## Cover Letter

Cover letter regarding PMN TS SK22BZ						11 July 2013 Good afternoon: I am submitting a PMN that I thought was originally submitted on 29 March 2013. On that date, I submitted the PMN and received an e-mail confirming receipt; a copy of the text of that e-mail is pasted below: "The Original document for CDX Transaction ID _2bc712ba-5844-497f-9c37-5846375ae519 was submitted to eTSCA on 03/29/2013 at 10:08:51 EDT Document Id: _a1199fe5-cdc1-4503-bb45-9ca908ef1489 Document Name: AlPhos_finalized.pmn_tsca" I understood this to mean that my PMN and attachments had been submitted and was proceeding through the review process. In mid-June, I checked with our technical consultant, who asked me for the PMN number that I should have received. I searched, but realized that notification of the PMN number was never received, so we began investigating the issue. We now understand that our document failed in some way during the submission process and, although we have already waited more than 90-days, our new chemical has yet to be reviewed. Note that we never received any notification that the document failed to be delivered to EPA at any step of the process and since EPA does not allow third parties (who are experts on new chemical submissions) to be the primary point of contact, I had no way of knowing that I should have received more information. After discussing the issue with EPA, we understand that we should have been contacted by one of EPA’s contractors who are meant to monitor the process and notify submitters of such issues. Due to these problems, which seem to be completely beyond our control, we respectfully request an expedited review of the subject PMN. Please call either Beth Bosley or David Diefenthal with any questions. Best regards, David Diefenthal		Beth Bosley 615.519.3732		724.612.5766

Page 1 SANITIZED SUBMISSION

### 000723 ALPH130711979972581 SK22BZ

X

X

X Page 2 SANITIZED SUBMISSION

### X



## X

Page 3 SANITIZED SUBMISSIONDavid Diefenthal President JJI Technologies, LLC 1350 Bacon Road Painesville OH 44077 dief@bellsouth.net

Beth Bosley President Boron Specialties 1350 Bacon Road Painesville OH 44077 44077 724-612-5766



## X

X X X XXX

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## X

XXX 

## X

XXX 

## X 321142 IES_Report_DP-111 SANITIZED.jpg 

### XXX 

## X See Attachment 001 (Structure for PMN_SANITIZED.pdf)

Structure for PMN_SANITIZED.pdf Page 5 SANITIZED SUBMISSIONPage 6 SANITIZED SUBMISSIONPage 7 SANITIZED SUBMISSIONPage 8 SANITIZED SUBMISSIONXXX

DP-111

Aluminum phosphate 

## X Water 7732-18-5 0.1 XXX XXX XXX 

### X

XXX XXX 

### X

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### XXX XXX 

## X

X Flame retardant for industrial plastics 100 XXX 

### X 10 0 90 0

Page 10 SANITIZED SUBMISSION

## X

XXX XXX XXX 

## X 1

XXX 

## X JJI Technologies 1350 Bacon Road Painesville Lake County OH 44077

Page 11 SANITIZED SUBMISSIONSee Attachment 002 (PFD_PMN_DP-111_SANITIZED.pdf)

PFD_PMN_DP-111_SANITIZED.pdf Page 12 SANITIZED SUBMISSIONA - packaging product

from dryer Local exhaust ventilation Respirator Tyvek suit Nitrile gloves Solid, 100% 1 1 190

Page 13 SANITIZED SUBMISSION

## X No water releases expected

1 0.2

kg/batch 0.8

kg/batch Fugitive Air Dust collector 0.1 kg/batch

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### XXX 

## X

See Attachment 003 (USE_PFD_PMN_DP-111_SANITIZED.pdf)

USE_PFD_PMN_DP-111_SANITIZED.pdf XXX 

## X

Page 15 SANITIZED SUBMISSIONP10SB1(a)(4)1 Part II, Section B, 1(a)(4). Operation Site Locations

XXX

Page 16 SANITIZED SUBMISSIONNone known

A 10 1 200 XXX XXX XXX

1 0.2 kg/batch 0.8 kg/batch 0.2 kg/batch estimated released as a fugitive air emission 0.8 kg/batch estimated released into air handling equipment, with product captured and (likely) disposed via offsite incineration. 

### X

Page 17 SANITIZED SUBMISSIONThe flame retardant described in this PMN provides an alternative to toxic brominated aromatic, antimony-based, and red phosphorous materials

for use in the electrical and electronics industry. DP-111 provides excellent mechanical properties while enhancing fire retardancy, especially in polyamides and polyesters. Based on like structures, DP-111 is expected to exhibit low toxicity and produces no discernible toxic byproducts during processing and use. In addition, the production methodology for DP-111 produces very few byproducts and makes use of direct recycle of solvents and wash liquors.

Page 18 SANITIZED SUBMISSION001 Structure_DP-111_SANITIZED Structure for PMN_SANITIZED.pdf Pt.I, Sec.B, 1e. 1 002 Manufacturing process flow diagram SANITIZED PFD_PMN_DP111_SANITIZED.pdf Pt.2, Sec.A, 1d. 1 003 Use Process Flow Diagram DP-111 SANITIZED USE_PFD_PMN_DP111_SANITIZED.pdf Pt.2, Sec.B, 1a. 1 004 IES Report DP-111 SANITIZED IES_Report_DP-111 SANITIZED.jpg Pt.I, Sec.B, 1c. 1 005 DP-111 Infrared spectrum SANITIZED DP-111 FTIR SANITIZED.jpg 1 006 DP-111 Thermogravimetric analysis spectrum SANITIZED DP-111 TGA SANITIZED.jpg 1 007 DP-111 MSDS DP-111 MSDS 7-30-12r7.pdf 5 008 Particle size distribution Particle_size.pdf Worksheet: Particle size distribution 1

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## X Measured
0.673 Measured
1.6 Measured 25 DMSO <2 Measured 25 320 (dec) Measured

XXX XXX 

## X

3.5 Measured 10%
MIE - 1.2 mJ Measured 

## X 008 ave = 10-15 microns Measured

Page 20 SANITIZED SUBMISSION

## ATTACHMENT HEADER SHEET Attachment Number 001 Attachment Name Structure_DP-111_SANITIZED 

## Associated PMN Section Number

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

## Report Number ALPH130711979972581

## ATTACHMENT HEADER SHEET Attachment Number 002 Attachment Name Manufacturing process flow diagram SANITIZED 

## Associated PMN Section Number

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

## Report Number ALPH130711979972581

## ATTACHMENT HEADER SHEET Attachment Number 003 Attachment Name Use Process Flow Diagram DP-111 SANITIZED 

## Associated PMN Section Number

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

## Report Number ALPH130711979972581

## ATTACHMENT HEADER SHEET Attachment Number 004 Attachment Name IES Report DP-111 SANITIZED 

## Associated PMN Section Number

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

## Report Number ALPH130711979972581

## ATTACHMENT HEADER SHEET Attachment Number 005 Attachment Name DP-111 Infrared spectrum SANITIZED 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number ALPH130711979972581

## ATTACHMENT HEADER SHEET Attachment Number 006 Attachment Name DP-111 Thermogravimetric analysis spectrum SANITIZED 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number ALPH130711979972581

## ATTACHMENT HEADER SHEET Attachment Number 007 Attachment Name DP-111 MSDS 

## Associated PMN Section Number

N/A Does not contain CBI 

## Report Number ALPH130711979972581

## ATTACHMENT HEADER SHEET Attachment Number 008 Attachment Name Particle size distribution 

## Associated PMN Section Number Worksheet: Particle size distribution Does not contain CBI 

## Report Number ALPH130711979972581