### Cover Letter

Cytec Industries Inc. Product Stewardship & Regulatory Affairs 1937 West Main Street Stamford, CT 06904 March 25, 2011 U.S. Environmental Protection Agency Office of Pollution Prevention & Toxics Confidential Business Information Center (CBIC) EPA East Building, room 6428 1201 Constitution Avenue Washington, D.C. 20004-3302 Dear Sir/Madam: ATTN: SUSTAINABLE FUTURES/EXPEDITED REVIEW REFERENCE: PMN for TS-62K64O On behalf of Cytec Industries Inc., I am pleased to re-submit a premanufacturing notice under Section 5 of the Toxic Substances Control Act using eTSCA Client. The PMN number for the previously submitted PMN was P10-541. This PMN is submitted for Expedited Review under the Sustainable Futures Program. The EPA has determined that Cytec Industries Inc. is eligible for simultaneous submission of Test Marketing Exemption Applications (TMEAs) and PMNs under the Sustainable Futures Initiative. Cytec Industries Inc. has developed this new chemical substance using the pollution prevention hierarchy as articulated in the Pollution Prevention Act of 1990 and EPA’s Pollution Prevention Strategy (56 FR 7849, February 26, 1991). In this strategy, the Agency ranks source reduction as the first preference in methods of controlling chemical risks. Cytec Industries Inc. has addressed source reduction through the application of SAR and risk screening methodologies that comprise EPA’s Pollution Prevention (P2) Framework. The P2 Framework is designed to evaluate potential chemical risk or hazards based on an analysis of chemical structure and other factors. This represents a unique approach to product development in the industrial chemical sector and constitutes a significant departure from standard practice in new product development. Standard practice typically does not include P2, SAR, and other risk screening approaches in early product development. This approach to product development Page 1 SANITIZED SUBMISSIONmay result in the selection of a material to be commercialized that is different from a material which might have

been selected based on more traditional approaches to product development (ie. cost, efficacy, yield, performance, etc.). The new chemical substance is intended for use as a binder resin for waterborne OEM surfaces. Cytec Industries Inc. plans to test market the new chemical that was developed with this unique P2-based product development paradigm to ensure acceptability of the product in the marketplace. Import volumes will be 1850 kg/45-day test period. The PMN and fee identification number is TS-62K64O . The PMN registration fee with the identifying TS-number was paid by credit card using Pay.Gov. If you have any questions, please contact me at (203) 321-2259. Regards, Daniel Liebowitz Regulatory Compliance Manager, Americas

Page 2 SANITIZED SUBMISSION251DBEPR RESY110325186502367 62K64O

X X X X X

X Page 3 SANITIZED SUBMISSIONX

Page 4 SANITIZED SUBMISSIONPatricia Vernon Senior Manager, Global Product Regulatory Compliance Cytec Industries Inc. 5 Garret Mountain Plaza Woodland Park NJ 07424 patricia.vernon.@cytec.com

Daniel Liebowitz Regulatory Compliance Manager, Americas Cytec Industries Inc. 1937 West Main Street Stamford CT 06904 daniel.liebowitz@cytec.com 203-321-2259 

### X X X XXX 

### X Page 5 SANITIZED SUBMISSIONPage 6 SANITIZED SUBMISSIONPage 7 SANITIZED SUBMISSION

### X

XXX XXX XXX

XXX XXX X XXX X XXX X XXX XXX X XXX X XXX X XXX XXX X XXX X XXX X XXX XXX X XXX X XXX X XXX XXX X XXX X XXX X 

### X Page 8 SANITIZED SUBMISSION

### (1)

XXX XXX X XXX X XXX X XXX XXX X XXX X XXX X XXX XXX X XXX X XXX X XXX XXX X XXX X XXX X XXX XXX X XXX X XXX X 

### X Page 9 SANITIZED SUBMISSION

### (2)

XXX XXX X XXX X XXX X

Page 10 SANITIZED SUBMISSION

### X 67216 Sanitized CAS IES Report.pdf 

### X XXX

XXX See Attachment 002 (Sanitized Structure.pdf)

Sanitized Structure.pdf Page 11 SANITIZED SUBMISSIONNone

XXX Epoxy modified alkyd resin, partially neutralized 

### X

None
Page 12 SANITIZED SUBMISSIONXXX XXX 

### X

X Coating Resin XXX X XXX X XXX X XXX XXX XXX XXX X

Page 13 SANITIZED SUBMISSIONImport Only-This section is not applicable

Page 14 SANITIZED SUBMISSIONPage 15 SANITIZED SUBMISSIONPage 16 SANITIZED SUBMISSIONPage 17 SANITIZED SUBMISSION5

See Attachment 003 (Sanitized Roll Coating Operation Description.pdf)

Sanitized Roll Coating Operation Description.pdf The PMN substance will be imported in formulated coatings. No further processing of the PMN substance will take place. The formulated coatings wil be applied to flat steel products by roller coating. These facilities are equipped with a closed varnish circulation system. There are no discharges to water from these roller coating operations. All drums are gravity drained. Empty drums are sent off site for reconditioning. Equipment cleaning residues are sent for off-site incineration. There are no discharge to water from drum or equipment cleaning operations.

Page 18 SANITIZED SUBMISSIONNone expected

XXX XXX XXX XXX XXX XXX XXX

XXX XXX XXX XXX

X X X

X X

Page 19 SANITIZED SUBMISSIONPage 20 SANITIZED SUBMISSION001 Sanitized CAS IES Report Sanitized CAS IES Report.pdf Pt.I, Sec.B, 2c. 1 002 Sanitized Structural Representation Sanitized Structure.pdf Pt.I, Sec.B, 2e. 1 003 Sanitized Roller Coating Operation Description Sanitized Roll Coating Operation Description.pdf Pt.2, Sec.B, 1a. 1 004 US MSDS US MSDS.pdf 7 005 Sanitized SF Assessment Sanitized SF Assessment.pdf 6

Page 21 SANITIZED SUBMISSION

### X Measured <0.1 Estimate 20 1.05 Estimate
miscible in all proportions Estimate ~100 Estimate

Page 22 SANITIZED SUBMISSION

### ATTACHMENT HEADER SHEET Attachment Number 001 Attachment Name Sanitized CAS IES Report 

### Associated PMN Section Number

Pt.I, Sec.B, 2c. Does not contain CBI 

### Report Number RESY110325186502367

### ATTACHMENT HEADER SHEET Attachment Number 002 Attachment Name Sanitized Structural Representation 

### Associated PMN Section Number

Pt.I, Sec.B, 2e. Does not contain CBI 

### Report Number RESY110325186502367

### ATTACHMENT HEADER SHEET Attachment Number 003 Attachment Name Sanitized Roller Coating Operation Description 

### Associated PMN Section Number

Pt.2, Sec.B, 1a. Does not contain CBI 

### Report Number RESY110325186502367

### ATTACHMENT HEADER SHEET Attachment Number 004 Attachment Name US MSDS 

### Associated PMN Section Number

N/A Does not contain CBI 

### Report Number RESY110325186502367

### ATTACHMENT HEADER SHEET Attachment Number 005 Attachment Name Sanitized SF Assessment 

### Associated PMN Section Number

N/A Does not contain CBI 

### Report Number RESY110325186502367