## Cover Letter

Document Control Officer Office of Pollution Prevention and Toxic Substances, 7407M U.S. Environmental Protection Agency 1200 Pennsylvania Avenue NW Washington, DC 20460 RE: The Goodyear Tire & Rubber Company Premanufacture Notice (PMN) Application (TS Number 50GT11) Enclosed is a PMN application in reference to the subject. We would appreciate your timely action, so that production of the new chemical substance may be expedited. If you have questions, please contact Robert Woloszynek at 330-796-7812, or Marty Trembly at 330-796-1837. Thank you. Sincerely, David K Woodyard Manager, Global Envronmental Sustainability Phone 330-796-9353 E-mail: dkwoodyard@goodyear.com

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### BCS464 NDXS121026809522074 50GT11

X X

X Page 2 SANITIZED SUBMISSION

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Page 3 SANITIZED SUBMISSIONDavid Woodyard Manager, Global Env Sustainability The Goodyear Tire & Rubber Company 1144 East Market Street Akron OH 44316 dkwoodyard@goodyear.com

Robert Woloszynek Lead Engineer The Goodyear Tire & Rubber Company 1485 East Archwood Avenue Akron OH 44306 robert_woloszynek@goodyear.com 330-796-7812



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## X

Neodymium, butadiene iso-Bu neodecanoate complexes 1386395-00-1 

## X 314782 CAS-IES processing results 080612.pdf 

### Unspecified See Attachment 001 (Reaction scheme Stage 1 catalyst.pdf)

Reaction scheme Stage 1 catalyst.pdf Page 5 SANITIZED SUBMISSIONXXX

XXX

XXX 

## X

X

X

Page 6 SANITIZED SUBMISSIONPage 7 SANITIZED SUBMISSIONPage 8 SANITIZED SUBMISSIONNot applicable

XXX Neodymium Ziegler-Natta preformed Stage 1 catalyst 

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### XXX XXX 

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Precursor to polymerization catalyst 100 3.5 100 0 0 0

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## X XXX XXX XXX 

## X X

XXX 

## X The Goodyear Tire & Rubber Company 11357 Interstate 10 Beaumont Jefferson TX 77705

Page 11 SANITIZED SUBMISSIONSee Attachment 002 (Catalyst Preparation Batch Process diagram SANITIZED.pdf)

Catalyst Preparation Batch Process diagram SANITIZED.pdf Page 12 SANITIZED SUBMISSIONTank to tank transfer Safety glasses, gloves, flame-retardant clothing, hard hat, safety shoes, hearing protection Liquid - 2.5- 3.5% 1 2 50 Sampling See continuation page. id: <P9SA2(3)C1R2> Liquid - 2.5- 3.5% 1 0.25 50 Maintenance See continuation page. id: <P9SA2(3)C1R3> Liquid - <0.1% 2 2 2 Equipment cleaning See continuation page. id: <P9SA2(3)C1R4> Solid - <0.1% 2 12 3

Page 13 SANITIZED SUBMISSIONP9SA2(3)C1R2 Part II, Section A, 2.(3) Prot. Equipment, etc., Row 2

Safety glasses, gloves, flame-retardant clothing, hard hat, safety shoes, hearing protection, face shield, protective suit, and respirator if needed

Page 14 SANITIZED SUBMISSIONP9SA2(3)C1R3 Part II, Section A, 2.(3) Prot. Equipment, etc., Row 3

Safety glasses, gloves, flame-retardant clothing, hard hat, safety shoes, hearing protection, face shield, protective suit, and respirator if needed

Page 15 SANITIZED SUBMISSIONP9SA2(3)C1R4 Part II, Section A, 2.(3) Prot. Equipment, etc., Row 4

Safety glasses, gloves, flame-retardant clothing, hard hat, safety shoes, hearing protection, face shield, protective suit

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Page 18 SANITIZED SUBMISSIONPage 19 SANITIZED SUBMISSIONThe entire process is closed and there will be no exposure to the Stage 1 catalyst during normal make-up conditions. The initial reactants and

the hexane carrier are charged to the Stage 1 reactor. Vents from the Stage 1 reactor are passed through a knockout pot to capture any liquid, then to a vent scrubbing system. No Stage 1 catalyst is expected to be discharged through the normal process vents due to the low volatility of this material. The only way Stage 1 catalyst could get into the vent system would be liquid overfilling of the Stage 1 reactor. Instrumentation and feed cut-offs will be incorporated into the equipment design to minimize the risk of tank overfill. Any Stage 1 catalyst that reaches the vent system would be contained and neutralized in the vent scrubber or start-up steam stripper. Stage 1 catalyst is transferred to the Stage 2 catalyst reactor. No exposure will occur during this step under normal operating conditions. The only potentials for exposure or release of the Stage 1 catalyst would be a leak in the Stage 1 reactor / transfer piping, or an emergency relieving event. Both of these events could result in a release of the Stage 1 catalyst to the containment area around the Stage 1 reactor. The Stage 1 catalyst has a very low volatility, so none will be discharged to the air. The catalyst is unstable in air because the allyl neodymium complex reacts with oxygen and water in air. As a result of this reaction, any released Stage 1 catalyst will quickly react with oxygen and water in the air to most probably form metal oxides, hydroxides, and/or alkoxides. If a release were to occur, the operation would be shut down remotely and the released material cleaned up using appropriate tools and receptacles, and workers will be fitted with personal protective equipment (protective suits, respirators, etc.). Cleaned up material will be disposed in accordance with all applicable environmental regulations.

Page 20 SANITIZED SUBMISSION001 Reaction scheme showing formulation of Stage 1

catalyst Reaction scheme Stage 1 catalyst.pdf Pt.I, Sec.B, 1e. 1 002 PFD Catalyst Preparation Batch Process diagram SANITIZED.pdf Pt.2, Sec.A, 1d. 0 003 CAS-IES processing results CAS-IES processing results 080612.pdf Pt.I, Sec.B, 1c. 2 004 Sanitized spectra for Nd catalyst Stage 1 and mixed hexanes Sanitized version of spectra for Nd Catalyst Stage 1.pdf 2

Page 21 SANITIZED SUBMISSION0.67 - 0.70 Estimate

69 Estimate 1 XXX XXX 

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## ATTACHMENT HEADER SHEET Attachment Number 001 Attachment Name Reaction scheme showing formulation of Stage 1 catalyst 

## Associated PMN Section Number

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

## Report Number NDXS121026809522074

## ATTACHMENT HEADER SHEET Attachment Number 002 Attachment Name PFD 

## Associated PMN Section Number

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

## Report Number NDXS121026809522074

## ATTACHMENT HEADER SHEET Attachment Number 003 Attachment Name CAS-IES processing results 

## Associated PMN Section Number

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

## Report Number NDXS121026809522074

## ATTACHMENT HEADER SHEET Attachment Number 004 Attachment Name Sanitized spectra for Nd catalyst Stage 1 and mixed hexanes 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number NDXS121026809522074