Cover Letter

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Re:	 Attached PMN Submission; TS-AG1105

Dear Sir or Madam:

Enclosed is the premanufacture notice (PMN) referenced above. The user fee for this PMN has been submitted

separately, as specified under 40 C.F.R. § 700.45.

If you have any questions regarding this submission, please contact me as soon as possible, at 202-624-2755. 

Sincerely,

Warren U. Lehrenbaum

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SANITIZED SUBMISSION

PMN Page 2

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

. 

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

with CD or paper submission.

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

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

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

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

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

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

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

Premanufacture Notification Rule. 

Additional Certification Statements: 

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

certification statement that applies: 

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

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

 accordance with 40 CFR 700.45(b), or

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

 accordance with 40 CFR 700.45(b).

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

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

the following certification statements: 

 The manufacturer submitting this notice intends to manufacture or import the new chemical substance for commercial purposes, 

 other than in small quantities solely for research and development, under the terms of 40 CFR 723.50. 

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

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

 If this application is for an LVE in accordance with 40 CFR 723.50(c)(1), the manufacturer intends to commence manufacture of 

 the exempted substance for commercial purposes within 1 year of the date of the expiration of the 30 day review period. 

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

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

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

Confidential 

Signature and title of 

Authorized Official (Original 

Signature Required) 

Date 

 

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

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

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

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

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

PMN2011P2

X

X

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SANITIZED SUBMISSION


PMN Page 4a

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

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

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

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

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

e. (2) Describe the nature of the reaction or process.

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

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

 Enter Attachment filename for Part I, Section B, 1. e. (3) 

PMN2011P4A

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SANITIZED SUBMISSION




PMN Page 7

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

Part I -- GENERAL INFORMATION -- Continued

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

The information on this page refers to consolidated chemical number(s): 1 2 3 4 5 6 

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

1. Production volume -- Estimate the maximum production volume during the first 12 months of production. Also estimate the maximum production 

volume for any consecutive 12-month period during the first three years of production. Estimates should be on 100% new chemical substance basis. 

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

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

Maximum first 12-month production (kg/yr) 

(100% new chemical substance basis) 

Maximum 12-month production (kg/yr) 

(100% new chemical substance basis) Confidential Binding Option Mark (X)

 

Enter Attachment filename for Part I, Section C, 1. CBI 

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

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

confidential. 

a. (1) --Describe each intended category of use of the new chemical substance by function and application. 

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

(3) --Indicate your willingness to have the information provided in column (1) binding. 

(4) --Estimate the percent of total production for the first three years devoted to each category of use. 

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

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

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

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

(8) --Indicate % of product volume expected for the listed “use” sectors. Mark more than one box if appropriate. Mark (X) to indicate your 

willingness to have the use type provided in (8) binding. 

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

% of substance expected per use 

(8) Category of use (1) 

(by function and application i.e. a dispersive dye for 

finishing polyester fibers) 

CBI 

(2) 

Binding 

Option 

Mark (X)

(3) 

Prod 

uction 

% 

(4) 

CBI 

(5) 

% in 

Formulation 

(6) 

CBI 

(7) 

Sitelimited Consumer* Industrial Commercial 

Binding 

Option 

CBI 

(9) 

 

 

 

 

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

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

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

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

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

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

 Enter Attachment filename for Part I, Section C, 2. b. CBI 

3. Hazard Information -- Include in the notice a copy of reasonable facsimile of any hazard warning statement, label, material safety 

data sheet, or other information which will be provided to any person who is reasonably likely to be exposed to this substance 

regarding protective equipment or practices for the safe handing, transport, use, or disposal of the new substance. List in part III 

hazard information you include. 

Binding Option 

Mark (X) 

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

PMN2011P7

XXX XXX X

X

Water and oil repellant

XXX X XXX X XXX X XXX XXX XXX XXX X

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SANITIZED SUBMISSION

PMN Page 8a

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

Confidential 

Diagram of the major unit operation steps. 

 Enter Attachment filename for Part II, Section A, 1. d. 

PMN2011P8A

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SANITIZED SUBMISSION




PMN Page 11

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

 

OPTIONAL POLLUTION PREVENTION INFORMATION

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

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

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

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

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

procedure modification, product reformulation, and/or raw materials substitution. Recycling refers to the reclamation of useful chemical components 

from wastes that would otherwise be treated or released as air emissions or water discharges, or land disposal. Quantitative or qualitative 

descriptions of pollution prevention, source reduction and recycling should emphasize potential risk reduction in addition to compliance with existing 

regulatory requirements. The EPA is interested in the information to assess overall net reductions in toxicity or environmental releases and 

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

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

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

Describe the expected net benefits, such as 

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

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

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

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

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

health or the environment.

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

and Pollution Prevention Guidance manual for guidance and examples.

 Enter Attachment filename for Pollution Prevention Page 11.

PMN2011P11

************************************************************ CONFIDENTIAL -- CBI

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It is anticipated that the PMN substance will replace conventional telomer-based perfluorinated polymeric compounds currently used in textile

treatments, which may contain C-8, C-10, C-12 or higher chain length components. In contrast, the PMN substance does not contain any

polymeric materials or impurities with chain lengths greater than six carbons and, as a result, presents a more favorable risk profile than

conventionally marketed telomer-based products, by eliminating any potential for environmental release of perfluorinated carboxylic acids of chain

lengths greater than C-6.

************************************************************ CONFIDENTIAL -- CBI

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PMN Page 12

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

Part III -- LIST OF ATTACHMENTS

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

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

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

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

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

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

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

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

# Number 

of Pages 

Associated 

PMN Section 

Number 

CBI 

 

 

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

Attachment Name Attachment Filename 

PMN2011P12

001 Structural Diagram Structural Diagram -

Sanitized.docx.pdf

1 Pt.I, Sec.B, 2e.

002 IES Report IES Report--.pdf 1 Pt.I, Sec.B, 2c.

003 Manufacturing Process Manufacturing Process

Description - Sanitized.pdf

1

004 Reverse Mutation Test Reverse Mutation-Sanitized.pdf 34

005 Test of Schematic Flow Test Schematic Flow -

sanitized.pdf

54

006 MSDS MSDS-Sanitized.pdf 5

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PMN2011P13

Page 20

SANITIZED SUBMISSION
ATTACHMENT HEADER SHEET

Attachment Number 001

Attachment Name

Structural Diagram

Associated PMN Section Number

Pt.I, Sec.B, 2e.

Does not contain CBI

Report Number

AG-R110923791952103
ATTACHMENT HEADER SHEET

Attachment Number 002

Attachment Name

IES Report

Associated PMN Section Number

Pt.I, Sec.B, 2c.

Does not contain CBI

Report Number

AG-R110923791952103
ATTACHMENT HEADER SHEET

Attachment Number 003

Attachment Name

Manufacturing Process

Associated PMN Section Number

N/A

Does not contain CBI

Report Number

AG-R110923791952103
ATTACHMENT HEADER SHEET

Attachment Number 004

Attachment Name

Reverse Mutation Test

Associated PMN Section Number

N/A

Does not contain CBI

Report Number

AG-R110923791952103
ATTACHMENT HEADER SHEET

Attachment Number 005

Attachment Name

Test of Schematic Flow

Associated PMN Section Number

N/A

Does not contain CBI

Report Number

AG-R110923791952103
ATTACHMENT HEADER SHEET

Attachment Number 006

Attachment Name

MSDS

Associated PMN Section Number

N/A

Does not contain CBI

Report Number

AG-R110923791952103