### Palmer International, Inc. Title: Description of Renewable Polyol
PMN Date of Issue: 11/24/2013 Revision Date: 11/24/2013 Page 1 of 5

11/24/2013 1 Subject Premanufacturing Notice for 1462343

- 28

- 7 Sponsor Palmer International, Inc Date November 2 0 th , 20 13 Comments Palmer is submitting pre

- manufacturing notice for a polymer of cashew

nutshell liquid, formaldehyde, diethanolamine and diisopropanolamine.

(1) Explanation Palmer is submitting a pre

- manufacturing notice to initiate the production of cashew nutshell liquid (CNSL)

, para formaldehyde, diethanolamine and diisopropanolamine polymer. The resulti ng reaction product is a low molecular weight polymer with multiple hydroxyl groups, known in the industry as a polyol or more specifically as a Mannich

polyol

. Such polyols find utility in polyurethane applications where they are reacted with polyisocyan ates. Isocyanate groups react with hydroxyl groups to form urethane linkages for form polymers. P olyurethane s are used applications such as coatings, molded flexible foams, rigid spray applied foam, cast elastomers , 2

- part adhesives and moisture

- cure adh esives

. The Mannich type polyols are advantages in that they contain a tertiary amine which acts as non

- fugitive catalyst for the isocyanate

- alcohol rea ction. The Mannich

- type polyol therefor reacts quickly and requires little additional catal ys ts.

Sh ortly after application the CNSL

- polyol is consumed by chemical reaction with the isocyanates. The CNSL

- polyol becomes part of a fully cured, intractable thermoset.

( 2 ) Foam Formulation

. The intended application for the new grades of CNSL / paraformal dehyde / diethanolamine / diisopropanolamine [ 1462343

- 28

- 7 ] is as a polyol used in the formulation of polyurethane insulating foams. Currently the commercial polyurethane insulating foams utilize nonyl phenol M a nnich reaction products such as [ 940912

- 28

- 7 ] as

a polyol . When approved, the 1462343

- 28

- 7 would allow the replacement of the existing petroleum derived nonyl

- phenol reaction with the renewable cashew

- nutshell

- liquid reaction product

.

The polyurethane insulating foams are created by several reacti on s of isocyanate molecules occurring simultaneously . A 2

- part system is used with reactive isocyanate containing oligomers , foaming agents and flame retardants are in one solution, termed the A

- side. The second solution consists of a blend of oligomeric polyols, surfactants, water (or other blowing agent) and catalysts together called the B

- side. The two A & B components are mixed only during application. Upon mixing, several reaction s take place within seconds forming rigid polymeric foam that fully cures with minutes.

### Palmer International, Inc. Title: Description of Renewable Polyol
PMN Date of Issue: 11/24/2013 Revision Date: 11/24/2013 Page 2 of 5

11/24/2013 2 The isocyanate groups present in the A

- side formula react with water from the B

- side to form urea crosslinks and carbon dioxide gas at the same time

. The urea linkages form a

cross

- linked polymer thermoset network. The CO 2 generated creates gas bubbles which become entrapped making a foamed material. The isocyanate groups also react with OH groups on the oligomeric polyols of the B

- side to form urethane bonds which also build the three

- dimensional polymeric network. The surfactant serves to stabilize the water and polyol mixture during storage and controls the CO 2 bubble size thereby controll ing the foam structure while the polyurethane reactions occur. The polyol molecules contain OH groups that react with the isocyanate from the A

- side and incorporate into the polymer foam and become intractable. The judicious selection of differing ratios of these ingredients can control the polyurethane foam’s flexibility, density , cure time and insulation properties.

Palmer ’ s immediate customer will formulate and blend the new CNSL

- polyol into a B

side portion of a polyurethane foam formula at a single manufacturing site.

Worker Exposure Scenario: A) Totes of CNSL

- polyol are received in shipping and transported by fork truck to warehouse storage or production area. No exposure except in a spill event. B) CNSL

- polyol is loaded into mixing vessels via cam

- lock fitted hoses via a pump. Operators wear PPE including gloves , safety glasses and chemical

resistant apron . Successive ingredients are charge via the same line and pump which is run until dry on the last charge. The same pump is then used for discharging to drums. Again, during drum filling the production operator must wear the same PPE. C) Finished product is sample for quality control by technicians and tested in QC lab. Technicians wear gloves, lab coat and safety glasses.

( 3 ) Foam Application

. The CNSL

- polyol will be formulated into a B

- side mixture as describ ed and then may end up in one of three possible applications: 1) Application #1 is the use of the formulated, 2

- part reactive polyurethane foam in “pour

- in

- place” molded or spray applications. In these industrial manufacturing processes the reactive A and B sides are fed from separate tanks and blended in a mix nozzle. The reacting liquid is either pumped into a mold or spray applied in

house. The spray method is used for cavity filling such as in

- place application of rigid insulation during refrigerator ass embly . The mold method is used for shaped foam articles such as seat cushions. The images below show the type of automated equipment used in these applications

### Palmer International, Inc. Title: Description of Renewable Polyol
PMN Date of Issue: 11/24/2013 Revision Date: 11/24/2013 Page 3 of 5

11/24/2013 3 Mold filling operation Enclosed and automated Separate A & B

- side tanks and metering
pumps.
Worker Exposu r e Scenario: D) The foam customer receives the formulated B

- side containing the CNSL

- polyol

. All containers are sealed. The o nly risk is a spill event. E) The production operator loads the formulated B

- side c ontaining the CNSL

polyol into a holding tank. The operator must wear safety googles, apron or tyvek suit and appropriate gloves. F) During use the CNSL

- polyol containing formulation is metered into a mix head and pumped into molds or cavities. Within minut es the chemical reaction consumes all the polyol. Any workers in contact with the curing foam must wear proper PPE including air

- purifying respirator, safety glasses and gloves.

2) Application #2 is the use of the formulated, 2

- part reactive polyurethane fo am in professional contractor spray applications. The foam is used in residential and commercial construction to improve insulation and reduce energy use for heating and air conditioning. This product line is not being sold to do

- it

- yourself homeowners. In accordance with the technical data sheet, a licensed dealer is instructed to store both the A

- Side and the B

- Side drums out of direct sunlight, and the stored chemicals should be kept at a temperature of between 60o F and 90 oF

. In case of a chemical spill licensed dealers are instructed to call both the formulator and Chemtrec for further instructions. The A & B side are stored separately and pumped via closed system to a mixer and spray head. Using high

- pressure spray guns t he reacting foam is sprayed in between the joists of walls and cures in place to a rigid foam

. To ensure safety during this process, the dealers follow strict safety procedures which require the use of personal protection equipment including (respirator, gloves, tyvek suit, goggles). The dealers are licensed and trained in the use of the equipment and chemicals.

### Palmer International, Inc. Title: Description of Renewable Polyol
PMN Date of Issue: 11/24/2013 Revision Date: 11/24/2013 Page 4 of 5

11/24/2013 4 During application the A

- Side chemically reacts with the B

- Side to form the finished product

- rigid polyurethane spray foam. During the A

- Side/B

- Side interaction that forms the cured thermoset insulation layer, the CNSL

- polyol becomes incorporated into the polyurethane’s carbon backbone. The incorporation of the polyol into the carbon backbone prevents leaching of the chemical into the

surro unding environment. Some excess foam may be created during spray application since the material expands upon curing. After curing, this excess is trimmed and transported to the landfill for its ultimate disposal. General guidelines for safe sprayfoam op erations can be found at: http://www.sprayfoam.org/index.php?page_id=220

Worker Exposure Scenario: G) The foam customer receives the formulated B

- side containing the CNSL

- polyol. A ll containers are sealed. The only risk is a spill event. H) The production operator loads the formulated B

- side containing the CNSL

polyol into a holding tank or attaches pump hose direct to the drum

. Operator wears PPE of safety goggles, gloves and tyvek suit. I) During use the CNSL

- polyol containing formulation is metered into a mix head and pumped into to a spray nozzle. The mixed and reacting A & B sides are sprayed on walls . Within minutes the chemical react ion consumes all the polyol. All workers i n vicinity during the spraying of the curing foam must wear proper P PE including safety glasses, gloves and respirator

. The respirator is mandatory to avoid any inhalation of liquid or aerosol spray. Note: the primary hazard is the A

- side containing isoc yanates.

Application #3 is the use of formulated 2

- part polyurethane system to make foam boards. This application is similar to #1 in that it is done in a controlled industrial manufacturing setting. The difference is that foam board and laminates are m anufactured continuously on conveyer systems with the 2 reactive sides being mixed and poured at one end and expanding and curing down the length of the moving conveyer belt.

Worker Exposure Scenario: J) The foam customer receives the formulated B

- side containing the CNSL

- polyol. All containers are sealed. The only risk is a spill event. K) The production operator loads th e formulated B

- side containing the CNSL

polyol into a holding tank . The operator must wear safety googles, apron or tyvek suit and appropriate gloves when pumping the material into a holding tank

. L) During use the CNSL

- polyol containing formulation is meter ed into a mix head and pumped onto a moving conveyor belt . Within minutes the chemical

### Palmer International, Inc. Title: Description of Renewable Polyol
PMN Date of Issue: 11/24/2013 Revision Date: 11/24/2013 Page 5 of 5

11/24/2013 5 reaction consumes all the polyol. Any workers in contact with the curing foam must wear proper PPE including safety glasses and gloves.

EPA Contact Log
11 /2 4 /20 13 Filed PMN electronically