart D. Such notice shall contain, in the form in which it appears in this Consent Order, the following information: (1) the PMN number, and (2) either (A) the specific chemical identity of the PMN substance, or (B) if the specific chemical identity is confiden tial, the generic chemical identity.

RISK NOTIFICATION (a) If as a result of the test data required under the terms of this Or der, the Company becomes aware that the PMN substance may present a risk of injury to human health or the environment (or is so notified by EPA), the Company must incorp orate this new information, and any information on methods for protecting against su ch risk, into a Material Safety Data Sheet ("MSDS") for the PMN substance, as described in 40 CFR secti on 721.72(c), within 90 days from the time the Company becomes aware of the new informa tion. If the PMN substance is not being manufactured, imported, processed, or used in the Company's workplace, the Company must add the new information to an MSDS before the PM N substance is reintroduced into the workplace.

(b) The Company must ensure that persons who will receive the PMN substance from the Company, or who have received the PMN substan ce from the Company within 5 years from the- 17 - date the Company becomes aware of the new info rmation described in paragraph (a) of this section, are provided an MSDS c ontaining the information require d under paragraph (a) within 90 days from the time the Company beco mes aware of the new information.

III. RECORDKEEPING (a) Records. The Company shall maintain the followi ng records until 5 years after the date they are created and shall make them available for inspection and copying by EPA in accordance with section 11 of TSCA: (1) Exemptions . Records documenting that the PMN substance did in fact qualify for any one or more of the exemptions described in Secti on I, Paragraph (b) of this Order. Such records must satisfy all the statutory and regulatory recordkeeping re quirements applicable to the exemption being claimed by the Company. Any amounts or batches of the PMN substance eligible for the export only exemp tion in Section I, Paragraph (b)(1) of this Order are exempt from all the requirements in this Recordkeeping section, if the Company maintains, for 5 years from the date of their creation, copies of the export label and expor t notice to EPA, required by TSCA sections 12(a)(1)(B) and 12(b), respectively. Any amounts or batches of the PMN substance eligible for the research and development exempti on in Section I, Paragra ph (b)(2) of this Order are exempt from all the requirements in this Reco rdkeeping section, if the Company maintains, for 5 years from the date of their creation, th e records required by 40 CFR 720.78(b). For any amounts or batches of the PMN substance claimed to be eligible for any other exemption described in Section I, Paragraph (b) of this Order, the Company shall keep records demonstrating qualification for that exemption as well as the reco rds specified in paragra phs (3) and (4) below, but is exempt from the other recordkeeping re quirements in this Recordkeeping section;- 18 - (2) Records documenting compliance with the Chemical Synthesis and Composition, section of this Order; (3) Records documenting the manufacture and importation volume of the PMN substance and the corresponding dates of manufacture and import; (4) Records documenting the names and a ddresses (including shipment destination address, if different) of all pers ons outside the site of manufacture or import to whom the Company directly sells or transfers the PM N substance, the date of each sale or transfer, and the quantity of the substance sold or tr ansferred on such date; (5) Records documenting the a ddress of all sites of manufacture, impor t, processing, and

use; (6) Records documenting compliance with any applicable manufacturing, processing, use, and distribution restrictions in the Manufacturing, Use, and Distribu tion sections of this Order; (7) Copies of MSDSs required by the Risk Notification section of this Order; (8) Copies of any Transfer documents a nd notices required by the Successor Liability section of this Order, if applicable; and, (9) The Company shall keep a copy of this Order at each of its sites where the PMN substance is manufactured, imported, processed, or used.

(b) Applicability. The provisions of this Recordkeeping Section are applicable only to activities of the Company, if applicable, and not to activities of the Company’s customers.

(c) OMB Control Number. Under the Paperwork Reduction Act and its regulations at 5 CFR Part 1320, particularly 5 CFR 1320.5(b), the Company is not required to respond to this “collection of- 19 - information” unless this Order displays a cu rrently valid control number from the Office of Management and Budget (“OMB”), and EPA so informs the Company. The “collection of information” required in this TSCA §5(e) Consent Order has been approved under currently valid OMB Control Number 2070-0012.

IV. REQUESTS FOR PRE-IN SPECTION INFORMATION (a) EPA’s Request for Information . Pursuant to section 11 of TSCA and 40 CFR 720.122, EPA may occasionally conduct on-site compliance inspec tions of Company facilities and conveyances associated with the PMN substance. To facilit ate such inspections, EPA personnel may contact the Company in advance to request information pertinent to the scheduling and conduct of such inspections. Such requests may be written or oral . The types of information that EPA may request include, but are not limited to, the following: (1) Expected dates and times when the PM N substance will be in production within the subsequent 12 months; (2) Current workshift schedules for workers w ho are involved in activities associated with the PMN substance and may reasonably be exposed to the PMN substance; (3) Current job titles or categories for worker s who are involved in activities associated with the PMN substance and may reasonabl y be exposed to the PMN substance; (4) Existing exposure monitoring data fo r workers who are involved in activities associated with the PMN substance and may reasona bly be exposed to the PMN substance that are collected during the manufacture or processing of the PMN substance; (5) Records required by the Recordkeep ing section of this Order; and/or,- 20 - (6) Any other information reasonably related to determining compliance with this Order or conducting an inspection for that purpose.

(b) Company’s Response . The Company shall respond to such requests within a reasonable period of time, but in no event later than 30 days after receiving EPA’s request. When requested in writing by EPA, the Company’s response shall be in writing. To the extent the information is known to or reasonably ascertainable by the Compa ny at the time of the request, the Company’s response shall demonstrate a good faith effort to provide reasonably accurate and detailed answers to all of EPA’s requests.

(c) Confidential Business Information . Any Confidential Business In formation (“CBI”) that the Company submits to EPA pursuant to paragraph (b ) shall be protected in accordance with §14 of TSCA and 40 CFR Part 2.

V. SUCCESSOR LIABILITY UPON TRANSFER OF CONSENT ORDER (a) Scope. This section sets forth the procedures by which the Co mpany’s rights and obligations under this Order may be transferred when the Company transfers its interests in the PMN substance, including the right to manufacture the PMN substance, to another person outside the Company (the “Successor in Interest”).

(b) Relation of Transfer Date to Notice of Commencement (“NOC”). (1) Before NOC. If the transfer from the Company to the Successor in Interest is effective before EPA receives a notice of commencement of manufacture or import (“NOC”) for the PMN- 21 - substance from the Company pursuant to 40 CFR 720.102, the Successor in Interest must submit a new PMN to EPA and comply fully with Section 5(a)(1) of TSCA and 40 CFR part 720 before commencing manufacture or import of the PMN substance. (2) After NOC. If the transfer from the Company to the Successor in Interest is effective after EPA receives a NOC, the Successo r in Interest shall comply with the terms of this Order and shall not be required to submit a new PMN to EPA.

(c) Definitions. The following definitions apply to this Successor Liability sect ion of the Order: (1) “Successor in Interest” means a pers on outside the Company who has acquired the Company’s full interest in the rights to manufact ure the PMN substance, including all ownership rights and legal liabilities, thr ough a transfer document signed by the Company, as transferor, and the Successor in Interest, as transferee. The te rm excludes persons who acquire less than the full interest of the Company in the PMN substance, such as a licensee who has acquired a limited license to the patent or manuf acturing rights associated with th e PMN substance. A Successor in Interest must be incorporated, licensed, or doing business in the United States in accordance with 40 CFR 720.22(a)(3) and 40 CFR 720.3(z). (2) “Transfer Document” means the legal instru ment(s) used to convey the interests in the PMN substance, including the right to manufacture the PMN substance, from the Company to the Successor in Interest.

(d) Notices. (1) Notice to Successor in Interest. On or before the effectiv e date of the transfer, the Company shall provide to the Successor in Intere st, by registered mail, a copy of the Consent- 22 - Order and the “Notice of Transfer” document whic h is incorporated by reference as Attachment B to this Order. (2) Notice to EPA. Within 10 business days of the e ffective date of the transfer, the Company shall, by registered mail, submit the fu lly executed Notice of Transfer document to: U.S. Environmental Protection Agency, Ne w Chemicals Branch (7405), 1200 Pennsylvania Avenue, N.W., Washington, D.C. 20460. (3) Transfer Document. Copies of the Transfer Docu ment must be maintained by the Successor in Interest at its principal place of busin ess, and at all sites where the PMN substance is manufactured or imported. Copies of the Transf er Document must also be made available for inspection pursuant to Section 11 of TSCA, must state the effectiv e date of transfer, and must contain provisions which expressly transfer liabi lity for the PMN substance under the terms of this Order from the Company to the Successor in Interest.

(e) Liability. (1) The Company shall be liable for complian ce with the requirements of this Order until the effective date of the transfer described above. (2) The Successor in Interest shall be liable for compliance with the requirements of this Order effective as of the date of transfer. (3) Nothing in this section shall be c onstrued to prohibit the Agency from taking enforcement action against the Company after the eff ective date of the transf er for actions taken, or omissions made, during the time in which the Comp any manufactured, processed, used, distributed in commerce, or disposed of the PMN substance pursuant to the terms of this Consent Order.- 23 - (f) Obligations to Submit Test Data under Consent Order. If paragraph (d) of the Testing section of this Consent Order requires th e Company to submit test data to EPA at a specified production volume (“test trigger”), the a ggregate volume of the PMN subs tance manufactured and imported by the Company up to the date of transfer shall c ount towards the test tri gger applicable to the Successor in Interest.

VI. MODIFICATION AND REVO CATION OF CONSENT ORDER The Company may petition EPA at any time, based upon new information on the human health or environmental effects of, or human e xposure to or environmental release of, the PMN substance, to modify or revoke substantive provi sions of this Order. The exposures and risks identified by EPA during its review of the PMN substance and the information EPA determined to be necessary to evaluate those exposures and risks are described in the preamble to this Order. However, in determining whether to amend or re voke this Order, EPA will consider all relevant information available at the time the Agency makes that determination, including, where appropriate, any reassessment of the test data or other information that supports the findings in this Order, an examination of new test data or other information or analysis , and any other relevant information. EPA will issue a modification or revocation if EPA determines that the activities proposed therein will not present an unreasonable risk of injury to health or the environment and will not result in significant or substantial human expos ure or substantial environmental release in the absence of data sufficient to permit a reasoned eval uation of the health or environmental effects of the PMN substance.- 24 - In addition, the Company may petition EPA at a ny time to make other modifications to the language of this Order. EPA will issue such a modification if EPA determines that the modification is useful, appropriate, and consistent with the structur e and intent of this Order as issued.ATTACHMENT A DEFINITIONS Note: The attached Order may not cont ain some of the terms defined below. “Chemical name” means the sc ientific designation of a chem ical substance in accordance with the nomenclature system developed by the Chemical Abstracts Service’s rules of nomenclature, or a name which will clearly iden tify a chemical substance for the purpose of conducting a hazard evaluation. “Chemical protective clothing” means items of clothing that provide a protective barrier to prevent dermal contact with chemical substances of concern. Examples can include, but are not limited to: full body protective clothing, boots, coveralls, gloves, jackets, and pants. “Company” means the person or persons subject to this Order. “Commercial use” means the use of a chemi cal substance or any mixture containing the chemical substance in a commercial enterprise pr oviding saleable goods or a service to consumers (e.g., a commercial dry cleaning estab lishment or painting contractor). “Common name” means any designation or identi fication such as code name, code number, trade name, brand name, or generic chemical name used to identify a chemical substance other than by its chemical name. “Consumer” means a private individual who uses a chemical substance or any product containing the chemical substance in or around a permanent or temporary household or residence, during recreation, or for any personal use or enjoyment. “Consumer product” means a chemical substance th at is directly, or as part of a mixture, sold or made available to consumers for thei r use in or around a permanent or temporary household or residence, in or around a school, or in recreation. “Container” means any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, or the like that contains a hazardous chemical . For purposes of this section, pipes or piping systems, and engines, fuel tanks, or other operating systems in a vehicle, are not considered to be containers. “Contract Manufacturer” means a person, out side the Company, who is authorized to manufacture and import the PMN substance under th e conditions specified in Part II. of this Consent Order and in the Consent Order for Contract Manufacturer. “Final Formulation of the PMN substances” means the formulated dispersion of the PMN substances in the form in which it is sold to customers outside the Comp any or transferred to a different business unit within the Company. The te rm does not include intermediate dilutions of- 2 - the PMN substances that are intended only for use within the Company for further dilution prior to sale. “Identity” means any chemical or common name used to identify a chem ical substance or a mixture containing that substance. “Immediate use.” A chemical substance is for the “immediate use” of a person if it is under the control of, and used only by, the person who tr ansferred it from a labeled container and will only be used by that person within the work shift in which it is transferred from the labeled container. “Initially Isolated Formulations containing the PMN substances” means a common intermediate PMN formulation, as it exists when first produced and isol ated after the polymer manufacturing process, that can be further processed or repack aged at the direction of the Company to result ultimately in one or more final formulations of the PMN substances. “Impervious.” Chemical protective clothing is “impervious” to a chemical substance if the substance causes no chemical or mechanical degradation, permeation, or penetration of the chemical protective clothing under the condi tions of, and the duration of, exposure. “Manufacturing stream” means all reasonably an ticipated transfer, flow, or disposal of a chemical substance, regardless of physical stat e or concentration, throug h all intended operations of manufacture, including the cleaning of equipment. “MSDS” means material safety data sheet, the written listing of data for the chemical substance. “NIOSH” means the National In stitute for Occupational Safety and Health of the U.S. Department of Health and Human Services. “Non-enclosed process” means any equipmen t system (such as an open-top reactor, storage tank, or mixing vessel) in which a chem ical substance is manufactured, processed, or otherwise used where significant direct contact of the bulk chemical substance and the workplace air may occur. “Non-industrial use” means use other than at a facility where chemical substances or mixtures are manufacture d, imported, or processed. “PMN substance” means the chemical substa nce described in the Premanufacture notice submitted by the Company relevant to this Order. “Personal protective equipment” means any ch emical protective clothi ng or device placed on the body to prevent contact wi th, and exposure to, an identif ied chemical substance or substances in the work area. Examples incl ude, but are not limited to, chemical protective- 3 - clothing, aprons, hoods, chemical goggles, face splash shields, or equivalent eye protection, and various types of respirators. Barrier creams are not included in this definition. “Process stream” means all reasonably anticipate d transfer, flow, or disposal of a chemical substance, regardless of physical state or con centration, through all in tended operations of processing, including the cleaning of equipment. “Scientifically invalid” means any significan t departure from the EPA-approved protocol or the Good Laboratory Practice Standards at 40 CFR Part 792 without prior or subsequent Agency approval that prevents a reasoned evaluation of the health or environmental effects of the PMN substance. “Scientifically equivocal data” means da ta which, although deve loped in apparent conformity with the Good Laboratory Practice Standards and EPA-approved protocols, are inconclusive, internally inconsis tent, or otherwise insufficient to permit a reasoned evaluation of the potential risk of injury to human health or the environment of the PMN substance. “Sealed container” means a closed container th at is physically and chemically suitable for long-term containment of the PMN substance, a nd from which there will be no human exposure to, nor environmental release of, the PMN substance during transport and storage. “Use stream” means all reasonabl y anticipated transfer, flow, or disposal of a chemical substance, regardless of physical state or con centration, through all in tended operations of industrial, commercial , or consumer use. “Waters of the United States” has the meaning set forth in 40 CFR 122.2. “Work area” means a room or defined space in a workplace where the PMN substance is manufactured, processed, or used and where employees are present. “Workplace” means an establishment at one geographic location cont aining one or more work areas.ATTACHMENT B NOTICE OF TRANSFER OF TOXIC SUBSTANCES CONTROL ACT SECTION 5(e) CONSENT ORDER

___________________________ _________________ Company (Transferor) PMN Number

1. Transfer of Manufacture Rights. Effective on _______________, the Company did sell or otherwise transfer to ________________________________, (“Successor in Interest”) the rights and liabilities associated with manufacture of th e above-referenced chemical substance, which was the subject of a premanufacture notice (“PMN”) a nd is governed by a Consent Order issued by the U.S. Environmental Protection Agency (“EPA”) under the authority of §5(e) of the Toxic Substances Control Act (“TS CA,” 15 U.S.C. §2604(e)).

2. Assumption of Liability. The Successor in Interest hereby certi fies that, as of the effective date of transfer, all actions or omissions governed by the applicable Consent Order limiting manufacture, processing, use, di stribution in commerce and disposal of the PMN substance, shall be the responsibility of the Successor in Interest. Successor in Interest also certifies that it is incorporated, licensed, or doing business in th e United States in accordance with 40 CFR 720.22(a)(3).

3. Confidential Business Information. The Successor in Interest hereby:
___ reasserts, ___ relinquishes, or ___ modifies all Confidential Business Information (“CBI”) cl aims made by the Company, pursuant to Section 14 of TSCA and 40 CFR part 2, for the PMN substanc e(s). Where “reasserts” or “relinquishes” is indicated, that designation shall be deemed to apply to all such claims. Where “modifies” is indicated, such modification shall be explained in detail in an attachment to this Notice of Transfer. Information which has been previously disclosed to the public (e.g., a chemical identity that was not claimed as CBI by the original su bmitter) would not subsequently be eligible for confidential treatment under this Notice of Transfer.- 1 - TOXIC SUBSTANCES CONTROL ACT SECTION 5(e) CONSENT ORDER NOTICE OF TRANSFER (continued)

___________________________________ _____________________ Company (Transferor) PMN Number

___________________________________ _____________________ Signature of Authori zed Official Date

___________________________________ Printed Name of Authorized Official

___________________________________ Title of Authorized Official

___________________________________ Successor in Interest

___________________________________ _____________________ Signature of Authori zed Official Date

___________________________________ Printed Name of Aut horized Official

___________________________________ Title of Authorized Official

___________________________________ Address

___________________________________ City, State, Zip Code- 2 - TOXIC SUBSTANCES CONTROL ACT SECTION 5(e) CONSENT ORDER NOTICE OF TRANSFER (continued)

___________________________________ Successor’s Technical Contact

___________________________________ Address

___________________________________ City, State, Zip Code

___________________________________ Phone