EPA Support Form 

Support Form Report Number Mark (X) if anything is CBI

I. ORIGINAL NOTICE SUBMISSION IDENTIFICATION 

Report Number TS 

Number 

Case 

Number 

Original Submission Date 

Original Submission Media Type 

II. ORIGINAL NOTICE SUBMITTER IDENTIFICATION CBI 

Authorized Official 

Name 

Company Name

Mailing Address 

(Number & Street) 

City State Postal Code 

e-mail Telephone 

(include area code) 

III. CURRENT SUPPORT DOCUMENT IDENTIFICATION INFORMATION CBI 

Mailing Address 

(Number & Street) 

City State Postal Code 

e-mail Telephone 

(include area code) 

IV. TYPE OF SUPPORT (Check One) 

Letter of Support (Mark the certification statement checkbox below)

Withdrawal Request 

Other Correspondence 

TEST DATA (Health/Eco/Fate) 

Amendment (Changes made to PMN pages 1-13, MSDS or Physical/Chemical 

properties) 

Check if requested by EPA/ contractor 

EPA person/ contractor 

Position

(first) (last)

Name 

Position Company Name

(first) (last)

Submitter Signature

Province Country

All information provided in this Letter of Support is complete and truthful

as of the date of the submission.

Form Approved. O.M.B. No. 2070-0173.

PNCX111121539532664 X

B127Y1

Nov 21, 2011

CDX

X

Tracey Malone

Product Regulatory Specialist BASF Corporation

prcoe@basf.com 864-266-5552

1520 Old Stage Road

Mauldin SC 29662

X

Tracey Malone

Product Regulatory Specialist BASF Corporation

prcoe@basf.com 864-266-5552

1520 Old Stage Road

Mauldin SC 29662

US

X

CBI SUBMISSION

SUP2012P1
V. TEXT / DESCRIPTION OF CHANGES CBI 

Insert Attachment 

X

{November 21, 2011

CONFIDENTIAL

Ms. Rose A. Allison

Office of Pollution Prevention & Toxics (New Chemicals Program)

U.S. Environmental Protection Agency

EPA East Building, Room 4133

1201 Constitution Avenue, NW

Washington, DC 20004-3302

Dear Ms. Allison:

Subject: Testing required for Pre-manufacturing Notice of Perfluorinated Polymer

Attached you will find the chemical identity (CAS IES order), structure and GPC analysis for the substance which BASF Corporation intends

to submit a PMN. Previously, BASF Corporation used the polymer exemption rule for TSCA compliance of this substance, CASRN 459415-

06-6. Use of this exemption will no longer be acceptable after January 27, 2012, due to the Final Rule that was published in the Federal

Register on January 27, 2010. When we met with you during our previous meeting on April 6, 2011, you stated that BASF could submit a pre

-notice consultation to your attention to determine what testing would need to be completed and submitted with our PMN for this new

substance. You would review the chemistry of our new substance, where the C8 is being replaced with C6 material, and confirm what, if any,

additional testing needed to be completed and submitted with our PMN.

BASF appreciates your input and will contact you before 12/15/11, if we have not received a response by then. I can be reached at (864) 266

-5552, if you have any questions.

					Sincerely,

					BASF CORPORATION

					Tracey Malone

					Product Regulatory Center of Expertise Team Member

Enc:

Chemical identities and structures}

CBI SUBMISSION

SUP2012P2
LIST OF ATTACHMENTS

# Number 

of Pages 

Associated 

Section 

Number 

CBI 

 

 

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

Attachment Name Attachment Filename 

001 CAS IES report PNC CAS IES report.pdf 2

X

002 GPC analysis GPC k-168.pdf 32

X

CBI SUBMISSION

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ATTACHMENT HEADER SHEET

Attachment Number 001

Attachment Name

CAS IES report

Associated PMN Section Number

N/A

Contains CBI

Report Number

PNCX111121539532664

CBI SUBMISSION
ATTACHMENT HEADER SHEET

Attachment Number 002

Attachment Name

GPC analysis

Associated PMN Section Number

N/A

Contains CBI

Report Number

PNCX111121539532664

CBI SUBMISSION